While the guidelines and recommendations contained in Circular Letter No. 11 continue to be workable, they may not be suitable to meet the unique needs of some insurers. The Department recognizes that there may be other innovative approaches that would enable an insurer to write business and/or retain existing business in coastal areas. For example, responses to a recent request to the industry regarding the use of catastrophe modeling in rate-making are presently being analyzed.

The Department is also contemplating modifications to the guidelines in Circular Letter 11, such as increasing the amount of the windstorm deductible and more closely coupling the deductible with hazard mitigation on the part of the insured and, under the wrap-around concept, having NYPIUA instead of the voluntary insurer provide contents coverage.

The Department wants to continue this dialogue and encourages insurers to discuss with and submit to the Department any new approaches, including modifications to the existing windstorm deductibles or wrap-around protection. that would meet the needs of the homeowner while still protecting insurer solvency. Any new approaches and modifications will be reviewed on an individual basis depending on the unique needs of the insurer and its policyholders.

Any new approaches or modifications should be submitted to:

Mr. Gerald Scattaglia
Supervising Examiner
New York State Insurance Department
Property Casualty Bureau
160 West Broadway, 13th Floor
New York, New York 10013