Tesla Texas Insurance Redpoint Co Mutual

SERFF Tracking #: MISF-132484597 State Tracking #: UG-2020-09-012 Company Tracking #: RCMIC-PA-TX-2001-UW
State: Texas Filing Company: Redpoint County Mutual Insurance Company

TOI/Sub-TOI: 19.0 Personal Auto/19.0001 Private Passenger Auto (PPA)
Product Name: Personal Auto
Project Name/Number: /
Table of Contents
User Usage Agreement
Attachments
Usage Agreement Usage Agreement.pdf
Supporting Document (ex. Supporting Document Name Attachment Name)

Attachments
Filing Authorization Letter Tesla Insurance Services - Milliman Authorization Letter 08 07
2020.pdf
PDF Pipeline for SERFF Tracking Number MISF-132484597 Generated 01/05/2021 12:42 AM

Filing at a Glance
Company: Redpoint County Mutual Insurance Company
State: Texas
TOI: 19.0 Personal Auto
Sub-TOI: 19.0001 Private Passenger Auto (PPA)
Filing Type: Underwriting Guidelines
Date Submitted: 09/09/2020
SERFF Tr Num: MISF-132484597
SERFF Status: Closed-CL-Closed; No additional info required at this time
State Tr Num: UG-2020-09-012
State Status: GF-Underwriting Guidelines (FULL)
Co Tr Num: RCMIC-PA-TX-2001-UW
Effective Date 12/01/2020

Requested (New):
Effective Date
Requested (Renewal):
Author(s): Sheri Scott, Courtney Burke, Celine Showman, Christine O'Brien, Matt Samuel, Linda Hancock
Reviewer(s): Eric Hintikka (primary), Sharalyn Taylor-Hargrove, Roberto Piedra
Disposition Date: 01/04/2021
Disposition Status: CL-Closed; No additional info required at this time
Effective Date (New):
Effective Date (Renewal):

General Information
Project Name: Status of Filing in Domicile:
Project Number: Domicile Status Comments:
Reference Organization: Reference Number:
Reference Title: Advisory Org. Circular:
Filing Status Changed: 01/04/2021
State Status Changed: 12/02/2020 Deemer Date:
Created By: Courtney Burke Submitted By: Courtney Burke
Corresponding Filing Tracking Number: RCMIC-PA-TX-2001-
F, RCMIC-PA-TX-2001-R, RCMIC-PA-TX-2001-CS
State TOI: Personal Automobile State Sub-TOI: Personal Auto
Filing Description:
Redpoint County Mutual Insurance Company (Redpoint) is pleased to announce its new Private Passenger Auto (PPA) Tesla
Insurance Program for private passenger auto in the State of Texas. The program will be distributed through the digital
InsurTech platform from Tesla Insurance Services of Texas, Inc. (Tesla), formerly called Samson General Agency, Inc.
Company and Contact

Filing Contact Information
Sheri Scott, FCAS, MAAA, Principal and sheri.scott@milliman.com
Actuary
Milliman, Inc. 714-933-1100 [Phone]
19200 Von Karman Avenue
Irvine, CA 92612
Filing Company Information

(This filing was made by a third party - MUSA04)
Redpoint County Mutual Insurance CoCode: 29300 State of Domicile: Texas
Company Group Code: Company Type:
13215 Bee Cave Parkway, Group Name: State ID Number:
Building 2, Suite 150 FEIN Number: 75-6043791
Austin, TX 78738
(737) 615-4700 ext. [Phone]

Filing Fees
State Fees
Fee Required? No
Retaliatory? No
Fee Explanation:
State Specific
1.[PII] Does this filing contain any personally identifiable information (PII)? (See SERFF General Instructions for the definition
and examples of PII.) Answer either YES or NO: : No
2.[Associated filing] Provide the TDI file number or SERFF tracking number for all associated filings: : MISF-132490558
(forms), MISF-132484598 (rate/rule), MISF-132492963 (credit scoring)
3.[Deemer date] Do you waive the deemer for form, endorsement, and certificate of insurance filings under 28 TAC 5.9321?
Answer either YES or NO: : not applicable (UW guideline filing)
4.Do you waive the limits on requests for information for rate/rule filings under 28 TAC 5.9336? Answer either YES or NO:: not
applicable (UW guideline filing)
5.[Replacement number] Provide the TDI file number of the previously approved forms and endorsements or accepted rates,
rules, or rate/rules that you are replacing: : not applicable (new program)
6.[Reference/adopt] Provide the TDI file number that contains approved forms and endorsements or accepted rates, rules, or
rate/rules that you are referencing/adopting.: not applicable (not an adoption filing)
7.[Interline] State if this is an interline filing and list all lines of insurance the endorsement or rate/rules applies to. : not
applicable (not an interline filing)
8.[Dual] For dual filings (monoline and multi-peril) state if this is a new program. If not, provide the TDI file number for either the
previous dual filing, or the previous monoline and multi-peril filings approved for this program:: not applicable (not a dual filing)
9.[Policy form] What policy form do these endorsements and forms go with? List the TDI file number where the policy form was
approved or referenced:: not applicable (new program)
10.[RPG] Will this filing be used for a Risk Purchasing Group? Answer either YES or NO. If yes, provide the name: : No
11. [COVID-19] Is this filing related to the COVID-19 pandemic? Answer either YES or NO.: No

