Risk & Regulatory Consulting (“RRC” or “we”) supports the efforts of the Big Data (EX) Working Group (“BDWG”) to create a mechanism that increases the resources available to states for the review and collection of data related to complex ratemaking models for property and casualty insurance coverages. We also support the conceptual framework proposed for the mechanism, consisting of a Predictive Analytics Team (“PAT”) and a Predictive Analytics Working Group (“PAWG”). We have reviewed the proposal and offer the following comments for your consideration. We would be glad to answer any questions, and we appreciate the opportunity to offer our comments.

Model Definition

The proposal refers in several instances to “models”. RRC recommends that the proposal specify the types of models to be included within the PAT’s purview, as “model” can be interpreted in numerous fashions, not all of which may be relevant to the BDWG.