SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Filing at a Glance Company: Zurich American Insurance Company Product Name: Pet Insurance Program State: California TOI: 09.0 Inland Marine Sub-TOI: 09.0004 Pet Insurance Plans Filing Type: New Program Date Submitted: 04/25/2019 SERFF Tr Num: ZURC-131915450 SERFF Status: Closed-Approved State Tr Num: 19-1596 State Status: Approved Co Tr Num: 42557

Effective Date 07/01/2019 Requested (New): Effective Date 07/01/2019 Requested (Renewal): Author(s): Paula Bartell Reviewer(s): Won Choi (primary), William Lee Disposition Date: 09/24/2019 Disposition Status: Approved Effective Date (New): Effective Date (Renewal):

This filing was provided as part of The California Insurance ADVISOR Subscribe @ www.martincompanyus.com or call 800-896-8000

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

General Information Project Name: Status of Filing in Domicile: Pending Project Number: 42557 Domicile Status Comments: Reference Organization: Reference Number: Reference Title: Advisory Org. Circular: Filing Status Changed: 09/24/2019 State Status Changed: 09/24/2019 Deemer Date: 07/09/2019 Created By: Paula Bartell Submitted By: Paula Bartell

Corresponding Filing Tracking Number: Filing Description: Zurich American Insurance Company is submitting a new Zurich Pet Illness and Injury Insurance Policy. This policy provides reimbursement for reasonable and necessary veterinary expenses incurred due to the Pet's illness or injury.

Company and Contact Filing Contact Information Paula Bartell, Project Manager [email protected] 1299 Zurich Way 847-605-6177 [Phone] Schaumburg, IL 60196-1056 847-240-4514 [FAX]

Filing Company Information Zurich American Insurance CoCode: 16535 State of Domicile: New York Company Group Code: 212 Company Type: 1299 Zurich Way Group Name: State ID Number: Schaumburg, IL 60196 FEIN Number: 36-4233459 (847) 605-6000 ext. [Phone]

Filing Fees Fee Required? No Retaliatory? No Fee Explanation: State Specific Variance Requested? (Yes/No): No

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Correspondence Summary Dispositions Status Created By Created On Date Submitted Approved William Lee 09/24/2019 09/24/2019

Objection Letters and Response Letters Objection Letters Response Letters

Status Created By Created On Date Submitted Responded By Created On Date Submitted Pending Won Choi 09/20/2019 09/20/2019 Paula Bartell 09/20/2019 09/20/2019 company response Pending Won Choi 09/18/2019 09/18/2019 Paula Bartell 09/20/2019 09/20/2019 company response Pending Won Choi 08/01/2019 08/01/2019 Paula Bartell 08/27/2019 08/27/2019 company response Pending Won Choi 07/25/2019 07/25/2019 Paula Bartell 07/26/2019 07/26/2019 company response Respond Won Choi 07/01/2019 07/02/2019 Paula Bartell 07/02/2019 07/02/2019 immediately Pending Won Choi 06/28/2019 06/28/2019 Paula Bartell 07/03/2019 07/03/2019 company response Filing Notes Subject Note Type Created By Created On Date Submitted Status Note To Reviewer Paula Bartell 09/24/2019 09/24/2019 RE: Status Note To Filer Won Choi 09/23/2019 09/23/2019 Status Note To Reviewer Paula Bartell 09/17/2019 09/17/2019 RE: Status Note To Filer Won Choi 09/13/2019 09/13/2019 Status Note To Reviewer Paula Bartell 09/10/2019 09/10/2019 RE: question and request for extension Note To Filer Won Choi 08/02/2019 08/02/2019 question and request for extension Note To Reviewer Paula Bartell 08/02/2019 08/02/2019 Deemer Waiver Note To Reviewer Paula Bartell 07/03/2019 07/03/2019

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Disposition

Disposition Date: 09/24/2019 Effective Date (New): Effective Date (Renewal): Status: Approved Comment: Only the changes specifically indicated in the application set forth above, as it may have been amended, are approved. Nothing in this letter shall constitute approval of any other application, whether incorporated by reference, or filed prior or subsequent to the application set forth above. Zurich American Insurance Company shall begin issuing policies pursuant to this approval within 90 days of the date of this approval, provided that the insurer is licensed in California to transact the line of insurance for which the approval is given. The insurer may implement this approval earlier if it is able to do so. Regardless of the implementation date, the insurer shall implement this approval with the same effective date for both new and renewal business and shall offer this product to all eligible applicants as of the implementation date. This approval shall continue to have full force and effect until such time as a subsequent change for the referenced lines or programs may be approved or ordered by the Insurance Commissioner.

If any portion of the application or related documentation conflicts with California law, that portion is specifically not approved. This approval does not constitute an approval of underwriting guidelines nor the specific language, coverages, terms, covenants and conditions contained in any forms, or the forms themselves. Policy forms and underwriting guidelines included in this filing were reviewed only insofar as they relate to rates contained in this filing or currently on file with the California Department of Insurance. Any subsequent changes to underwriting guidelines or coverage, terms, covenants and conditions contained in any forms must be submitted with supporting documentation where those changes result in any rating impact. The Commissioner may at any time take any action allowed by law if he determines that any underwriting guidelines, forms or procedures for application of rates, or any other portions of the application conflict with any applicable laws or regulations.

Overall % Overall % Written Premium Number of Policy Written Maximum % Minimum % Company Indicated Rate Change for Holders Affected Premium for Change Change Name: Change: Impact: this Program: for this Program: this Program: (where req'd): (where req'd): Zurich American 0.000% 0.000% $0 0 $0 % % Insurance Company

Schedule Schedule Item Schedule Item Status Public Access Supporting Document (revised) New Prior Approval Rate Application Yes Supporting Document New Prior Approval Rate Application Yes Supporting Document New Prior Approval Rate Application Yes Supporting Document California Examples Yes

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Schedule Schedule Item Schedule Item Status Public Access Form Zurich Pet Illness and Injury Insurance Policy Yes Declarations Page Form Zurich Pet Illness And Injury Insurance Policy Yes Form Pet Wellness Endorsement - California Yes Form Policy Changes Yes Form California Amendatory Yes Form Insurer Disclosure of Important Policy Provisions Yes Rate Zurich American Insurance Company Pet Insurance Yes Program Countrywide Rating Plan Rate Zurich American Insurance Company Pet Insurance Yes Program State Exception Page - California

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Objection Letter Objection Letter Status Pending company response Objection Letter Date 09/20/2019 Submitted Date 09/20/2019 Respond By Date 09/24/2019 Dear Paula Bartell, Introduction:

Objection 1 - New Prior Approval Rate Application (Supporting Document) Comments: The underwriting guideline says, "Policies are not eligible for $0 deductible and 0% copayment." However, the rating manual shows $0 deductible has a factor of 1.15. Does this mean $0 deductible is allowed but not with 0% copayment?

Furthermore, the rating manual does not say much about copayment/coinsurance. There is no list of copayment/coinsurance levels nor their associated factors. How does copayment/coinsurance work for this program?

Conclusion:

Sincerely, Won Choi

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Objection Letter Objection Letter Status Pending company response Objection Letter Date 09/18/2019 Submitted Date 09/18/2019 Respond By Date 09/23/2019 Dear Paula Bartell, Introduction:

Objection 1 - New Prior Approval Rate Application (Supporting Document) Comments: Memoranda say territory factors were determined by researching competitor filings. A. Please give rationale for including territory factors for pet insurance especially since VBW-I and VB-II products do not. B. Do you have the SERFF numbers of the mentioned competitor filings other than Nationwide's VBW-I and VB-II products?

Objection 2 - New Prior Approval Rate Application (Supporting Document) Comments: Why or how is $750 the sublimit for the Wellness endorsement opposed to unlimited or $500?

Conclusion:

Sincerely, Won Choi

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Objection Letter Objection Letter Status Pending company response Objection Letter Date 08/01/2019 Submitted Date 08/01/2019 Respond By Date 08/27/2019 Dear Paula Bartell, Introduction:

Objection 1 - New Prior Approval Rate Application (Supporting Document) Comments: VPIC-131531260 is referenced for base rate development in your exhibits 1, 5, and 6 in "CA.pdf". VPIC- 131531260 was withdrawn by its filer, and now there are two rate filings newer than VPIC-131531260 for VBW-I and VB-II that are still pending. Please confirm if the rate development calculations submitted here on 2019-07-26 are still sound or if you would like to make changes contemplating the new developments mentioned above.

Conclusion:

Sincerely, Won Choi

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Objection Letter Objection Letter Status Pending company response Objection Letter Date 07/25/2019 Submitted Date 07/25/2019 Respond By Date 08/02/2019 Dear Paula Bartell, Introduction:

Objection 1 - New Prior Approval Rate Application (Supporting Document) Comments: Worksheet '8.Miscellaneous Fees' in the application file indicates there are no fees in this program, but Page 5 of the rating plan lists five different fees. Please review and update accordingly. Please review if row 19, Misc. Fees, or row 29, ancillary income, in worksheet '6.1Ratemaking Data' of the Template file need updating too.

Objection 2 - Zurich American Insurance Company Pet Insurance Program Countrywide Rating Plan, Pages 1-20 (Rate) Comments: Please describe what is "Pet Tag & Found-Pet Service Registry" fee is. If a new customer already has their pet(s) microchipped, do they still have to pay for this fee?

Conclusion:

Sincerely, Won Choi

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Objection Letter Objection Letter Status Respond immediately Objection Letter Date 07/01/2019 Submitted Date 07/02/2019 Respond By Date Dear Paula Bartell, Introduction: The above filing will deem Tuesday, 7/9/2019. We require additional time to review this filing. Please consider waiving the deemer in order to continue working on the above filing without disruption. Zurich American Insurance Company may consider waiving all deemer provisions of California Insurance Code Section 1861.05 by sending us a letter BEFORE Tuesday, July 9th, 2019 using the following EXACT language:

Regarding the above-referenced rate application, Zurich American Insurance Company ("applicant") hereby waives all deemer provisions of California Insurance Code Section 1861.05, specifically, the 60-day deemer and the 180-day deemer. If the applicant wishes to reactivate the deemer provisions, the applicant will make its request in writing to the Department of Insurance Rate Filing Bureau, Los Angeles, California. Upon reactivation, the 60-day deemer will resume five days after the Department's receipt of the applicant's request to reactivate the deemer, on day 52, and the 180-day deemer will resume five days after the Department's receipt of the applicant's request to reactivate the deemer, on day 67.

Conclusion:

Sincerely, Won Choi

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Objection Letter Objection Letter Status Pending company response Objection Letter Date 06/28/2019 Submitted Date 06/28/2019 Respond By Date 07/09/2019 Dear Paula Bartell, Introduction: Please show premium calculation in Excel for the following new customers: 2 years old, large, neutered or spayed, golden retriever without pre-existing condition in Los Angeles (ZIP Code 90013). 8 years old, medium, miex-short hair cat, neutered or spayed without pre-existing condition in Los Angeles (ZIP Code 90013).

If any parameters are lacking, please let me know through Note to Reviewer in SERFF.