Correspondence Summary
Dispositions
Status Created By Created On Date Submitted
CL-Closed; No Eric Hintikka 01/04/2021 01/04/2021
additional info
required at this
time
CL-Closed; No Eric Hintikka 12/02/2020 12/02/2020
additional info
required at this
time
Objection Letters and Response Letters

Objection Letters Response Letters
Status Created By Created On Date Submitted Responded By Created On Date Submitted
Revision Roberto Piedra 11/04/2020 11/04/2020 Christine O'Brien 11/05/2020 11/05/2020
Requested
Information Roberto Piedra 10/09/2020 10/09/2020 Courtney Burke 10/13/2020 10/13/2020
Requested
Information Sharalyn Taylor- 10/04/2020 10/04/2020 Courtney Burke 10/05/2020 10/05/2020
Requested Hargrove
Amendments
Schedule Schedule Item Name Created By Created On Date Submitted
Rate Underwriting Guidelines Matt Samuel 12/23/2020 12/23/2020
Rate Safety Score Definitions Matt Samuel 12/23/2020 12/23/2020
Supporting Underwriting Guidelines in Track Changes Mode Matt Samuel 12/23/2020 12/23/2020
Document

Disposition
Status: CL-Closed; No additional info required at this time
Comment: We are closing this filing. You do not need to take any further action. Please include this filing’s state tracking number if you refer to it in a future filing.
Reminder: Insurers writing personal automobile, residential property, and workers’ compensation insurance must file a complete set of underwriting guidelines every
three years by March 1. 28 TAC Section 5.9342. Questions? Contact 512-676-6710.
Rate data does NOT apply to filing.
Schedule Schedule Item Schedule Item Status Public Access

Supporting Document Does this filing contain confidential information? Yes
Supporting Document Underwriting Guidelines Yes
Supporting Document Filing Authorization Letter Yes

Disposition
Status: CL-Closed; No additional info required at this time
Comment: We are closing this filing. You do not need to take any further action. Please include this filing’s state tracking number if you refer to it in a future filing.
Reminder: Insurers writing personal automobile, residential property, and workers’ compensation insurance must file a complete set of underwriting guidelines every
three years by March 1. 28 TAC Section 5.9342. Questions? Contact 512-676-6710.
Schedule Schedule Item Schedule Item Status Public Access

Supporting Document Does this filing contain confidential information? Yes
Supporting Document Underwriting Guidelines Yes
Supporting Document Filing Authorization Letter Yes

Objection Letter
Objection Letter Status Revision Requested
Objection Letter Date 11/04/2020
Submitted Date 11/04/2020
Respond By Date 11/10/2020
Dear Sheri Scott,
Introduction:
Thank you for your assistance during our review of this filing. Please address the comment below.
Objection 1
Comments: Page 1. Ineligible Risks. E. Vehicles used in business except
When used by an artisan to deliver or transport goods or materials and such use is incidental to the insured's business of installing,
maintaining or repairing furnishings or equipment; and
This section conflicts with Insurance Code Section 1952.059(c). Coverage is required for a newly acquired vehicle that is not used for
the delivery or transportation of goods, materials, or supplies, other than samples, unless:
(A) the delivery of the goods, materials, or supplies is not the primary use for which the vehicle is employed; or
(B) the vehicle is used for farming or ranching.
Change this section to more closely track with 1952.059(c) or add an exception for a newly acquired vehicle.
Conclusion:
If you have questions about this filing, you may contact me at (512) 676-6721 or by email at roberto.piedra@tdi.texas.gov.
Sincerely,
Roberto Piedra

