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My name is R.J. Lehmann and I am administrator of finance, allowance and barter action at the R Street Institute. R Street is a anticipate catchbasin adherent to businesslike free-market solutions to accessible action challenges and that has affianced on allowance authoritative issues back our founding eight years ago.

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I address you in action to S.B. 17, legislation that would bar absolutely the use of acclaim history in appraisement risks underwritten by private-passenger auto-insurance policies. We accept this legislation would accept a deleterious aftereffect on the competitiveness of Maryland’s already-concentrated clandestine auto allowance market, advance to added behavior actuality transferred to the high-risk Maryland Auto Allowance Fund (MAIF) and leave consumers with beneath adorable and affordable auto allowance products.

Over the accomplished 30 years, the use of ambiguous beeline models (GLM) to actualize credit-based allowance array has revolutionized the claimed auto band of business. The analysis of actuarially aboveboard variables angry to acclaim advice has accustomed insurers to assemble abundantly avant-garde models that can accredit a able amount to around any abeyant insured. Whereas in the 1980s, some states saw as abundant as bisected of all auto-insurance consumers shunted into balance markets, these insurers-of-last-resort today annual for beneath than 0.1 percent of the bazaar in 34 of the 50 states.[1] [1]

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To the admeasurement that it reverses this advance against active aggressive markets, affective to outlaw the use of acclaim in allowance rate-setting would account cogent disruption in any state. It should be of accurate affair in Maryland, which already struggles with a beneath than active auto-insurance market. Maryland accustomed a brand of “C” in the R Street Institute’s 2019 Allowance Regulation Address Card,[2] [2] as its auto-insurance bazaar denticulate decidedly ailing on two benchmarks of competitiveness. With a bazaar allotment of 1.57 percent of claimed auto premiums, MAIF charcoal the fourth-largest balance auto allowance bazaar in the nation. Moreover, the Herfindahl-Hirschman Index – a bazaar absorption apparatus acclimated by the U.S. Department of Justice (DOJ) and the Federal Barter Commission (FTC) to appraise the amount to which markets are accountable to monopolistic absorption – finds that Maryland is the seventh-most concentrated auto-insurance bazaar in the nation.

Banning the use of acclaim in rate-setting would do added accident to the competitiveness of Maryland’s auto-insurance market. It additionally would be reflected anon in a lower account in the R Street address card, which alone assigns demerits for approved prohibitions that bind underwriting freedom. Maryland’s account already reflects that it is currently one of aloof two states, forth with California, to bar the use of acclaim in homeowners allowance rating.

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Studies by, amid others, the Texas Department of Allowance and the Federal Barter Commission[3] [3] authenticate actually that acclaim factors are predictive of approaching claims. What’s more, the Maryland Allowance Administration already has at its auctioning all-encompassing authoritative accoutrement to ensure that ante submitted by auto insurers are not excessive, bereft or unfairly discriminatory. We appetite the board to adios this legislation.

[1] [4] https://www.aipso.com/Portals/0/IndustryData/Ranking Of States By Balance And Total Bazaar Premium_BD047_2018.xlsx?ver=2019-08-28-143340-300 [5].

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[2] [6] https://www.rstreet.org/wp-content/uploads/2019/12/191.pdf [7].

[3] [8] https://www.ftc.gov/reports/credit-based-insurance-scores-impacts-consumers-automobile-insurance-report-congress-federal [9].

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