Conclusion:

Sincerely, Won Choi

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Response Letter Response Letter Status Submitted to State Response Letter Date 09/20/2019 Submitted Date 09/20/2019 Dear Won Choi, Introduction: Thank you for your correspondence.

Response 1 Comments: That is correct. Customers will be able to choose either a $0 deductible or a 0% copayment, but not both.

The copayment and reimbursement rates complement each other. The reimbursement rate is determined by subtracting the selected copayment from 100%. This and the corresponding factors can be found in the (6) Reimbursement Factor section of the manual.

Related Objection 1 Applies To: - New Prior Approval Rate Application (Supporting Document) Comments: The underwriting guideline says, "Policies are not eligible for $0 deductible and 0% copayment." However, the rating manual shows $0 deductible has a factor of 1.15. Does this mean $0 deductible is allowed but not with 0% copayment?

Furthermore, the rating manual does not say much about copayment/coinsurance. There is no list of copayment/coinsurance levels nor their associated factors. How does copayment/coinsurance work for this program?

Changed Items:

No Supporting Documents changed.

No Form Schedule items changed.

No Rate/Rule Schedule items changed. Conclusion: We appreciate your continued review. Sincerely, Paula Bartell

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Response Letter Response Letter Status Submitted to State Response Letter Date 09/20/2019 Submitted Date 09/20/2019 Dear Won Choi, Introduction: The following information is in response to your comments.

Response 1 Comments: a.Nationwide's VBW-I and VB-II products are offered through their worksite programs. Because of this, they have removed some of the rating complexity found in other pet insurance plans (for both Nationwide and other carriers). Our product will be offered through multiple channels: worksite programs and direct-to-consumer online. Because of this, we have included additional factors (age, breed and territory) to reflect differences in expected losses and to help avoid adverse selection. All of these factors will be reevaluated using our own experience as it becomes available. b.The proposed territory factors are based on the Westchester Fire Insurance Company (WFIC) rating plan (SERFF# ACEH- 131634684). WFIC's territory definitions were moved from the zip code level up to a county level using population data. Westchester Fire Insurance Company was selected because it is part of Chubb's Healthy Paws program. Outside of Nationwide, Chubb is one of the largest writers of pet insurance (~12% market share).

Related Objection 1 Applies To: - New Prior Approval Rate Application (Supporting Document) Comments: Memoranda say territory factors were determined by researching competitor filings. A. Please give rationale for including territory factors for pet insurance especially since VBW-I and VB-II products do not. B. Do you have the SERFF numbers of the mentioned competitor filings other than Nationwide's VBW-I and VB-II products?

Changed Items:

No Supporting Documents changed.

No Form Schedule items changed.

No Rate/Rule Schedule items changed.

Response 2 Comments: The wellness limit was raised to keep pace with the rising costs of exams / test costs. At the same time, we also tried to be thoughtful about providing more coverage than the typical customer needed, as this would drive up the cost of the wellness product.

Related Objection 2 Applies To: - New Prior Approval Rate Application (Supporting Document) Comments: Why or how is $750 the sublimit for the Wellness endorsement opposed to unlimited or $500?

Changed Items:

No Supporting Documents changed.

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

No Form Schedule items changed.

No Rate/Rule Schedule items changed. Conclusion: If I can be of further assistance please do not hesitate to contact me. Sincerely, Paula Bartell

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Response Letter Response Letter Status Submitted to State Response Letter Date 08/27/2019 Submitted Date 08/27/2019 Dear Won Choi, Introduction: The following information is in response to your comments.

Response 1 Comments: After reviewing the more recent filings (19-1271 and 19-1273) we have determined that no changes are necessary. The base rate adjustments that have been proposed fall within the range of rate changes indicated in the newer filings. The attached exhibit compares the proposed base rate adjustments to these ranges and the proposed rate changes for the VBW-I and VB-II products.

Related Objection 1 Applies To: - New Prior Approval Rate Application (Supporting Document) Comments: VPIC-131531260 is referenced for base rate development in your exhibits 1, 5, and 6 in "CA.pdf". VPIC-131531260 was withdrawn by its filer, and now there are two rate filings newer than VPIC-131531260 for VBW-I and VB-II that are still pending. Please confirm if the rate development calculations submitted here on 2019-07-26 are still sound or if you would like to make changes contemplating the new developments mentioned above.

Changed Items:

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State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Supporting Document Schedule Item Changes Satisfied - Item: New Prior Approval Rate Application Comments: CA Exhibit 18 Rules.pdf CA Exhibit 16 New Program.pdf CA.pdf Explanatory Memo CW 041019.pdf CW Memo.pdf Attachment(s): Underwriting Guidelines Pet - California v5.pdf PriorAppRateAPL_Ed01-25-2019.pdf PriorAppRateAPL_Ed01-25-2019.xlsm PriorAppRateTl_Ed12-12-2018.pdf PriorAppRateTl_Ed12-12-2018.xlsm Rate Change Comparison.pdf Previous Version Satisfied - Item: New Prior Approval Rate Application Comments: CA Exhibit 18 Rules.pdf CA Exhibit 16 New Program.pdf CA.pdf Explanatory Memo CW 041019.pdf Attachment(s): CW Memo.pdf Underwriting Guidelines Pet - California v5.pdf PriorAppRateAPL_Ed01-25-2019.pdf PriorAppRateAPL_Ed01-25-2019.xlsm PriorAppRateTl_Ed12-12-2018.pdf PriorAppRateTl_Ed12-12-2018.xlsm Previous Version Satisfied - Item: New Prior Approval Rate Application Comments: CA Exhibit 18 Rules.pdf CA Exhibit 16 New Program.pdf CA.pdf Explanatory Memo CW 041019.pdf Attachment(s): CW Memo.pdf Underwriting Guidelines Pet - California v5.pdf PriorAppRateAPL_Ed01-25-2019.pdf PriorAppRateAPL_Ed01-25-2019.xlsm PriorAppRateTl_Ed12-12-2018.pdf PriorAppRateTl_Ed12-12-2018.xlsm

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

No Form Schedule items changed.

No Rate/Rule Schedule items changed. Conclusion: If I can be of further assistance please do not hesitate to contact me. Sincerely, Paula Bartell

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Response Letter Response Letter Status Submitted to State Response Letter Date 07/26/2019 Submitted Date 07/26/2019 Dear Won Choi, Introduction: The following information is in response to your comments.

Response 1 Comments: The application file has been revised to reflect the fees in the rating plan. The projected fees have also been separated from the premium in the template.

Related Objection 1 Applies To: - New Prior Approval Rate Application (Supporting Document) Comments: Worksheet '8.Miscellaneous Fees' in the application file indicates there are no fees in this program, but Page 5 of the rating plan lists five different fees. Please review and update accordingly. Please review if row 19, Misc. Fees, or row 29, ancillary income, in worksheet '6.1Ratemaking Data' of the Template file need updating too.

Changed Items:

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State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Supporting Document Schedule Item Changes Satisfied - Item: New Prior Approval Rate Application Comments: CA Exhibit 18 Rules.pdf CA Exhibit 16 New Program.pdf CA.pdf Explanatory Memo CW 041019.pdf Attachment(s): CW Memo.pdf Underwriting Guidelines Pet - California v5.pdf PriorAppRateAPL_Ed01-25-2019.pdf PriorAppRateAPL_Ed01-25-2019.xlsm PriorAppRateTl_Ed12-12-2018.pdf PriorAppRateTl_Ed12-12-2018.xlsm Previous Version Satisfied - Item: New Prior Approval Rate Application Comments: CA Exhibit 18 Rules.pdf CA Exhibit 16 New Program.pdf CA.pdf Explanatory Memo CW 041019.pdf Attachment(s): CW Memo.pdf Underwriting Guidelines Pet - California v5.pdf PriorAppRateAPL_Ed01-25-2019.pdf PriorAppRateAPL_Ed01-25-2019.xlsm PriorAppRateTl_Ed12-12-2018.pdf PriorAppRateTl_Ed12-12-2018.xlsm

No Form Schedule items changed.

No Rate/Rule Schedule items changed.

Response 2 Comments: The "Pet Tag & Found-Pet Service Registry" fee provides each enrolled pet with a set of metal ID tags with a unique number and registration for lost-pet service with 24/7 phone coverage. All new customers will pay this fee, even those that have microchipped their pets.

Related Objection 2 Applies To: - Zurich American Insurance Company Pet Insurance Program Countrywide Rating Plan, Pages 1-20 (Rate)

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State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Comments: Please describe what is "Pet Tag & Found-Pet Service Registry" fee is. If a new customer already has their pet(s) microchipped, do they still have to pay for this fee?

Changed Items:

No Supporting Documents changed.

No Form Schedule items changed.

No Rate/Rule Schedule items changed. Conclusion: If I can be of further assistance please do not hesitate to contact me. Sincerely, Paula Bartell

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Response Letter Response Letter Status Submitted to State Response Letter Date 07/02/2019 Submitted Date 07/02/2019 Dear Won Choi, Introduction: The following information is in response to your comments.

Response 1 Comments: Zurich American Insurance Company ("applicant") hereby waives all deemer provisions of California Insurance Code Section 1861.05, specifically, the 60-day deemer and the 180-day deemer

Changed Items:

No Supporting Documents changed.

No Form Schedule items changed.

No Rate/Rule Schedule items changed. Conclusion: If I can be of further assistance please do not hesitate to contact me. Sincerely, Paula Bartell

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Response Letter Response Letter Status Submitted to State Response Letter Date 07/03/2019 Submitted Date 07/03/2019 Dear Won Choi, Introduction: The following information is in response to your comments.

Response 1 Comments: Please see attached Excel file (Zurich Pet Insurance - CA Examples).

Changed Items:

Supporting Document Schedule Item Changes Satisfied - Item: California Examples Comments: Attachment(s): Zurich Pet Insurance - CA Examples.xlsx

No Form Schedule items changed.

No Rate/Rule Schedule items changed. Conclusion: If I can be of further assistance please do not hesitate to contact me. Sincerely, Paula Bartell

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Note To Reviewer

Created By: Paula Bartell on 09/24/2019 06:35 AM Last Edited By: Paula Bartell Submitted On: 09/24/2019 06:35 AM Subject: Status Comments: Thank you for providing this information to me. We look forward to completion of the review of this filing.

Thank you for all of your assistance with this filing.

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State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Note To Filer

Created By: Won Choi on 09/23/2019 04:06 PM Last Edited By: Won Choi Submitted On: 09/23/2019 04:06 PM Subject: RE: Status Comments: This filing is at the final review process.

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Note To Reviewer

Created By: Paula Bartell on 09/17/2019 11:52 AM Last Edited By: Paula Bartell Submitted On: 09/17/2019 11:52 AM Subject: Status Comments: Thank you for your response regarding the probability of a 10/1/2019 effective date. We were wondering if you have had an opportunity to discuss this with your supervisor and if the 10/1/2019 date is attainable? If there is anything that we can do to move this filing along please don't hesitate to contact me.

Thank you for your time and help with this filing.