Objection Letter
Objection Letter Status Information Requested
Dear Sheri Scott,
Introduction:
In review of this filing, the following items are identified for further review/revision:
Objection 1
Comments: Page 1.
Eligible Risks
A. Policies purchased through Tesla Insurance Services., Inc. for households with one or more Tesla private passenger vehicles.
Ineligible Risks
E. Vehicles used in business except
- When used by an artisan to deliver or transport goods or materials and such use is incidental to the insured's business of installing,
- With a Gross Vehicle Weight less than 10,000 lbs.
We are reviewing these sections as they appear to conflict with Insurance code section 1952.059. Please explain how you will comply
if a policyholder replaces or adds a vehicle that weighs over 10,000 pounds, or replaces the only Tesla on the policy with a vehicle
that is not a Tesla.
Conclusion:
If you have questions about this filing, you may contact me at (512) 676-6721 or by email at roberto.piedra@tdi.texas.gov.
Sincerely,
Roberto Piedra

Objection Letter
Objection Letter Status Information Requested
Dear Sheri Scott,
Introduction:
Objection 1
- Underwriting Guidelines (Supporting Document)
Comments: Please let us know if you consider this submission a 'full set' or a 'partial set' in accordance with 28 TAC
§§5.9355-5.9357, 28 TAC §5.5005 and Texas Insurance Code §38.002 for Personal Automobile and Residential
Property, and §2053.034 for Workers' Compensation.
Conclusion:
Sincerely,
Sharalyn Taylor-Hargrove

Response Letter
Response Letter Status Submitted to State
Response Letter Date 11/05/2020
Dear Eric Hintikka,
Introduction:
Response 1
Comments:
We have amended the section to comply with Texas Insurance Code §1952.059(c).
Related Objection 1
Comments: Page 1. Ineligible Risks. E. Vehicles used in business except
When used by an artisan to deliver or transport goods or materials and such use is incidental to the insured's business of installing,
This section conflicts with Insurance Code Section 1952.059(c). Coverage is required for a newly acquired vehicle that is not used for
the delivery or transportation of goods, materials, or supplies, other than samples, unless:
(A) the delivery of the goods, materials, or supplies is not the primary use for which the vehicle is employed; or
(B) the vehicle is used for farming or ranching.
Change this section to more closely track with 1952.059(c) or add an exception for a newly acquired vehicle.
Changed Items:
No Supporting Documents changed.
No Form Schedule items changed.
No Rate/Rule Schedule items changed.

Conclusion:
Sincerely,
Christine O'Brien

Response Letter
Dear Eric Hintikka,
Introduction:
Response 1
Comments:
We have amended the underwriting guidelines to clarify how the program will comply with Insurance code section 1952.059
Related Objection 1
Comments: Page 1.
Eligible Risks
A. Policies purchased through Tesla Insurance Services., Inc. for households with one or more Tesla private passenger vehicles.
Ineligible Risks
E. Vehicles used in business except
- When used by an artisan to deliver or transport goods or materials and such use is incidental to the insured's business of installing,
- With a Gross Vehicle Weight less than 10,000 lbs.
We are reviewing these sections as they appear to conflict with Insurance code section 1952.059. Please explain how you will comply
if a policyholder replaces or adds a vehicle that weighs over 10,000 pounds, or replaces the only Tesla on the policy with a vehicle
that is not a Tesla.
Changed Items:

Conclusion:
Sincerely,
Courtney Burke

Response Letter
Dear Eric Hintikka,
Introduction:
Response 1
Comments:
This underwriting guidelines submission is a full set for this Tesla Insurance Program.
Also, we have made an update to the underwriting guidelines. The only change from previously submitted version is under Item B on
page 3. The first bullet now refers to Tier 6 instead of Tier 5.
Related Objection 1
Applies To:
- Underwriting Guidelines (Supporting Document)
Comments: Please let us know if you consider this submission a 'full set' or a 'partial set' in accordance with 28 TAC
§§5.9355-5.9357, 28 TAC §5.5005 and Texas Insurance Code §38.002 for Personal Automobile and Residential
Property, and §2053.034 for Workers' Compensation.
Changed Items:

