TITLE insurance

Part I. Texas Department of Insurance

Chapter 5. Property and Casualty Insurance

Subchapter F. Inland Marine Insurance

Division 1. Definition and Classification of Inland Marine Insurance

28 TAC §5.5002

The Texas Department of Insurance proposes an amendment to §5.5002, relating to the definition of inland marine insurance. The amendment adds a new subparagraph (PP) to paragraph (5) to provide that electronic equipment protection coverage is a class of inland marine insurance for which rates, rules, and forms must be filed with the department for approval. The purpose of §5.5002 is to identify the various classifications of risks defined by the department as inland marine insurance. The section designates each defined class or subclass of inland marine insurance as "filed" or "non-regulated" which indicates whether the rates, rules, and forms for such class or subclass of inland marine insurance must be filed with the department for approval. The amendment is necessary to add electronic equipment protection as a defined classification of risk subject to being insured as inland marine insurance. The amendment designates the regulatory status of electronic equipment protection as "filed" which provides that the rules, rates, and forms must be filed with the department and approved by the commissioner. The amendment further provides that coverage for electronic equipment includes the electronic equipment, electronic media, and extra expense incurred in order to continue normal operations and that coverage must be provided while the property is in transit.

Electronic equipment coverage has historically been regulated as commercial property insurance. Traditionally, property insurance covers real property and personal property at set locations. Electronic equipment has been generally classified as personal property at a set location and, therefore, was classified as a commercial property exposure. Article 5.25, the fire rating statute in Texas prior to October 1, 1991, required the department to establish maximum fire rates for all property insured for the peril of fire. Policy forms providing coverage specifically on electronic equipment were introduced prior to October 1, 1991 and the existing regulatory scheme required that such forms be promulgated standard forms and that the rates be promulgated. While other states allowed electronic equipment to be insured as inland marine insurance, Texas considered classification of electronic equipment protection as inland marine insurance to be in conflict with the maximum fire rating laws in Texas. Those classes designated as "filed" classes under the definition of inland marine insurance are regulated under the regulatory system of prior approval for policy forms and rates, and to have classified electronic equipment protection as an inland marine coverage prior to October 1, 1991 would have imposed a less stringent regulatory system on this type of coverage. Therefore, the department would not allow electronic equipment protection to be classified as inland marine insurance in Texas.

The enactment of House Bill 2, 72nd Legislative Session, created new Article 5.13-2 (effective October 1, 1991) which placed commercial property insurance under a new regulatory system of prior approval for policy forms and file and use for rates. The statutory change of regulating commercial property insurance under Article 5.13-2 rather than under Article 5.25 eliminated the regulatory requirement that the department promulgate maximum fire rates for commercial property insurance. All of the classes of risks traditionally considered commercial property insurance (including electronic equipment protection) which had a regulatory system of promulgated forms and rates under Article 5.25 were placed under a new regulatory system enacted in Article 5.13-2 of prior approval for policy forms and file and use for rates.

The department has determined that in the absence of the maximum fire rating law (Article 5.25) as the controlling regulation for all fire insurance, more flexibility now exists as to the choice of the method of insuring specific types of property. Since commercial property is now under the less stringent regulatory scheme of Article 5.13-2, there is no longer a compelling reason not to allow specific types of property, such as electronic equipment, to be insured as inland marine insurance rather than property insurance. The classification of electronic equipment protection as an inland marine coverage does not create a conflict in the regulatory scheme because the regulatory scheme for inland marine and commercial property are similar now that commercial property is regulated under Article 5.13-2. Allowing electronic equipment protection to be classified as inland marine insurance does not conflict with the regulatory scheme under Article 5.13-2 which requires prior approval of policy forms and file and use for rates.

On July 22, 1997 the Texas Insurance Organization (TIO) filed a petition with the Chief Clerk requesting that the department amend the definition of inland marine insurance in 28 TAC §5.5002 to allow electronic equipment protection to be written as inland marine insurance. The text of the rule in TIO's petition designated electronic equipment protection as "filed" making it subject to prior approval for both policy forms and rates. Because many insurers do write electronic equipment as inland marine insurance in other states, the department believes it is cost effective for those insurers to be able to write such property as inland marine insurance in Texas. Insurers that write electronic equipment protection as inland marine insurance in other states, must develop and support a separate system in Texas because currently electronic equipment protection can only be written as commercial property insurance in Texas. Additionally, the department believes that the current regulation of electronic equipment protection pursuant to Article 5.13-2 will remain unchanged allowing insurers the option of writing electronic equipment protection either as commercial property insurance or as inland marine insurance.