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Note To Filer

Created By: Won Choi on 09/13/2019 07:41 PM Last Edited By: Won Choi Submitted On: 09/13/2019 07:45 PM Subject: RE: Status Comments: Although an approval date before 10/1 is possible, it is very difficult for me to indicate when the review for a filing to complete, but thank you for the context and update regarding this filing. I will inform my supervisors today, and see what we can do.

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Note To Reviewer

Created By: Paula Bartell on 09/10/2019 06:23 AM Last Edited By: Paula Bartell Submitted On: 09/10/2019 06:23 AM Subject: Status Comments: Dear Mr. Choi, Thank you for continuing to work with Zurich on the filing of the Pet Program. Our target date for launch of the program is October 1st and we are reaching out to see if there was anything we can do to help advance the filing to achieve the October 1 date. California is a target market for the program. There are two major distribution channels for our Pet Program – direct to the consumer via the Trusted Pals website and through employee benefit programs. We anticipate the employee benefit offering will be the largest distribution channel for the Program. The October 1st effective date is critical as employer(s)’menu(s) of offerings are typically finalized by this date. Additionally, we are pleased that the California Bar Association and the California Medical Association have already indicated that they would like to offer our product to their employees via the workplace. We would like to set up a conference call to discuss our Program with you, and in particular, what we can do or any information we can provide, to help advance the approval of our product by the 10/1 effective date. Thank you,

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Note To Filer

Created By: Won Choi on 08/02/2019 04:26 PM Last Edited By: Won Choi Submitted On: 08/02/2019 04:27 PM Subject: RE: question and request for extension Comments: The respond-by-date has been extended. Thank you for your inquiry.

The following are the pending filings. VPIC-131863524 is for VBW-I, and VPIC-131863562 is for VB-II.

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Note To Reviewer

Created By: Paula Bartell on 08/02/2019 10:56 AM Last Edited By: Paula Bartell Submitted On: 08/02/2019 10:57 AM Subject: question and request for extension Comments: Would it be possible to get an extension to respond to your objection until 8/22? I also was wondering if you would be able to provide us with the two rate filings that you are referencing that are still pending.

Thank you for your time and assistance.

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Note To Reviewer

Created By: Paula Bartell on 07/03/2019 12:37 PM Last Edited By: Paula Bartell Submitted On: 07/03/2019 12:37 PM Subject: Deemer Waiver Comments: Regarding the above-referenced rate application, Zurich American Insurance Company ("applicant") hereby waives all deemer provisions of California Insurance Code Section 1861.05, specifically, the 60-day deemer and the 180-day deemer. If the applicant wishes to reactivate the deemer provisions, the applicant will make its request in writing to the Department of Insurance Rate Filing Bureau, Los Angeles, California. Upon reactivation, the 60-day deemer will resume five days after the Department's receipt of the applicant's request to reactivate the deemer, on day 52, and the 180-day deemer will resume five days after the Department's receipt of the applicant's request to reactivate the deemer, on day 67.

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Form Schedule

Item Schedule Item Form Form Edition Form Form Action Specific Readability No. Status Name Number Date Type Action Data Score Attachments 1 Zurich Pet Illness and U-PETZ-D- (07/19) DEC New 0.000 UPETZD001AC Injury Insurance Policy 001-A CW W0719.pdf Declarations Page 2 Zurich Pet Illness And U-PETZ- (07/19) PCF New 0.000 UPETZ0100ACW Injury Insurance Policy 0100-A CW 0719.pdf 3 Pet Wellness U-PETZ- (07/19) END New 0.000 UPETZ0101ACA Endorsement - California 0101-A CA 0719.pdf 4 Policy Changes U-PETZ- (07/19) END New 0.000 UPETZ0102ACW 0102-A CW 0719.pdf 5 California Amendatory U-PETZ- (07/19) END New U-PETZ-0105-A 105-A CA CA 0719.pdf 6 Insurer Disclosure of U-PETZ- (07/19) DSC New U-PETZ-0106-A Important Policy 106-A CA CA 0719.pdf Provisions

Form Type Legend: ABE Application/Binder/Enrollment ADV Advertising BND Bond CER Certificate CNR Canc/NonRen Notice DEC Declarations/Schedule DSC Disclosure/Notice END Endorsement/Amendment/Conditions ERS Election/Rejection/Supplemental Applications OTH Other

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM

Policy Changes

Policy No. Policy Affected Policy Changes Authorized Add’l. Prem. Return Prem. Effective Date Representative

This endorsement modifies insurance provided under the: Zurich Pet Illness and Injury Insurance Policy Declarations Page Zurich Pet Illness and Injury Insurance Policy

The modification(s) may result in a change in the premium as indicated above.

Type(s) of Change(s) ☐ Name(s) of Pet Owner(s) ☐ Phone Number, Email or Mailing Address of Pet Owner ☐ Name of Pet ☐ Company ☐ Policy Period ☐ Limit ☐ Policy Number ☐ Discount ☐ Copayment ☐ Deductible(s) ☐ Premium ☐ Endorsement(s) ☐ Waiting Period ☐ Other

CHANGES

All other terms, conditions, provisions and exclusions of this policy remain the same.

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Pet Wellness Endorsement - California

This endorsement modifies insurance provided under the: Zurich Pet Illness and Injury Insurance Policy

I. Solely for the purposes of Coverage provided by this endorsement, Subparagraph C.1. in SECTION I – INSURING AGREEMENT is deleted in its entirety and replaced with the following: C. Benefits 1. We will reimburse You for reasonable and necessary Veterinary Expenses that You incur for Veterinary Services including the following: a. a physical examination of Your Pet; b. Prescribed behavioral training, therapy or treatment; c. fees or other expenses related to Covered Veterinary Expenses, including Pet services and supplies prescribed by Your Veterinarian; d. Prescribed Drugs; e. Prescribed Nutritional Supplements; f. Prescription Pet Food. II. Solely for the purposes of Coverage provided by this endorsement, Exclusion P. in SECTION II – EXCLUSIONS is deleted. III. Solely for the purposes of Coverage provided by this endorsement, Paragraphs C. and D. of SECTION IV- DEDUCTIBLE, COPAYMENT AND LIMIT are replaced with the following: C. You are responsible for the remainder of Covered Veterinary Expenses in addition to any amounts not covered by this endorsement. D. Reimbursement of Veterinary Expenses is subject to the Pet Wellness Endorsement Limit shown on the Declarations Page. This limit is the maximum amount payable for reimbursement during the Policy Period for Coverage provided by this endorsement. You are responsible for the remainder of Veterinary Expenses that exceed the limit. IV. Solely for the purposes of Coverage provided by this endorsement, the definition of Veterinary Services in SECTION V- DEFINITIONS is replaced with the following: Veterinary Services means preventive medicine, diagnosis or treatment provided by a Veterinarian who has physically examined Your Pet, including, but not limited to Prescribed Drugs, Prescribed Nutritional Supplements and Prescription Pet Food.

All other terms, conditions, provisions and exclusions of this policy remain the same.

U-PETZ-0101-A CA (07/19) Page 1 of 1

Zurich Pet Illness And Injury Insurance Policy

Please read the entire Policy carefully to determine Your rights and duties and what is and is not covered. Some provisions in the Policy limit or restrict Coverage. This Policy begins on the Policy Effective Date shown on the Declarations Page of this Policy. This Policy shall continue in effect, provided premiums are paid when due unless otherwise cancelled. Throughout this Policy, the words You and Your refer to the Pet Owner shown on the Declarations Page. The words We, Us and Our refer to the Company providing this insurance. Words and phrases that appear in bold type have special meaning found in the DEFINITIONS section. This Policy is governed by the laws of the state in which it is delivered. You and the Company have agreed to all terms and conditions of this Policy.

PLEASE READ THIS POLICY CAREFULLY

U-PETZ-0100-A CW (07/19) Page 1 of 8 Includes copyrighted material of Insurance Services Office, Inc., with its permission.

TABLE OF CONTENTS Section SECTION I INSURING AGREEMENT SECTION II EXCLUSIONS SECTION III PREMIUM PAYMENT SECTION IV DEDUCTIBLE, COPAYMENT AND LIMIT SECTION V DEFINITIONS SECTION VI CONDITIONS

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I. INSURING AGREEMENT A. Pets Covered 1. Your covered Pet is shown on the Declarations Page. 2. Your Pet must be a domesticated dog or cat that resides with You. 3. Coverage is in effect for the Policy Period shown on the Declarations Page, beginning on the Policy Effective Date. B. Pets Not Covered 1. A Pet not listed on the Declarations Page shall not be covered under this Policy. 2. We do not cover a Pet that is younger than eight (8) weeks old or a Pet owned for commercial reasons. Commercial reasons include, but are not limited to, racing, breeding, law enforcement, guarding, dog racing, or dog fighting. 3. A Pet may not be covered based upon the terms, limits, exclusions, definitions, limitations, conditions and any other applicable provisions of this Policy. C. Benefits 1. We will reimburse You for Covered Veterinary Expenses that You incur for Veterinary Services performed during the Policy Period related to Your Pet’s Illness or Injury that first began after the Policy Effective Date and during the Policy Period including the following: a. a physical examination of Your Pet; b. Prescribed behavioral training, therapy or treatment; c. fees or other expenses related to Covered Veterinary Expenses, including Pet services and supplies Prescribed by Your Veterinarian to diagnose or treat Your Pet’s Illness or Injury; d. Prescribed Drugs; e. Prescribed Nutritional Supplements; or f. Prescription Pet Food. 2. Your Pet’s Illness may include: a. an Illness associated with a disease; b. an Illness that Your Pet contracts or incurs, including an Illness that arises as a direct result of the Pet’s pregnancy; or c. a Chronic Condition that began after the Policy Effective Date but during the Policy Period. 3. These benefits are subject to the terms, limits, conditions, limitations, exclusions, and Waiting Period(s) of this Policy, as well as Your responsibility to pay the premium, Copayment and deductible amounts shown on the Declarations Page. D. Additional Benefits for Death of Your Pet from Injury or Illness 1. If Your Pet dies during the Policy Period, We will pay: a. expenses a Veterinarian incurred in euthanizing Your Pet (if applicable); and b. cremation and burial expenses with a maximum benefit of $250. 2. We will pay You one hundred fifty dollars ($150) as a death benefit for Your Pet if You did not pay for Your Pet or have no receipt to prove how much You paid for Your Pet. Alternatively, if You can provide proof of how much You paid for Your Pet, We will pay You the price You paid for Your Pet up to the maximum benefit of $1,000. However, We will not pay for the price You paid for Your Pet if: a. Your dog was eight (8) years of age or older at the time of death or Your cat was ten (10) years of age or older at the time of death; and b. Your Pet died or was euthanized due to an Illness; and

