[Wltaunderwritersection] R 2025-05: Proposed Rule re Claims Handling

Thu Aug 7 09:26:33 PDT 2025

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

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Craig Trummel
Regional Underwriter/Washington State Counsel
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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<mailto:rulescoordinator at oic.wa.gov>.

The text of the prepublication draft can be found here [insurance.wa.gov]<https://urldefense.com/v3/__https:/www.insurance.wa.gov/laws-rules/legislation-and-rulemaking/rulemaking/clarifying-and-updating-minimum-standards-claims-handling-r-2025-05?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery&utm_term=__;!!D1GiJZDdVrw!YZDmlDM0WJXxm2viRJBvtGIegASxYjIIRYaMrMYitxI96YqpoIJSp3GmjLT6OqosP-K2rmv4xXW13EEA0g$>.  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

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