Lyndon Anderson, associate commissioner for the property and casualty program of the Texas Department of Insurance, has determined that for the first five-year period the proposed amendment is in effect, there will be no fiscal impact to the state or local units of government as a result of enforcing or administering the section. Mr. Anderson also has determined there will be no other implications for the local economy and no impact on local employment as a result of administering the proposed amendment.

Mr. Anderson also has determined that for each year of the first five years the proposed amendment is in effect the public benefit anticipated as a result of enforcing or administering the proposed amendment will be the more efficient processing of policies by many insurers resulting in a reduction in the expense of doing the business of insurance in Texas. Mr. Anderson has also determined that the proposed amendment will allow insurers greater flexibility and more options in providing the needed coverage resulting in the increased availability of coverage and additional coverage options for consumers. There is no anticipated adverse economic effect on large or small insurers who are required to comply with the proposed amendment. It is anticipated that there would be a benefit to both large and small insurers because with the addition of electronic equipment protection as a class of inland marine insurance, insurers will be able to file the same forms in Texas that they file nationwide, thereby, reducing the insurers' cost of doing business in Texas. Although insurers may have some costs associated with making new filings, those additional costs may be offset by the fact that the insurers will not have to produce a Texas specific policy form which is different from the other programs that the insurers write in other states.

Comments on the proposal to be considered by the department must be submitted within 30 days after publication of the proposed section in the Texas Register to Lynda Nesenholtz, General Counsel and Chief Clerk, Texas Department of Insurance, P.O. Box 149104, Mail Code 113-2A, Austin, Texas 78714-9104. An additional copy of comments should be submitted to Lyndon Anderson, Associate Commissioner, Property and Casualty Division, P. O. Box 149104, MC 103-1A, Austin, Texas 78714-9104. A request for public hearing on the proposed amendment should be submitted separately to the Office of Chief Clerk.

The amendment to §5.5002(5) is proposed pursuant to the Insurance Code, Articles 5.13-2, 5.53, 5.98, and 1.03A; and the Government Code §§2001.004-2001.038. Article 5.13-2 authorizes the commissioner to approve policy forms for commercial property insurance. Article 5.53 authorizes the commissioner to adopt a definition and classes of inland marine insurance. Article 5.98 authorizes the commissioner to adopt reasonable rules and rates that are appropriate to accomplish the purposes of Chapter 5. Article 1.03A authorizes the commissioner to adopt reasonable rules and regulations, which must be for general and uniform regulation, for the conduct and execution of the duties and functions of the department only as authorized by a statute. The Government Code, §§20001.004-2001.038 (Administrative Procedure Act) authorize and require each state agency to adopt rules of practice stating the nature and requirements of available formal and informal procedures and prescribe the procedures for adoption of rules by a state administrative agency.

The following articles of the Insurance Code are affected by this section: Statute Insurance Code, Articles 5.13-2; 5.53

§5.5002.Texas Definition of Inland Marine Insurance.

Inland marine insurance is defined and classified as follows.

(1)-(4)

(No change.)

(5)

Other inland marine risks.

(A)-(OO)

(No change.)

(PP)

Electronic Equipment Protection Policy (filed). Coverage may be provided for electronic equipment, including data processing equipment and components, connections, extensions, and systems; electronic media including converted data; and extra expense incurred in order to continue normal operations which are interrupted as a result of a loss insured. The policy must provide coverage on such property while in transit.

This agency hereby certifies that the proposal has been reviewed by legal counsel and found to be within the agency's legal authority to adopt.

Filed with the Office of the Secretary of State, on January 11, 1999.

TRD-9900119

Lynda H. Nesenholtz

General Counsel and Chief Clerk

Texas Department of Insurance

Earliest possible date of adoption: February 21, 1999

For further information, please call: (512) 463-6327