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c. Your Veterinarian is not able to verify the death of Your Pet or sign the claim form. 3. You must send Us a completed claim form including a receipt for Veterinary Expenses and, if applicable, a receipt for the price You paid for Your Pet. II. EXCLUSIONS We do not cover: A. Diagnosis or treatment of any Pre-Existing Condition; B. Complications, diagnosis, treatment or progressions of an Illness or Injury excluded or limited by this Policy; C. Diagnosis or treatment of any Illness or Injury caused directly or indirectly by war or war activities whether war has been declared or not. War activities include civil war, insurrection, rebellion, or revolution or any act or condition incident of any of the foregoing; D. Diagnosis or treatment of any Illness or Injury caused directly or indirectly by a nuclear incident as defined in the Nuclear Liability Act, a nuclear explosion or contamination by radioactive material; E. Diagnosis or treatment of any Illness or Injury caused intentionally by You or any other resident of Your household; F. Any behavioral training, therapy or treatment that is not Prescribed by a Veterinarian; G. Dietary or Prescribed Nutritional Supplements used to preserve or improve general nutrition or health and can be purchased without a prescription, including foods such as: life stages (puppy, senior, etc.), low calorie, sensitive stomach, or limited ingredients, even if recommended by a Veterinarian for treatment of Your Pet’s Illness or Injury; H. Boarding, storage, transportation and grooming, including services such as nail trims or bathing; I. Fees or other expenses for Pet services and supplies not Prescribed by Your Veterinarian to diagnose or treat Your Pet’s Illness or Injury; J. Fees or other expenses not directly related to Veterinary Services, including fees or expenses incurred for items such as: (1) waste disposal; (2) record access or copying; (3) any license or certification, except a state or federal health certificate provided to You by Your Veterinarian; (4) compliance with any governmental rule or regulation; (5) any tax; or (6) any charge assessed by any bank, credit card company or other financial institution; K. Diagnosis or treatment that is experimental, investigational, or otherwise not within the standard of care accepted by the veterinary medical board of Your state; L. Breeding or pregnancy, except for an Illness that arises as a direct result of the Pet’s pregnancy; M. Illness or Injury related to hip dysplasia that occurs or recurs within the first twelve (12) months following the Policy Effective Date if this is the first Policy issued for this Pet, or if this is a Policy issued as a new Policy because of Policy changes requiring a renewal Policy to be issued as a new enrollment Policy. This exclusion will not be applicable to a renewed Policy; N. Illness or Injury related to cruciate ligament problems that occurs or recurs within the first twelve (12) months following the Policy Effective Date if this is the first Policy issued for this Pet, or if this is a Policy issued as a new Policy because of Policy changes requiring a renewal Policy to be issued as a new enrollment Policy. This exclusion will not be applicable to a renewed Policy; O. Taxidermy; or P. Veterinary Examination Fees for preventive veterinary medicine. III. PREMIUM PAYMENT A. Upon Your payment of the premiums when due, We will reimburse You for Covered Veterinary Expenses to the extent set forth in the Policy, provided that You have complied with the terms and conditions of the Policy. B. Premium is payable as stated on the Declarations Page. If You do not pay the premium, We may cancel this Policy according to the Cancellation, Nonrenewal and Renewal Condition of SECTION VI - CONDITIONS of this Policy.

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C. If there is a change in premium based upon a mid-term Policy change, the change in premium, as specified on either the Declarations Page or the Policy Changes endorsement, will take effect on the first of the month following the Policy change Waiting Period. D. Upon renewal, the premium amount may change for all Pet Owners based upon the changing costs of veterinary medicine. IV. DEDUCTIBLE, COPAYMENT AND LIMIT A. We will not pay any amount unless Your Covered Veterinary Expenses exceed Your annual deductible. After the deductible is met, You will pay the Copayment. We will reimburse the remaining percentage of Covered Veterinary Expenses subject to any maximum applicable Policy limit. B. If Your Covered Veterinary Expenses exceed Your deductible, We will: 1. Deduct Your Copayment from the Covered Veterinary Expenses that exceed Your annual deductible; and 2. Pay the remaining amount. C. You are responsible for the remainder of Covered Veterinary Expenses in addition to any amounts not covered by this Policy. D. The Policy limit, if shown on the Declarations Page, is the maximum amount reimbursed to You for Covered Veterinary Expenses during the Policy Period. E. Your Coverage, Copayment or annual deductible will not change based upon Your Pet’s claims experience. V. DEFINITIONS The following terms, whether in the singular or plural, are defined as follows: A. Chronic Condition means an Illness or Injury that can be treated or managed, but not Cured. The Chronic Condition must be diagnosed by a Veterinarian after the Policy Effective Date but during the Policy Period. B. Company means Zurich American Insurance Company, the insurance company insuring this Policy. C. Copayment means the percentage You must pay of Covered Veterinary Expenses. The percentage You must pay is identified on the Declarations Page or Policy Changes endorsement. D. Coverage means the insurance protection for which premium is charged as reflected on the Declarations Page and as described in this Policy, and/or by endorsement. E. Covered Veterinary Expenses means expenses for reasonable and necessary Veterinary Expenses that You incur for Veterinary Services that are eligible for payment under this Policy. F. Cured means the Illness or Injury is eliminated and has no effect on the Pet so that the Pet is fully restored to normal health without any treatment or management. G. Declarations Page means the written document that identifies the Pet, the Policy number, the Policy Period, the limit, Copayment, premium, deductible and the Pet Owner. H. Illness means a sickness or disease, including sickness or disease that arises as a direct result of Your Pet’s pregnancy. I. Injury means physical damage to Your Pet’s body caused by an unforeseen physical action or force outside Your Pet’s body. J. Pet means a domesticated dog or cat that is eight weeks old or older and resides with You. Pet is the dog or cat identified on the Declarations Page of this Policy. K. Pet Owner means the owner of the Pet as listed on the Declarations Page. L. Policy Effective Date means 12:01 a.m. of the date shown on Your Declarations Page or as modified by a Policy Changes endorsement. M. Policy means this Zurich Pet Illness and Injury Insurance Policy including the Declarations Page and attached endorsements.

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N. Policy Period is the period of time as specified in the Declarations Page or as modified by a Policy Changes endorsement. O. Pre-Existing Condition(s) means any Illness or Injury or complication resulting from an Illness that developed, or any Injury that occurred, prior to the Policy Effective Date. P. Prescribed means directly provided by or authorized by written instruction of a Veterinarian. Q. Prescribed Drugs means medication approved by the U.S. Food and Drug Administration (FDA), or the Environmental Protection Agency (EPA), used to treat Your Pet’s Illness or Injury. R. Prescribed Nutritional Supplements means dietary supplements, vitamins, and nutraceuticals, Prescribed to treat an Illness or Injury that is covered by Your Policy. S. Prescription Pet Food means manufactured Pet diet formulated to be used in a diagnostic or therapeutic setting which has modifications of nutrient concentrations outside the current Association of America Feed Control Officials (AAFCO) guidelines for a healthy Pet. Prescription Pet Food is Prescribed solely to treat or manage a Illness or Injury that is covered by Your Policy and is available exclusively through Your Veterinarian, or Prescribed by Your Veterinarian. T. Veterinarian means a properly licensed and registered professional who actively practices veterinary medicine in the state where Your Pet is treated or examined. Veterinarian shall not include You or a member of Your immediate family regardless of whether You or a member of Your immediate family also is a Veterinarian. U. Veterinary Examination Fees means fees charged for the professional opinion of a Veterinarian; also referred to as consultation, examination, referral and recheck fees. V. Veterinary Expenses means the costs associated with diagnosis or treatment provided by a Veterinarian who has physically examined Your Pet, including, but not limited to Prescribed Drugs, Prescribed Nutritional Supplements and Prescription Pet Food. W. Veterinary Services means diagnosis or treatment provided by a Veterinarian who has physically examined Your Pet, including, but not limited to Prescribed Drugs, Prescribed Nutritional Supplements and Prescription Pet Food. X. Waiting Period means the period of time specified on the Declarations Page that is required to transpire before some or all of the Coverage in the Policy can begin. If there is a mid-term Policy change, the Waiting Period for the Policy change to take effect will be the period of time specified on either the Declarations Page or the Policy Changes endorsement. VI. CONDITIONS A. Agreement We will provide the insurance described in this Policy in return for Your payment of the premium and compliance with all applicable provisions of this Policy. The Policy contains the agreement between You and Us. By accepting this Policy, You agree that all the statements in Your application and the Declarations Page are true and that You have provided Us with all material information about Your Pet. B. Assignment You shall not transfer or assign this Policy in whole or in part. If You die, Your Policy shall transfer to Your legal representative or surviving heirs. If You become unable to care for the Pet, or transfer the ownership of Your Pet to a new Pet owner, the Coverage will continue without interruption, if approved by Us in writing, subject to all other terms and conditions of this Policy. This Policy and Coverage is not transferable to other Pets. C. Cancellation, Nonrenewal and Renewal 1. You may cancel this Policy at any time by returning it to Us or by letting Us know in writing of the date cancellation is to take effect. Your Policy shall be cancelled 60 days following notification of the death of Your Pet. 2. We may cancel this Policy by informing You in writing of the date cancellation takes effect. This cancellation notice may be delivered to You, or mailed to You at Your mailing address shown in the Declarations Page. Proof of mailing will be sufficient proof of notice. The cancellation will be effective as of the date shown on the Cancellation Notice, but not less than ten (10) days after mailing to the address in this Policy or last known

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address. The mailing of notice is sufficient proof of notice of cancellation. Delivery of notice shall be equivalent to mailing. 3. Upon cancellation, We shall refund any unearned premium on a prorated basis and if applicable, pay the Additional Benefits for Death of Your Pet as described in paragraph D. of Section I – INSURING AGREEMENT. 4. Nonrenewal. We may elect not to renew this Policy. We may do so by delivering to You, or mailing to You at Your mailing address shown in the Declarations Page, written notice at least 30 days before the expiration date of this Policy. Proof of mailing will be sufficient proof of notice. 5. Renewal. At the end of the Policy Period, this Policy shall automatically renew for an additional twelve- month period unless either party expresses its intent to terminate as specified herein. D. Changes in Policy If You wish to make changes to Your Coverage, please contact Us or make those changes on Your on-line account. Any requested change, including adding Coverage for a new Pet, is subject to underwriting and Our approval, and a 30-day Waiting Period for the change to take effect as specified on either the Declarations Page or the Policy Changes endorsement. Certain changes may result in Us issuing a new Policy, which would terminate Your existing Policy and shall not be considered continuous Coverage. Conditions that occur prior to the new Policy Effective Date shall be considered a Pre-Existing Condition. E. Conformity to State Statutes When any provision in this Policy conflicts with the statutes of the state in which this Policy is issued, that provision is amended to conform to state statutes. F. Fraud and Concealment We shall not provide Coverage if You commit fraud, at any time, as it relates to this Policy, or at any time, intentionally conceal or misrepresent a material fact concerning: 1. This Policy; 2. Your Pet; 3. Your interest in Your Pet; or 4. A claim under the Policy. G. Legal Action Against Us You shall not bring a legal action against Us under this Policy unless: 1. All of this Policy’s terms have been fully complied with; and 2. The action is brought within 2 years after the date from when You paid for Your Pet’s Veterinary Expenses. H. Liberalization Should we adopt any revisions that would broaden the Coverage under this Policy without additional premium within 60 days prior to or during the Policy Period, the broadened Coverage shall immediately apply to this Policy. I. Other Insurance 1. If Your Pet is covered by more than one insurance policy issued by Us, We will not pay more than the highest amount payable under any one insurance policy. 2. This insurance is excess over any other insurance covering Your Pet that is provided by an insurance policy issued by any other insurance company, whether collectable or not. J. Review You may request a review: 1. If We deny Your claim in whole or in part; or 2. To request removal of exclusions applicable to Your Pet.

