An insurer that opts into California's new Comprehensiveness Review will learn the Department's maximum and minimum permissible earned premium within 90 days of submitting, and can then file a rate application that must be approved between 47 and 60 days after public notice (CDI, October 19, 2026). That 60-day ceiling disappears if a hearing petition is granted or the requested change exceeds 7% for personal lines or 15% for commercial lines.
Commissioner Ricardo Lara's office posted the final text and the Statement of Reasons for REG-2025-00024 on October 19 after Office of Administrative Law approval. The rulemaking was filed as exempt from the Administrative Procedure Act under Government Code section 11340.9(g), so there was no formal comment period to summarize; the Statement of Reasons is dated September 8, 2026 and carries the full regulatory text.
Key Takeaways
- 90 days plus 17: the Rate Regulation Branch must issue its range of rate changes within 90 days of a submittal and its affirmative evaluation of comprehensiveness within 17 days after that, extendable by a total of 60 days in 30-day increments, each extension written into SERFF with the deficiencies listed.
- 47 to 60 days after public notice is the approval window for an application carrying the inference of comprehensiveness, against the 180-day period in Insurance Code section 1861.05(c) that an ordinary complete application works under.
- 7% personal, 15% commercial: the 60-day deadline does not apply when a timely hearing petition is filed and either the Commissioner grants it or the proposed change exceeds those thresholds, the same figures that trigger a mandatory hearing under Prop 103.
- Once per line per 180 days is the cap on review requests, and a submittal is rejected outright if a section 1861.05 application for the same line is already pending.
- Zero intervenor compensation inside the review: section 2644.29(c) says the review is not a "proceeding," and subdivision (g) switches off the intervention articles, so Consumer Watchdog's fee mechanism engages only once the application is filed.
How the Two New Sections Fit Together
Section 2644.29 creates the review itself. The insurer sends the Rate Regulation Branch a "submittal" containing everything it believes a complete rate application would require, and the Branch tests whether that package lets it determine legal compliance, perform a complete analysis, and compute the maximum and minimum earned premium that would be permissible under the Prop 103 formula (CDI Statement of Reasons, September 8, 2026). If it can, it issues an "affirmative evaluation of sufficiency to determine a range of rate changes" stating both figures. From there the insurer has 10 days to update the submittal to a rate inside that range or withdraw.
An updated submittal gets one more pass. The Branch either issues an affirmative evaluation of comprehensiveness, meaning the package contains everything needed for approval "to the best of Department staff's knowledge," or a single request for clarification. A revised submittal that still carries the defect terminates the review with a notice citing what remains. Every submittal, evaluation, request and extension is published in SERFF for public inspection under subdivision (h), so the Department's indicated range becomes a public document before any rate application exists.
Section 2648.2.2 converts the evaluation into a filing advantage. An application filed within 16 days of the evaluation, consisting only of a statement incorporating the submittal by reference, carries an "inference of comprehensiveness" with four effects: the 30-day completeness review under section 2648.2 does not apply, public notice goes out within 10 days, approval may not come before day 47 after notice, and must come by day 60. The Statement of Reasons describes the purpose as a way to "fast-track" most complete rate applications, and the Department's press release claims its review of hundreds of filings a year has saved consumers $6.6 billion since 2019.
What the Range Does to a Filing Strategy
Everything in the review turns on the maximum permissible earned premium, which is the output of the Prop 103 ratemaking formula in sections 2644.2 and 2644.3: projected losses and defense costs, adjusted for fixed investment income and net of ancillary income, divided by a denominator built from the efficiency standard and the profit factor, all applied to the insurer's own data.
Today an insurer learns that number through objections and negotiation over months of a pending application, with the 180-day deemer and a possible hearing as the outer bound. Under 2644.29 it learns the number first, in writing, in 90 days, with no application on file and no intervenor at the table.
Filing at the top of the published range is the rational response, and the regulation anticipates it: subdivision (d)(2)(A) requires the update to "comport with the range," and the Department is then committed, to the best of its knowledge, to the view that a filing at that rate is approvable.
For a homeowners book that would otherwise request 6% and settle at 4% after a year of correspondence, the review compresses the process into a 90-day indication plus a 47-to-60-day approval, roughly 150 days end to end with no extensions. Per the Statement of Reasons, the 47-day floor is there "to protect the public's statutory right of intervention," so the window is the time the public has to petition.
What can go into the submittal bounds the range. Subdivision (e) excludes rates for specialty insurance, any update to a class plan under section 2632.11, and any model used for segmentation, underwriting or risk scoring. A catastrophe model can be included only to project annual aggregate cat loss, and only with a pre-application required information determination under section 2648.5 that will still be valid 180 days after the review starts, or for earthquake, fire following, flood and terrorism.
The wildfire models the Department certified under its Sustainable Insurance Strategy therefore enter the review on the PRID timeline, and a filing that also changes territorial relativities through a class plan cannot use it at all.
The Threshold That Takes the Fast Track Away
Subdivision (b)(4) of section 2648.2.2 removes the 60-day approval deadline when a timely petition for hearing is filed and either the Commissioner grants it or the proposed rate adjustment exceeds 7% for personal lines or 15% for commercial lines. Those are the thresholds in Insurance Code section 1861.05(c) at which a requested hearing becomes mandatory. The regulation does not raise them, and it does not say how long an above-threshold application takes once a petition lands; it says only that the fast-track clock stops. The filings that have defined the California market since 2023, homeowners increases in the high teens and twenties, sit above the line.
Even the inference is conditional. Section 2648.2.2(a)(2) detaches it if any fact unknown to Department staff when the evaluation issued later indicates the submittal was incomplete, and the Statement of Reasons says this matters "particularly" because the public has no explicit opportunity for input during the review and instead participates at the application stage. An intervenor that surfaces such a fact in the 47-day petition window converts a fast-track filing back into an ordinary one. Having been excluded from the review, intervenors meet the filing at the one point where the regulation lets a new fact undo it.
A 180-day cap per line also prices the option. A submittal that terminates on an uncured defect, or that returns a range the insurer will not accept, locks the line out of a second attempt for six months, and a pending 1861.05 application for the same line is grounds for rejection, so an insurer cannot run both tracks at once. A carrier gets the Department's formula answer early and in public; it does not get a dated approval for the rate changes large enough to have needed one.
Further Reading
- California's Intervenor Overhaul Rewrites Who Pays to Fight a Rate Filing – the August 2026 rule that governs the intervention stage this regulation routes around.
- Three Models, One Green Light: CDI Wildfire Cat Model Certifications and What They Require of P&C Rate Filings – the PRID exhibit requirements that decide whether a cat model can enter a review submittal.
- California's First Cat Model Approval Reshapes Property Rate Filings – how AAL-based pricing changed the content of a complete rate application.
- Illinois's Rate-Review Law Turns Actuarial Credibility Into a Statutory Test – another state writing review timelines into regulation, with a 40-day objection window.
- Lara Moves to Strip Marital Status From California Auto Rates – a class plan change of the kind section 2644.29(e)(3) keeps out of the review.
Sources
- California Department of Insurance, "Commissioner Lara opens insurance rate review process to unprecedented transparency," press release 037-2026, October 19, 2026
- California Department of Insurance, Statement of Reasons, Comprehensiveness Review; Complete Rate Application, REG-2025-00024, September 8, 2026
- California Department of Insurance, Final Text of Regulation, REG-2025-00024
- Insurance Journal, "California Adds Voluntary Review Before Insurers File Rate Applications," October 19, 2026
- California Department of Insurance, Sustainable Insurance Strategy