Conclusion:
Sincerely,
Courtney Burke

Amendment Letter
Submitted Date: 12/23/2020
Comments:
Dear Reviewer,
As per our telephone call last week, during programming of the proposed Tesla Insurance Program, Tesla has identified several items to facilitate the implementation of
the program approved under Redpoint County Mutual Insurance Company (Redpoint) State Filing UG-2020-09-012. No policies have been quoted or written under the
program. The following revisions to the approved filing are submitted for your review.
Enhance the Safety Score Program
With the change from discrete 10 Safety Tier factors to a continuous and gradual Safety Score and interpolated factor, it is proposed that the 2 tier movement capping
also be removed. This enables the eligible vehicles to fully utilize the discount indicated by the Safety Score Model. A revised underwriting guideline, with both the
proposed factors at various scores and the capping rule removed, has been submitted with this note in final view mode, as well as in track changes from the prior
version approved for ease of reference.
All Tesla Vehicles Will Automatically Opt-in to the Safety Score Program.
The underwriting guidelines have been updated to reflect that all Tesla vehicles that meet the eligibility guidelines will automatically enroll in the Safety Score Program
and will receive a Safety Score. The vehicle safety score differentiates risk and better matches insurance rates to the expected future loss. The option for vehicles that
qualify for the Safety Score Program to opt-out of the program has been removed.
For vehicles that have missing values for part of the data collected to calculate the Safety Score, the revenue neutral value will be used.
We respectfully request this amendment filing to be effective January 14, 2021. Please find the required Exhibits and UW Guidelines for this amendment attached with
the filing.
Sincerely,
Matthew Samuel
Changed Items:
No Form Schedule Items Changed.
No Rate Schedule Items Changed.
No Supporting Documents Changed.


Rate Information

Supporting Document Schedules

Satisfied - Item: Does this filing contain confidential information?
Comments: Yes
Attachment(s):
Item Status:
Status Date:
Satisfied - Item: Underwriting Guidelines

Comments: Acknowledged
Attachment(s):
Item Status:
Status Date:
Satisfied - Item: Filing Authorization Letter

Comments:
Attachment(s): Tesla Insurance Services - Milliman Authorization Letter 08 07 2020.pdf
Item Status:
Status Date:

Tesla Texas Insurance Redpoint Co Mutual

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SERFF Tracking #: MISF-132484597 State Tracking #: UG-2020-09-012 Company Tracking #: RCMIC-PA-TX-2001-UW

State: Texas Filing Company: Redpoint County Mutual Insurance Company

Supporting Document (ex. Supporting Document Name Attachment Name)

State: Texas Filing Company: Redpoint County Mutual Insurance Company

Effective Date 12/01/2020

State: Texas Filing Company: Redpoint County Mutual Insurance Company

Company and Contact

Filing Company Information

State: Texas Filing Company: Redpoint County Mutual Insurance Company

State: Texas Filing Company: Redpoint County Mutual Insurance Company

Objection Letters and Response Letters

State: Texas Filing Company: Redpoint County Mutual Insurance Company

Rate data does NOT apply to filing.

Schedule Schedule Item Schedule Item Status Public Access

State: Texas Filing Company: Redpoint County Mutual Insurance Company

Rate data does NOT apply to filing.

Schedule Schedule Item Schedule Item Status Public Access

State: Texas Filing Company: Redpoint County Mutual Insurance Company

(B) the vehicle is used for farming or ranching.

State: Texas Filing Company: Redpoint County Mutual Insurance Company

State: Texas Filing Company: Redpoint County Mutual Insurance Company

State: Texas Filing Company: Redpoint County Mutual Insurance Company

(B) the vehicle is used for farming or ranching.

No Supporting Documents changed.

No Form Schedule items changed.

No Rate/Rule Schedule items changed.

State: Texas Filing Company: Redpoint County Mutual Insurance Company

No Supporting Documents changed.

No Form Schedule items changed.

No Rate/Rule Schedule items changed.

State: Texas Filing Company: Redpoint County Mutual Insurance Company

No Supporting Documents changed.

No Form Schedule items changed.

No Rate/Rule Schedule items changed.

State: Texas Filing Company: Redpoint County Mutual Insurance Company

Enhance the Safety Score Program

No Rate Schedule Items Changed.

No Supporting Documents Changed.

State: Texas Filing Company: Redpoint County Mutual Insurance Company

State: Texas Filing Company: Redpoint County Mutual Insurance Company

State: Texas Filing Company: Redpoint County Mutual Insurance Company

Supporting Document Schedules

Satisfied - Item: Underwriting Guidelines

Satisfied - Item: Filing Authorization Letter

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