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You must submit Your review request in writing indicating the reason for the review. You must provide Us with all medical records from Your Veterinarian relating to any condition that is the basis of Your request. All review decisions are final. K. Subrogation Upon payment of benefits, We will be subrogated to Your rights of recovery from any other party. L. Your Duties after Requesting Reimbursement We have no duty to provide Coverage under this Policy if You fail to comply with the following duties: 1. You must provide prompt notice of Your claim to Us or our authorized representative as soon as practicable, but not later than 60 days from the date when Your Pet received his or her first treatment for the Illness or Injury. 2. You must submit complete and legible claim forms to Us and include itemized receipts for Covered Veterinary Expenses that identify Your Pet by name and the date of treatment. 3 Upon Our request, You must provide Us with all medical records or requested documentation related to Your Pet’s health from the Veterinarian that treated your Pet. 4. You must reasonably protect Your Pet from aggravation of any Illness or Injury. 5. Upon Our request, You will submit Your Pet to examination by a Veterinarian selected by Us. 6. It is agreed that, unless otherwise notified by You, all documents and communications regarding this Policy, its endorsements and any notices may be delivered to You by electronic mail using the electronic mail address associated with Your account, except documents required to be delivered by another method. It is Your responsibility to keep Your contact details, including electronic mail, telephone and postal address, current and correct. M. Installment Payment Service Charge If You elect to pay Your premium in installments, other than payroll deductions, We will charge You the installment fee listed on the Declarations Page or Policy Changes endorsement, if any, on each installment payment. N. Value Added Services From time to time and as permitted by state law, We may directly or indirectly offer the Pet Owner monetary or other incentives to refer friends and colleagues to apply for a Zurich Pet Illness and Injury Insurance Policy with Us. These referral offers are voluntary and the Pet Owner’s participation will not affect the eligibility, benefits, and/or premium charged under this Policy.

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Zurich Pet Illness and Injury Insurance Policy Declarations Page

Insurance Provided by: Zurich American Insurance Company 1299 Zurich Way Schaumburg, Illinois 60196

Policy Information Policy Number: Policy Effective Date: [mmddyy] 12:01 a.m. at [address of Pet Owner] Policy Period: Waiting Period: Premium: Copayment: Limit: Deductible: Fees: Discounts (if applicable): Administrative Fee: Installment Fee: Pet Wellness Endorsement Limit (if applicable): Endorsements Attached to Policy:

Pet Information Covered Pet’s Name: Pet Type: [dog/cat] Pet’s Gender: Breed: Pet’s Date of Birth: [mmddyy]

Pet Owner’s Information Name(s): Phone: Street Address: E-mail address: City, State, Zip Code:

U-PETZ- D-001-A CW (07/19) Page 1 of 1

Insurer Disclosure of Important Policy Provisions

THIS DISCLOSURE DOES NOT GRANT ANY COVERAGE OR CHANGE THE TERMS AND CONDITIONS OF ANY COVERAGE UNDER THE Zurich Pet Illness and Injury Insurance Policy

I. Your policy contains exclusions which are listed in Section II. These provisions exclude coverage for diagnosis or treatment of any Pre-Existing Conditions, which means “any condition for which a veterinarian provided medical advice, the pet received treatment for, or the pet displayed signs or symptoms consistent with the stated condition prior to the effective date of a pet insurance policy or during any waiting period.” Other exclusions may also apply. Please refer to the exclusions section of the policy for more information. II. Section IV. DEDUCTIBLE, COPAYMENT AND LIMIT contains sections that limit your coverage.  Paragraph A. explains how we will apply your deductible;  Paragraph B. explains how we will apply your Copayment after you exceed your deductible.  Paragraph C. explains that you are responsible for the remainder of Covered Veterinary Expenses in addition to any amounts not covered under this Policy; and  Paragraph D. explains that the maximum amount we will during any single policy period is shown on the Declarations Page. III. The following waiting periods apply to your Policy.  Paragraph M. of Section II. EXCLUSIONS says that we will not pay for “Illness or Injury related to hip dysplasia that occurs or recurs within the first 12 months following the Policy Effective Date if this is the first Policy issued for this Pet, or if this is a Policy issued as a new Policy because of Policy changes requiring a renewal Policy to be issued as a new enrollment Policy.”  Paragraph N. of Section II. EXCLUSIONS says that we will not pay for “Illness or Injury related to cruciate ligament problems that occurs or recurs within the first 12 months following the Policy Effective Date if this is the first Policy issued for this Pet, or if this is a Policy issued as a new Policy because of Policy changes requiring a renewal Policy to be issued as a new enrollment Policy.”  Paragraph C. of Section III. PREMIUM PAYMENT says that any change of premium based on a mid-term Policy change will take effect on the first of the month following the Policy change Waiting Period.  Paragraph D. of Section VI. CONDITIONS says that if You request any changes to Your Coverage, including adding Coverage for a new Pet, this change will be subject to a 30- day Waiting Period.

U-PETZ-106-A CA (07/19) Page 1 of 2

IV. Your Coverage, Copayment or annual deductible will not change based upon Your Pet’s claims experience. V. We review all invoices for Veterinary Services and supporting forms and documentation you submit and determine whether the Veterinary Expenses you submit are covered under your policy. If your Veterinary Expenses meet the terms of the insuring agreement of your policy, we determine whether any other policy provision excludes or limits coverage. If you have complied with all policy terms and conditions and if the Veterinary Expenses you submit to us are payable under your policy, we pay these expenses subject to all terms, conditions, limitations, and exclusions of your policy.

NOTICE: 30-DAY FREE LOOK: CANCELLATION BY RETURN OF POLICY After we have issued your Policy to you, you may cancel your Policy without charge as described in Section VI.C.1. of your Policy. You must deliver or mail your Policy to us, or to the agent through whom it was purchased, and tell us that you want to cancel your Policy, within 30 days of your Policy effective date as shown on your Declarations Page. If we have not paid any claims nor advised you in writing that a claim will be paid under your policy, your policy will be considered void from the beginning and you and we will be in the same position as if a policy or contract had been not been issued. In this case, we will refund you all premiums and policy fees you have paid us under your policy within 30 days from the date that you notify us of this cancellation. However, if we have either paid any claim or advised you in writing that a claim will be paid under your policy, this 30-day free look under your policy is inapplicable and instead the policy provisions in Section VI.C.5. of your policy relating to cancellation will apply to any refund. You may only take advantage of this 30-day free look period in the first term of your policy, within 30 days of your policy effective date as shown on your Declarations Page.

U-PETZ-106-A CA (07/19) Page 2 of 2

California Amendatory

This endorsement modifies insurance provided under the: Zurich Pet Illness and Injury Insurance Policy

I. Section V. DEFINITIONS is amended as follows: A. Paragraph A. is replaced with the following: A. Chronic Condition means a condition that can be treated or managed, but not cured. B. Paragraph O. is replaced with the following: O. Pre-Existing Condition(s) means any condition for which a Veterinarian provided medical advice, the Pet received treatment for, or the Pet displayed signs or symptoms consistent with the stated condition prior to the effective date of a pet insurance policy or during any waiting period. C. Paragraph T. is replaced with the following: T. Veterinarian means an individual who holds a valid license to practice veterinary medicine from the Veterinary Medical Board pursuant to Chapter 11 (commencing with Section 4800) of Division 2 of the Business and Professions Code or other appropriate licensing entity in the jurisdiction in which he or she practices. D. Paragraph V. is replaced with the following: V. Veterinary Expenses means the costs associated with medical advice, diagnosis, care, or treatment provided by a Veterinarian, including, but not limited to, the cost of drugs prescribed by a Veterinarian. E. Paragraph X. is replaced with the following: X. Waiting Period means the period of time specified in a pet insurance policy that is required to transpire before some or all of the coverage in the Policy can begin. II. Section VI. CONDITIONS, Paragraph C. Cancellation, Nonrenewal and Renewal, is replaced by the following: C. Cancellation, Nonrenewal and Renewal 1. During the first 30 days after the effective date of Your Policy that is not a renewal or issued as a new Policy issued as described in Paragraph VI.D., You may cancel this Policy by delivering or mailing it to Us, or to the agent through whom it was purchased. If We have not paid any claims nor advised You in writing that a claim will be paid under Your Policy, Your Policy will be considered void from the beginning and You and We will be in the same position as if a policy or contract had been not been issued. In this case, we will refund you all premiums and policy fees you have paid us under Your Policy within 30 days from the date that You notify Us of this cancellation. 2. More than 30 days after the effective date of Your Policy, if We have paid any claims, or We have advised You that a claim will be paid under Your Policy, You may cancel this Policy by delivering or mailing it to Us, or to the agent through whom it was purchased, or by letting Us know in writing of the date cancellation is to take effect. Your Policy shall be cancelled 60 days following notification of the death of Your Pet. 3. We may cancel this Policy by informing You in writing of the date cancellation takes effect. This cancellation notice may be delivered to You, or mailed to You at Your mailing address shown in the Declarations Page or last known address. Proof of mailing or delivery of notice will be sufficient proof of notice. The cancellation will be effective as of the date shown on the Cancellation Notice, but not less than 20 days after delivery or mailing.

U-PETZ-105-A CA (07/19) Page 1 of 2

4. The cancellation will be effective as of the date shown on the Cancellation Notice, but not less than: (a) 10 days after mailing or delivery of this notice if We cancel for fraud, or nonpayment of premium; or (b) 20 days after mailing or delivery of this notice if We cancel for any other reason. 5. Upon cancellation, We shall refund any unearned premium on a prorated basis within 25 days after We send the cancellation notice to You, and if applicable, pay the Additional Benefits for Death of Your Pet as described in paragraph D. of Section I – INSURING AGREEMENT. 6. Nonrenewal. We may elect not to renew this Policy. We may do so by delivering to You, or mailing to You at Your mailing address shown in the Declarations Page, written notice at least 45 days before the expiration date of this Policy. Proof of mailing will be sufficient proof of notice. 7. Renewal. At the end of the Policy Period, this Policy shall automatically renew for an additional twelve- month period unless either party expresses its intent to terminate as specified herein.

All other terms, conditions, provisions and exclusions of this policy remain the same.

U-PETZ-105-A CA (07/19) Page 2 of 2

SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Rate Information Rate data applies to filing.

