From MPowell at firstam.com Wed Aug 6 15:27:26 2025 From: MPowell at firstam.com (Megan Powell) Date: Wed, 6 Aug 2025 22:27:26 +0000 Subject: [Wltaunderwritersection] R 2025-05: Proposed Rule re Claims Handling Message-ID: This email is being sent to all of the members of the Underwriters Section of the WLTA. The Washington State Office of the Insurance Commissioner released a prepublication draft for claims handling minimum standards rule (R2025-05). Comments on the prepublication draft are due on August 8, 2025 and can be sent to rulescoordinator at oic.wa.gov. The text of the prepublication draft can be found here. It is also attached to this email. Each Underwriter should consider whether they want to provide their own comments to the OIC. It is my understanding there is also a draft letter in process that will be provided to the WLTA Board for consideration to submit on behalf of the industry as a whole. Since we have a short timeframe it would be appreciated if each Underwriter could provide any comments they have promptly. Please let me know if you have any questions. Thank you. __________________________________________________ Megan Powell Director of Underwriting - Direct Division [Description: https://www.firstam.com/assets/email/images/fa-logo-signature.jpg] First American Title Insurance Company Madison Centre 920 Fifth Avenue, Suite 1250 Seattle, WA 98104 Direct: 206-615-3285 Mobile: 206-375-3491 Email: mpowell at firstam.com A member of the First American Financial Corporation family of companies | NYSE: FAF [cid:image002.png at 01DC06E5.C01BB130] [A blue rectangular sign with white text AI-generated content may be incorrect.] ****************************************************************************************** This message may contain confidential or proprietary information intended only for the use of the addressee(s) named above or may contain information that is legally privileged. If you are not the intended addressee, or the person responsible for delivering it to the intended addressee, you are hereby notified that reading, disseminating, distributing or copying this message is strictly prohibited. If you have received this message by mistake, please immediately notify us by replying to the message and delete the original message and any copies immediately thereafter. If you received this email as a commercial message and would like to opt out of future commercial messages, please let us know and we will remove you from our distribution list. Thank you. ****************************************************************************************** FAFLD -------------- next part -------------- An HTML attachment was scrubbed... URL: -------------- next part -------------- A non-text attachment was scrubbed... Name: image001.jpg Type: image/jpeg Size: 5008 bytes Desc: image001.jpg URL: -------------- next part -------------- A non-text attachment was scrubbed... Name: image002.png Type: image/png Size: 27536 bytes Desc: image002.png URL: -------------- next part -------------- A non-text attachment was scrubbed... Name: image003.png Type: image/png Size: 25178 bytes Desc: image003.png URL: -------------- next part -------------- A non-text attachment was scrubbed... Name: r2025-05-first-prepublication-draft.pdf Type: application/pdf Size: 242041 bytes Desc: r2025-05-first-prepublication-draft.pdf URL: From CTrummel at wfgtitle.com Thu Aug 7 09:26:33 2025 From: CTrummel at wfgtitle.com (Craig Trummel) Date: Thu, 7 Aug 2025 16:26:33 +0000 Subject: [Wltaunderwritersection] R 2025-05: Proposed Rule re Claims Handling In-Reply-To: References: Message-ID: <643eb9fc51374c7ea1031b8ea179d617@wfgtitle.com> Megan: Comments from WFG: Systemic concerns: 1. We have a duty to report certain sanctions and adverse findings to all of our regulators. By redefining every "foot fault" as an "unfair and deceptive practices" broadly, this would increase the number of notifications that Don has to do and trigger a lot of unnecessary investigations in other states. 2. The requirement of a full and complete investigation for any denial - can't rely only on databases is simply wrong for title. I don't need to investigate very far beyond policy language for many types of claims; and the first and sometimes only step needed on some claims is to rerun the title search (which is a database) and see if the claimant missed any documents. "You don't have a claim, because that mortgage really was satisfied." 3. This triggers short time-frames based on a notification to an agent. That may work in auto and P&C where the agent is on the front lines of processing claims, but not in title. Maybe the Title Industry can convince the OIC to allow the WLTA to assist in creating separate and appropriate rules governing title insurance, instead of shoe horning us into the casualty insurance sphere? craig [cid:image005.png at 01DC077D.5C366F50][WLTA-WTP1 LOGO small] Craig Trummel Regional Underwriter/Washington State Counsel C: 206.580.8344 | ctrummel at wfgtitle.com | www.wfgtitle.com Confidentiality Notice: The information contained in this electronic e-mail and any accompanying attachment(s) is intended only for the use of the intended recipient and is non-public in nature and may be confidential and/or privileged. If any reader of this communication is not the intended recipient, unauthorized use, disclosure, dissemination or copying is strictly prohibited, and may be unlawful. If you have received this communication in error, please immediately notify the sender by return e-mail, and delete the original message and all copies from your system and promptly destroy any copies made of this electronic message. Click Here for WFG's Plain English Privacy Policy From: Wltaunderwritersection [mailto:wltaunderwritersection-bounces at washingtonlandtitle.com] On Behalf Of Megan Powell Sent: Wednesday, August 6, 2025 3:27 PM To: wltaunderwritersection at washingtonlandtitle.com Subject: [Wltaunderwritersection] R 2025-05: Proposed Rule re Claims Handling This email is being sent to all of the members of the Underwriters Section of the WLTA. The Washington State Office of the Insurance Commissioner released a prepublication draft for claims handling minimum standards rule (R2025-05). Comments This email is being sent to all of the members of the Underwriters Section of the WLTA. The Washington State Office of the Insurance Commissioner released a prepublication draft for claims handling minimum standards rule (R2025-05). Comments on the prepublication draft are due on August 8, 2025 and can be sent to rulescoordinator at oic.wa.gov. The text of the prepublication draft can be found here [insurance.wa.gov]. It is also attached to this email. Each Underwriter should consider whether they want to provide their own comments to the OIC. It is my understanding there is also a draft letter in process that will be provided to the WLTA Board for consideration to submit on behalf of the industry as a whole. Since we have a short timeframe it would be appreciated if each Underwriter could provide any comments they have promptly. Please let me know if you have any questions. Thank you. __________________________________________________ Megan Powell Director of Underwriting - Direct Division [Description: https://www.firstam.com/assets/email/images/fa-logo-signature.jpg] First American Title Insurance Company Madison Centre 920 Fifth Avenue, Suite 1250 Seattle, WA 98104 Direct: 206-615-3285 Mobile: 206-375-3491 Email: mpowell at firstam.com A member of the First American Financial Corporation [firstam.com] family of companies | NYSE: FAF [firstam.com] [cid:image010.png at 01DC077D.5C366F50] [A blue rectangular sign with white text AI-generated content may be incorrect.] ****************************************************************************************** This message may contain confidential or proprietary information intended only for the use of the addressee(s) named above or may contain information that is legally privileged. If you are not the intended addressee, or the person responsible for delivering it to the intended addressee, you are hereby notified that reading, disseminating, distributing or copying this message is strictly prohibited. If you have received this message by mistake, please immediately notify us by replying to the message and delete the original message and any copies immediately thereafter. If you received this email as a commercial message and would like to opt out of future commercial messages, please let us know and we will remove you from our distribution list. Thank you. ****************************************************************************************** FAFLD -------------- next part -------------- An HTML attachment was scrubbed... URL: -------------- next part -------------- A non-text attachment was scrubbed... Name: image008.jpg Type: image/jpeg Size: 5008 bytes Desc: image008.jpg URL: -------------- next part -------------- A non-text attachment was scrubbed... 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