CFA is concerned that the regulation will both allow insurers to use unverifiable catastrophe models that could lead to excessive homeowners insurance rates and fail to make good insurance coverage more affordable and accessible for California homeowners who are currently finding it difficult to get coverage.

CFA appreciates today's announcement of California's public model project with Cal Poly Humboldt. In light of this announcement, this regulation should be amended to provide that insurers may incorporate use of the public model in its ratemaking without a PRID process and the Department should be required to use this public model as a baseline tool. CFA further urges the Department to delete the several alternative means of complying with insurer commitment goals other than the eighty-five percent standard.

Finally, the rules governing public participation in evaluating insurance rate increases will discourage engagement in the process by consumer advocates. CFA urges the Department to rescind the proposed language that will make consumer representation more risky and less viable.