Filing Method: Prior Approval Rate Change Type: Neutral Overall Percentage of Last Rate Revision: % Effective Date of Last Rate Revision: Filing Method of Last Filing: New Program SERFF Tracking Number of Last Filing:

Company Rate Information Overall % Overall % Written Premium Number of Policy Written Maximum % Minimum % Company Indicated Rate Change for Holders Affected Premium for Change Change Name: Change: Impact: this Program: for this Program: this Program: (where req'd): (where req'd): Zurich American 0.000% 0.000% $0 0 $0 % % Insurance Company

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Rate/Rule Schedule

Item Schedule Item Previous State No. Status Exhibit Name Rule # or Page # Rate Action Filing Number Attachments 1 Zurich American Insurance Pages 1-20 New CW Rate Manual - Company Pet Insurance Updated.pdf Program Countrywide Rating Plan 2 Zurich American Insurance Page 1 New CA exception.pdf Company Pet Insurance Program State Exception Page - California

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan

Section A - Zurich Pet Illness And Injury Insurance Policy (U-PETZ-0100-A CW)

(1) Base Rate × (2) Species Factor × (3) Breed Factor × (4) Age Factor × (5) Territory Factor × (6) Reimbursement Factor × (7) Deductible Factor × (8) Policy Limit Factor × (9) Discount Factor

(1) Base Rate The annual Base Rate can be found in the state exception page. For different policy terms, convert the annual rate to a daily rate and then multiply it with the number of days in the policy term.

(2) Species Factor Determine the Species Factor based on the following table:

Species Factor Canine 0.64 Feline 0.43

(3) Breed Factor Determine the Breed Group based on the table in Appendix A and the Breed Factor based on the following table:

Breed Group Factor A 1.00 B 1.13 C 1.47 D 1.93 X1 0.99 X2 1.25 A2 1.00 B2 1.72

7/1/19 edition - Page 1 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan

(4) Age Factor Determine the Age Factor based on the following table:

Age Canine Feline Less than 1 Year 1.20 1.20 1 Year 1.00 1.00 2 Years 1.00 1.00 3 Years 1.09 1.08 4 Years 1.23 1.17 5 Years 1.38 1.29 6 Years 1.55 1.43 7 Years 1.71 1.58 8 Years 1.90 1.76 9 Years 2.15 1.95 10 Years 2.43 2.17 11 Years 2.73 2.40 12 Years 3.05 2.68 13 Years 3.29 2.97 14 Years 3.53 3.25 15 Years 3.81 3.48 16 Years 4.12 3.57 17 Years 4.47 3.66 18 Years 4.88 3.76 19 Years 5.35 3.85 20+ Years 5.50 3.95

(5) Territory Factor Determine the Territory Group based on the table in the State Exception Pages. Determine the Territory Factor based on the following table:

Territory Factor A 0.85 B 0.90 C 0.95 D 1.00 E 1.05 F 1.10 G 1.15 H 1.20 I 1.25 J 1.30 K 1.35 L 1.40 M 1.45 N 1.50

7/1/19 edition - Page 2 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan

(6) Reimbursement Factor The reimbursement rate is equal to 100% minus the selected coinsurance/copayment. Determine the Reimbursement Factor based on the following table:

Reimbursement Factor 100% 1.25 90% 1.00 80% 0.90 70% 0.85

(7) Deductible Factor Determine the Deductible Factor based on the following table:

Deductible Factor $0 1.15 $100 1.00 $250 0.85 $500 0.75 $750 0.65

(8) Policy Limit Factor Determine the Policy Limit Factor based on the following table:

Limit Factor $4,000 0.90 $8,000 1.00 $15,000 1.10 Unlimited 1.30

(9) Discount Factor

The Total Discount is equal to the sum of the individual discounts that a customer qualifies for. The Total Discount is subject to a 15% maximum. The Discount Factor is equal to 1 - Total Discount.

• A 5% discount will be provided to customers that enroll multiple pets.

• A 5% discount will be provided to employees of Marsh and Zurich, associations, sponsors, affinity groups, worksite programs and strategic partners that generate policies through marketing programs.

• A 5% discount will be provided to those who qualify as Military/Veterans, Veterinary Staff/Students, First Responders and Medical Service Animals.

7/1/19 edition - Page 3 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan

Section B - Zurich Pet Wellness Endorsement (U-PETZ-0101-A CW) - $750 limit

(1) Base Rate × (2) Species Factor × (3) Breed Factor × (4) Age Factor × (5) Territory Factor × (6) Reimbursement Factor × (7) Deductible Factor × (8) Discount Factor

All rating factors are identical to those determined in Section A, unless stated otherwise.

(1) Base Rate The annual Base Rate can be found in the state exception page. For different policy terms, convert the annual rate to a daily rate and then multiply it with the number of days in the policy term.

7/1/19 edition - Page 4 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan

Section C - Fees

Name Description Amount New Customer Pet Tag & Found-Pet Service Registry 9.00 Enrollment Fee ¹ Policy administration & collection of medical records 9.00 Administrative fee 12.00 Total 30.00 Installment Fee ² $1 per month charged to customers using monthly installments 12.00 Reinstatement Fee Reinstatement of a policy for a customer that previously enrolled 10.00

¹ Will be charged once per customer at the account level (will not be charged for multipet or pets added midterm) ² Does not apply to worksite programs

7/1/19 edition - Page 5 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan Appendix A - Breed Groups

Species Breed Group Species Breed Group Canine Affenpinscher C Canine Berger Blanc Suisse D Canine Afghan Hound C Canine Berger Picard C Canine African Hairless Dog A Canine Bernese Mountain Dog D Canine Airedale- Terrier C Canine Bichon Bolognese B Canine Akbash C Canine Bichon Frise C Canine Akita C Canine Bichpoo A Canine Alapaha Blue Blood Bulldog D Canine Biewer Terrier C Canine Alaskan Husky B Canine Black Mouth Cur C Canine Alaskan Klee Kai B Canine Black Russian Terrier C Canine Alaskan Malamute D Canine Bloodhound C Canine American Alaskan Spitz B Canine Blue Heeler B Canine American Bulldog D Canine Boggle A Canine American English Coonhound B Canine Border Collie C Canine American Eskimo - Teacup/Toy B Canine Border Terrier B Canine American Eskimo- Standard B Canine Borzoi C Canine American Eskimo-Miniature B Canine Boston Terrier C Canine American Foxhound B Canine Bouvier Des Flandres C Canine American Hairless Terrier A Canine Boxer D Canine American Indian Dog C Canine Boykin Spaniel C Canine American Pitbull Terrier D Canine Bracco Italiano C Canine American Staffordshire Terrier C Canine Braque Du Bourbonnais A Canine American Staghound C Canine Braque Francais D Canine American Tundra Shepherd B Canine Brazilian Fila D Canine American Water Spaniel C Canine Briard C Canine Anatolian Shepherd B Canine Brittany Spaniel C Canine Appenzeller Sennenhunde D Canine Brussels Griffon C Canine Argentine Dogo D Canine Bull Terrier - Standard C Canine Australian Cattle Dog B Canine Bull Terrier-Miniature C Canine Australian Dingo A Canine Bulldog D Canine Australian Kelpie B Canine Bulldog - English D Canine Australian Labradoodle C Canine Bulldog - French D Canine Australian Shepherd B Canine Bulldog - Olde English D Canine Australian Shepherd- Tea Cup B Canine Bulldog - Victorian D Canine Australian Shepherd- Toy B Canine Cairn Terrier C Canine Australian Shepherd-Miniature B Canine Canaan Dog C Canine Australian Terrier A Canine Canary Dog C Canine Azawakh A Canine Cane Corso D Canine Basenji B Canine Carolina Dog C Canine Basset Fauve De Bretagne A Canine Catahoula Leopard Dog A Canine Basset Hound C Canine Catalan Sheepdog C Canine Beagle C Canine Caucasian Mountain Dog C Canine Bearded Collie C Canine Caucasian Ovtcharka D Canine Beauceron C Canine Cavachon B Canine Bedlington Terrier C Canine Cavalier King Charles Spaniel D Canine Belgian Groenendal C Canine Cavapoo B Canine Belgian Laekenois C Canine Central Asian Shepherd Dog C Canine Belgian Malinois C Canine Cesky Terrier C Canine Belgian Sheepdog B Canine Chesapeake Bay Retriever C Canine Belgian Tervuren C Canine Chihuahua A Canine Bergamasco A Canine Chihuahua-Long-Haired B 7/1/19 edition - Page 6 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan Appendix A - Breed Groups

Species Breed Group Species Breed Group Canine Chinese Crested B Canine Fourche Terrier A Canine Chinese Crested Powder Puff B Canine Fox Terrier - Toy A Canine Chinese Pug C Canine Fox Terrier- Smooth-Wire C Canine Chinook C Canine Francais) D Canine Chow Chow C Canine French Bulldog D Canine Cirneco Dell'Etna A Canine French Spainiel (Epagneul D Canine Clumber Spaniel C Canine German Pinscher A Canine Cockalier B Canine German Shepherd C Canine Cockapoo B Canine German Shorthaired Pointer C Canine Cocker Spaniel - American C Canine German Spitz A Canine Cocker Spaniel - English C Canine German Wirehaired Pointer A Canine Collie C Canine Glen Of Imaal Terrier B Canine Collie - Smooth Coated C Canine Golden Retriever C Canine Coonhound-Black & Tan C Canine Goldendoodle C Canine Coonhound-Blue Tick C Canine Gordon Setter D Canine Coonhound-Redbone C Canine Grand Basset Griffon Vendeen C Canine Corgi-Cardigan C Canine Great Dane D Canine Corgi-Pembroke C Canine Great Pyrenees C Canine Coton De Tulear B Canine Greater Swiss Mountain Dog D Canine Curly-Coated Retriever C Canine Greek Harehound C Canine Czechoslovakian Wolfdog C Canine Greyhound C Canine Dachshund Standard C Canine Hair D Canine Dachshund- Standard C Canine Haired D Canine Dachshund- Standard Wirehaired C Canine Haired D Canine Dachshund-Miniature D Canine Harrier B Canine Dachshund-Miniature Long D Canine Havanese A Canine Dachshund-Miniature Smooth D Canine Hovawart B Canine Dachshund-Miniature Wire D Canine Hungarian Sheepdog B Canine Dalmatian D Canine Ibizan Hound C Canine Dandie Dinmont Terrier A Canine Icelandic Sheepdog B Canine Danish Swedish Farm Dog C Canine Inca Orchid A Canine Doberman Pinscher D Canine Irish Red And White Setter C Canine Dogue De Bordeaux D Canine Irish Setter C Canine Dutch Shepherd B Canine Irish Terrier C Canine English Bulldog D Canine Irish Water Spaniel C Canine English Cocker Spaniel C Canine Irish Wolfhound D Canine English Foxhound B Canine Italian Greyhound C Canine English Pointer C Canine Jack Russell Terrier B Canine English Setter C Canine Japanese Chin B Canine English Shepherd C Canine Japanese Spaniel A Canine English Springer Spaniel C Canine Jindo A Canine English Toy Spaniel C Canine Kai Ken B Canine Entlebucher Mountain Dog C Canine Kangal C Canine Entlebucher Sennenhund D Canine Karelian Bear Dog A Canine Estrela Mountain Dog C Canine Keeshond C Canine Field Spaniel C Canine Kelpie A Canine Finnish Hound A Canine Kerry Blue Terrier C Canine Finnish Lapphund C Canine Kishu Ken A Canine Finnish Spitz B Canine Komondor C Canine Flat-Coated Retriever C Canine Kooikerhondje B 7/1/19 edition - Page 7 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan Appendix A - Breed Groups

