Florida Submissions

As most of our readers know, Florida is the only state that does not permit rate and form filings through the NAIC online System for Electronic Rate and Form Filing (SERFF). Instead, insurance filings must be drafted and filed directly through Industry Portal on the Florida Office of Insurance Regulation (FLOIR) website.

A central part of each Florida filing submission is the Universal Standardized Data Letter, which contains two required certifications; a readability of submitted forms and the overall filing submission’s compliance with applicable Florida statutes and rules. These certifications have always been required to be signed by a company officer, but in a recent telephone conversation with Mr. James W. Walker, Jr., Senior Management Analyst with FLOIR, he informed me that Florida has adopted a new policy of checking to see if this certifying company officer is also listed on the Jurat page of the latest Company’s Annual Statement. This may be an issue for a number of companies who have many more officers than are listed on the statement.  

Mr. Walker asked that we share this information with our clients and colleagues in the industry. He also noted that if company officers change in between annual filings of the Financial Statement, policy form or rate filers should be aware of this requirement and should make sure that another officer listed on the Jurat page is signing the certifications in any Florida submissions.