Species Breed Group Species Breed Group Canine Kuvasz C Canine Norwich Terrier C Canine Kyi-Leo B Canine Nova Scotia Duck Tolling Retriever C Canine Labradoodle C Canine Old Danish Pointing Dog B Canine Labrador Retriever C Canine Old English Sheepdog C Canine Lagotto Romagnolo-Female B Canine Olde English Bulldogge D Canine Lagotto Romagnolo-Male B Canine Otter Hound C Canine Lakeland Terrier C Canine Papillon A Canine Lancashire Heeler D Canine Parson Russell Terrier B Canine Leonberger C Canine Patterdale Terrier A Canine Lhasa Apso B Canine Peekapoo A Canine Lhasa Poo B Canine Pekingese C Canine Llewellin Setter C Canine Peruvian Hairless C Canine Longhaired C Canine Petit Basset Griffon Vendeen C Canine Louisiana Catahula Hog Dog A Canine Pharaoh Hound C Canine Lowchen A Canine Pit Bull-American D Canine Malinois C Canine Pitbull D Canine Maltese A Canine Plott Hound B Canine Malti Poo A Canine Pointer B Canine Manchester Terrier C Canine Polish Lowland Sheepdog D Canine Maremma Sheepdog C Canine Polish Tatra A Canine Mastiff D Canine Polski Ocharch Nizinny A Canine Mastiff - Pyrenean D Canine Pomeranian A Canine Mastiff- Brazilian - Fila Brasileiro D Canine Pompoo A Canine Mastiff- Bull D Canine Poodle-Miniature B Canine Mastiff- English D Canine Poodle-Standard C Canine Mastiff- Neapolitan D Canine Poodle-Teacup B Canine Mastiff- Tibetian D Canine Poodle-Toy B Canine Mastiff-Spanish D Canine Portuguese Podengo- Large C Canine Mexican Hairless (Xoloitzcuintle) A Canine Portuguese Podengo- Medium C Canine Mexican Hairless-Crested (Xoloitzcuintle) B Canine Portuguese Podengo- Small C Canine Mi-Ki C Canine Portuguese Pointer B Canine Mini Goldendoodle C Canine Portuguese Water Dog D Canine Mini Labradoodle C Canine Pudelpointer C Canine Miniature Pinscher C Canine Pug C Canine Mixed (Toy 0-10 Lbs) X1 Canine Puggle B Canine Mixed (Small 11-30 Lbs.) X1 Canine Puli B Canine Mixed (Medium 31-50 Lbs.) X1 Canine Pumi C Canine Mixed (Large 51-110 Lbs.) X2 Canine Pyrenean Shepherd C Canine Mixed (X Large 111 or Greater) X2 Canine Queensland Heeler B Canine Morkie A Canine Rafeiro Do Alentejo D Canine Mountain Cur B Canine Rare Breed C Canine Mudi C Canine Rat Terrier B Canine Munsterlander C Canine Rhodesian Ridgeback C Canine New Zealand Sheepdog B Canine Rottweiler C Canine Newfoundland D Canine Russian Toy Terrier A Canine Norfolk Terrier B Canine Russian Tsvetnaya Bolonka A Canine Northern Inuit B Canine Russian Wolfhound D Canine Norwegian Elkhound C Canine Saint Bernard D Canine Norwegian Lundehund B Canine Saluki C Canine Norwegian Viking Buhund A Canine Samoyed C 7/1/19 edition - Page 8 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan Appendix A - Breed Groups

Species Breed Group Species Breed Group Canine Sapsaree B Canine Weimaraner C Canine Schapendoes B Canine Welsh Springer Spaniel B Canine Schipperke B Canine Welsh Terrier C Canine Schnauzer-Giant C Canine West Highland White Terrier C Canine Schnauzer-Miniature C Canine Westmoreland Terrier A Canine Schnauzer-Standard C Canine Wheaten Terrier D Canine Schnoodle A Canine Whippet B Canine Scottish Deerhound D Canine White Shepherd C Canine Scottish Terrier C Canine Wire Haired Fox Terrier C Canine Sealyham Terrier C Canine Wirehaired Pointing Griffon C Canine Shar Pei D Canine Wolf Hybrid-Non F1 Generation C Canine Sheltie B Canine Xoloitzcuintli B Canine Shetland Sheepdog C Canine Yorki Poo A Canine Shiba Inu B Canine Yorkshire Terrier A Canine Shichon B Canine Yugoslavian Sheepdog D Canine Shih Poo A Canine Shih Tzu B Canine All Other (Toy 0-10 Lbs) X1 Canine Shikoku A Canine All Other (Small 11-30 Lbs.) X1 Canine Shiloh Shepherd C Canine All Other (Medium 31-50 Lbs.) X1 Canine Siberian Husky C Canine All Other (Large 51-110 Lbs.) X2 Canine Silken Windhound B Canine All Other (X Large 111 or Greater) X2 Canine Silky Terrier B Canine Skye Terrier B Canine Sloughi C Canine Slovak Cuvac D Canine Small Munsterlander Pointer A Canine Smooth Fox Terrier C Canine Smoothhaired C Canine Soft Coated Wheaten Terrier D Canine South African Boerboel C Canine Spanish Water Dog B Canine Spinone Italiano C Canine Spitz B Canine Stabyhoun C Canine Staffordshire Bull Terrier B Canine Sussex Spaniel B Canine Swedish Lapphund B Canine Swedish Vallhund B Canine Telomian B Canine Texas Blue Lacy A Canine Thai Ridgeback C Canine Tibetan Spaniel B Canine Tibetan Terrier C Canine Tosa (Japanese Mastiff) D Canine Toy Fox Terrier B Canine Toy Terrier A Canine Treeing Tennessee Brindle A Canine Treeing Walker Coon Hound A Canine Vizsla C Canine Walker Hound B 7/1/19 edition - Page 9 Zurich American Insurance Company Pet Insurance Program

Countrywide Rating Plan Appendix A - Breed Groups

Species Breed Group Species Breed Group Feline Abyssinian B2 Feline Mixed- Medium Hair A2 Feline American Bobtail B2 Feline Mixed- Short Hair A2 Feline American Curl B2 Feline Munchkin B2 Feline American Curl Shorthair B2 Feline Nebelung B2 Feline American Long Hair B2 Feline Norwegian Forest Cat B2 Feline American Shorthair B2 Feline Ocicat B2 Feline American Wirehair B2 Feline Oriental Shorthair B2 Feline Austrailian Mist B2 Feline Persian B2 Feline Balinese B2 Feline Persian-Himalayan B2 Feline Bengal B2 Feline Peterbald B2 Feline Birman B2 Feline Pixie-Bob B2 Feline Bombay B2 Feline Ragamuffin B2 Feline Brazilian Shorthair B2 Feline Ragdoll B2 Feline British Shorthair B2 Feline Rare Breed B2 Feline Burmese B2 Feline Rex B2 Feline Burmilla B2 Feline Russian Blue B2 Feline California Spangled B2 Feline Savannah B2 Feline Chantilly-Tiffany B2 Feline Scottish Fold B2 Feline Chartreux B2 Feline Serengeti B2 Feline Chausie B2 Feline Siamese B2 Feline Cheetoh B2 Feline Siberian Forest Cat B2 Feline Chinchilla Persian B2 Feline Silkirk Rex B2 Feline Colorpoint Shorthair B2 Feline Singapura B2 Feline Cornish Rex B2 Feline Snowshoe B2 Feline Cymric B2 Feline Somali B2 Feline Devon Rex B2 Feline Sphynx B2 Feline Domestic Longhair A2 Feline Tonkinese B2 Feline Domestic Medium Hair A2 Feline Toyger B2 Feline Domestic Shorthair A2 Feline Turkish Angora B2 Feline Donskoy B2 Feline Turkish Shorthair B2 Feline Egyptian Mau B2 Feline Turkish Van B2 Feline European Burmese B2 Feline York Chocolate Cat B2 Feline European Shorthair B2 Feline Exotic Longhair B2 Feline All Other A2 Feline Exotic Shorthair B2 Feline Germen Rex B2 Feline Havana Brown B2 Feline Highlander B2 Feline Himalayan B2 Feline Japanese Bobtail B2 Feline Javanese B2 Feline Korat B2 Feline Kurilian Bobtail B2 Feline La Perm B2 Feline Maine Coon B2 Feline Manx B2 Feline Manx Longhair B2 Feline Minuet B2 Feline Mixed A2 Feline Mixed- Long Hair A2 7/1/19 edition - Page 10 Zurich American Insurance Company Pet Insurance Program

State Exception Page - California

Section A - Zurich Pet Illness And Injury Insurance Policy (U-PETZ-0100-A CW)

(1) Base Rate The annual base rate is $624.11

Section B - Zurich Pet Wellness Endorsement (U-PETZ-0101-A CW) - $750 limit

(1) Base Rate The annual base rate is $308.99

7/1/19 edition - Page 1 Zurich American Insurance Company Pet Insurance Program

Territory Definitions - California

County Territory Alameda I Alpine D Amador D Butte C Calaveras D Colusa D Contra Costa H Del Norte B El Dorado E Fresno D Glenn C Humboldt C Imperial C Inyo C Kern D Kings C Lake C Lassen D Los Angeles H Madera E Marin I Mariposa D Mendocino D Merced D Modoc C Mono D Monterey E Napa F Nevada D Orange I Placer G Plumas B Riverside E Sacramento F San Benito G San Bernardino E San Diego G San Francisco N San Joaquin E San Luis Obispo D San Mateo J Santa Barbara F Santa Clara J Santa Cruz G Shasta D Sierra C Siskiyou B Solano E Sonoma E Stanislaus E Sutter C Tehama C Trinity C Tulare C Tuolumne D Ventura G Yolo D Yuba C

7/1/19 edition - Page 2 SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Supporting Document Schedules Satisfied - Item: New Prior Approval Rate Application Comments: CA Exhibit 18 Rules.pdf CA Exhibit 16 New Program.pdf CA.pdf Explanatory Memo CW 041019.pdf CW Memo.pdf Attachment(s): Underwriting Guidelines Pet - California v5.pdf PriorAppRateAPL_Ed01-25-2019.pdf PriorAppRateAPL_Ed01-25-2019.xlsm PriorAppRateTl_Ed12-12-2018.pdf PriorAppRateTl_Ed12-12-2018.xlsm Rate Change Comparison.pdf Item Status: Status Date:

Satisfied - Item: California Examples Comments: Attachment(s): Zurich Pet Insurance - CA Examples.xlsx Item Status: Status Date:

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM

Explanatory Memorandum Zurich American Insurance Company Zurich Pet Illness and Injury Insurance Form Filing

Zurich American Insurance Company is submitting a new Zurich Pet Illness and Injury Insurance Policy, Declarations Page and endorsements. The following forms are being submitted:

Zurich Pet Illness and Injury Policy Declarations Page U-PETZ-D-0001-A This mandatory Declarations Page provides the Policy Period date, information regarding the insurer, the Pet Parent, the Pet, the deductible, copayment and the limits provided by the Zurich Pet Illness and Injury Policy.

Zurich Pet Illness and Injury Policy U-PETZ-0100-A The Policy provides reimbursement to the Pet Parent for reasonable and necessary veterinary expenses incurred due to the Pet’s illness or injury. No commercial pets are insured and the only type of pet insured is either a cat or dog that resides with the insured. The policy provides no annual limit, a limit for an additional death benefit, an annual deductible, and a copayment.

Pet Wellness Endorsement U-PETZ-0101-A This optional endorsement provides coverage for preventive medicine treatment for the Pet. It has a separate limit of $750. The endorsement modifies the Policy and the Declarations Page in providing greater coverage than the Policy.

Policy Changes U-PETZ-0102-A This endorsement will be used to specify certain changes to the Zurich Pet Illness and Injury Policy or the Declarations Page. It will be used for mid-term policy changes as specified in the Policy and the endorsement.

A state specific amendatory endorsement may also be submitted with the filing for review.

Page 1 of 1 INTERNAL USE ONLY Zurich American Insurance Company Pet Insurance Program

Actuarial Memorandum

Zurich American Insurance Company is submitting rates for your review for our new Pet Illness and Injury Policy and our Pet Wellness Endorsement.

The Zurich Pet Illness and Injury Policy (U-PETZ-0100-A) provides reimbursement for reasonable and necessary veterinary expenses incurred due to the Pet's illness or injury. Different options are available for the policy limit, deductible and reimbursement rate. Our optional Pet Wellness Endorsement (U-PETZ-0101-A) provides coverage for preventative medicine treatment. It has a limit of $750.

The rating plan for these products is based on a review of competitor filings. The starting point is base rates and projected loss ratios for Nationwide's VBW-I and VB-II products. Adjustments to these rates have been made to account for differences in trend, expenses and coverage.

A trend adjustment was made to reflect the difference in average accident dates. The implied loss ratios for each product were compared to our permissble loss ratio to determine an initial base rate adjustment. The base rates were then modified to reflect differences in coverage.

The proposed rating plan introduces factors for breed, age and territory. These factors were also determined by researching competitor filings. The rating plan was modified using the average factor expected to ensure that this is revenue-neutral.

The base rate derived from the VB-II product is the proposed base rate for our Pet Illness and Injury Policy. The base rate for the Pet Wellness Endorsement is the difference between the rates derived from VBW-I and VB-II, adjusted to reflect the $750 sublimit.

The details behind these calculations can be found in the attached exhibits. Zurich North America Pet Insurance Program

California Exhibit 18 Rules

Zurich is introducing new rules to accompany the Zurich Pet Illness and Injury Policy and our optional Preventative Veterinary Medicine Endorsement. There is no rate impact of these rules as these are new rules and there are currently no policyholders.

The rating plan for these products is based on a review of competitor filings. The starting point is base rates for Nationwide’s VBW-I and VB-II products. Adjustments to these rates have been made to account for differences in expenses, coverage and trend.

The projected loss ratio in the filing was adjusted to reflect the requested rate change. A trend adjustment was also made to reflect the difference in average accident dates. The implied loss ratios for each product were then compared to our permissible loss ratio to determine the initial base rate adjustment. The base rates were then modified to reflect differences in coverage.

The proposed rating plan introduces factors for breed, age and territory. These factors were also determined by researching competitor filings. The rating plan was modified using the average factor expected to ensure that this is revenue-neutral.

The base rate derived from the VB-II product is the proposed base rate for our Pet Illness and Injury Policy. The base rate for the Preventative Veterinary Medicine Endorsement is the difference between the rates derived from VBW-I and VB-II, adjusted to reflect the $750 sublimit.

Zurich North America Pet Insurance Program

California Exhibit 16 New Program

The Zurich Pet Illness and Injury Policy (U-PETZ-0100-A) provides reimbursement for reasonable and necessary veterinary expenses incurred due to the Pet’s illness or injury. Different options are available for the policy limit, deductible and reimbursement rate. Our optional Preventative Veterinary Medicine Endorsement (U-PETZ-01010-A) provides coverage for preventative medicine treatment. It has a limit of $750.

The rating plan for these products is based on a review of competitor filings. The starting point is base rates for Nationwide’s VBW-I and VB-II products (SERFF #: VPIC-130349617). Adjustments to these rates have been made to account for differences in expenses, coverage and trend.

The projected loss ratio in the filing was adjusted to reflect the requested rate change. A trend adjustment was also made to reflect the difference in average accident dates. The implied loss ratios for each product were then compared to our permissible loss ratio to determine the initial base rate adjustment. The base rates were then modified to reflect differences in coverage.

The proposed rating plan introduces factors for breed, age and territory. These factors were also determined by researching competitor filings. The rating plan was modified using the average factor expected to ensure that this is revenue-neutral.

The base rate derived from the VB-II product is the proposed base rate for our Pet Illness and Injury Policy. The base rate for the Preventative Veterinary Medicine Endorsement is the difference between the rates derived from VBW-I and VB-II, adjusted to reflect the $750 sublimit.

Zurich has not previously written this program or any similar program in any state.

Zurich American Insurance Company Pet Insurance Program

California Exhibit 1 - Base Rate Development

VBW-I VB-II Notes Nationwide a Projected Loss Ratio 78.3% 86.0% From Exhibits 5-6 b Filed Rate Change 0.0% 0.0% c Revised Loss Ratio 78.3% 86.0% a / (1 + b) d Average Accident Date 7/26/2019 7/26/2019 From Exhibits 5-6 e Annual Loss Ratio Trend 6.0% 11.3% From Exhibits 5-6

Zurich f Average Accident Date 7/1/2020 7/1/2020 g Implied Loss Ratio 82.7% 95.0% c × (1 + e) ^ [(f - d) / 365.25] h Permissible Loss Ratio 67.5% 67.5% i Base Rate Adjustment 22.5% 40.8% g / h -1

j Current Base Rate 983.00 588.00 From VPIC-130349617 k Base Rate Adjustment 22.5% 40.8% i l Coverage Differences -7.9% -13.1% From Exhibit 2 m Off-Balance -13.3% -13.3% From Exhibit 3 n Implied Base Rate 961.96 624.11 j × (1 + k) × (1 + l) × (1 + m)

o Pet Illness and Injury Policy (U-PETZ-0100-A) 624.11 n (VB-II)

p Pet Wellness Endorsement (no sublimit) 337.85 n (VBW-I) - n (VB-II) q Impact of $750 Sublimit 28.86 From Exhibit 4 r Pet Wellness Endorsement U-PETZ-0101-A ($750 sublimit) 308.99 p - q

Exhibit 2 - Coverage Differences

VBW-I VB-II Ligament - 12-Month Waiting Period -3.0% -4.8% Pregnancy Exclusion -0.4% -0.6% Advertising and Reward -1.0% -1.8% Boarding or Kennel Fees -2.3% -3.9% Loss Due to Theft or Straying -1.5% -2.6% Total Impact -7.9% -13.1% Zurich American Insurance Company Pet Insurance Program

California Exhibit 3 - Off-Balance Factors

Territory Factor Distribution A 0.85 0.0% B 0.90 0.2% C 0.95 3.9% D 1.00 8.2% E 1.05 19.2% F 1.10 5.4% G 1.15 12.4% H 1.20 28.6% I 1.25 12.9% J 1.30 6.9% K 1.35 0.0% L 1.40 0.0% M 1.45 0.0% N 1.50 2.2% 1.15 100.0%

Adjustment: -13.3% = 1 / 1.15 - 1

Exhibit 4 - U-PETZ-0101-A - $750 Wellness Sublimit

Nationwide's VBW-I policy does not include a wellness sublimit. Nationwide offers an optional $500 wellness sublimit for a 5% credit, which is applied to the total premium.

Pet Illness and Injury Policy with Endorsement - no wellness sublimit: 961.96 Exhibit 1: o + p With $750 Wellness Sublimit - 3% credit on total premium: 933.10 = .97 × 961.96 Total premium reduction: 28.86 = 961.96 - 933.10 Zurich American Insurance Company Pet Insurance Program

California

Exhibit 5 - Projected Loss & LAE Ratio - Nationwide - VBW-I Product From VPIC-131531260

Earned Projected Treatment Premium @ Loss Projected Ultimate Year Current Rate Ultimate Trend Ultimate Loss & LAE Ending Level Loss & LAE Factor Loss & LAE Ratio 9/30/2016 72,376 61,769 9/30/2017 5,008,362 3,451,178 Total 5,080,738 3,512,947 1.13 3,979,783 78.3%

Exhibit 6 - Projected Loss & LAE Ratio - Nationwide - VB-II Product From VPIC-131531260

Earned Projected Treatment Premium @ Loss Projected Ultimate Year Current Rate Ultimate Trend Ultimate Loss & LAE Ending Level Loss & LAE Factor Loss & LAE Ratio 9/30/2016 18,668 2,030 9/30/2017 1,282,453 886,902 Total 1,301,121 888,932 1.26 1,119,044 86.0% Underwriting Guideline

Underwriting Guidelines: Pet Insurance Personal Inland Marine

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Underwriting Guideline

Underwriting Guidelines: Marsh Pet Insurance

Version: 1.0 Author/Contact: Brian O'Neill Region/Country: North America Commercial-Programs Line(s) of Business: Personal Inland Marine Effective Date: April 1, 2019

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Underwriting Guideline

Table of Contents 1. PROGRAM DESCRIPTION ...... 4 2. ELIGIBLE RISKS ...... 4 3. POLICY CHANGES ...... 4 3.1 MIDTERM CHANGES ...... 4 3.2 RENEWAL CHANGES ...... 4 3.3 UNDERWRITING REQUIREMENTS FOR INCREASE IN POLICY BENEFITS AT RENEWAL ...... 4 4. RENEWALS ...... 4 5. BILLING ...... 4 6. GLOBAL SANCTIONS SCREENING (OFAC) ...... 5 6.1 PROCEED AS FOLLOWS WHEN YOU HAVE A ZTR HIT ...... 5 7. DOCUMENT RETENTION ...... 5 8. BINDING AUTHORITY ...... 6 9. BACKDATING ...... 7 10. POLICY TERM ...... 7 11. REVISION HISTORY ...... 7

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Underwriting Guideline

1. PROGRAM DESCRIPTION This program will provide Accident, Health, and Wellness policies to felines and canines through a workplace benefit offering as well as a direct-to-consumer offering.

The intent is to provide coverage for accident and illness with the option to add wellness coverage via endorsement.

2. ELIGIBLE RISKS  Animals over 8 weeks old are eligible for coverage  Coverage is to be provided for felines or canines only  All U.S. states and D.C. (policyholders in Guam and Puerto Rico will not be eligible)  Policies are not eligible for $0 deductible and 0% copayment

3. POLICY CHANGES 3.1 MIDTERM CHANGES Any midterm request for adding coverage is subject to a thirty day (30) waiting period. A decrease in insurance coverage is allowed at any time. An increase in insurance coverage (e.g., increase in copayment, decrease in deductible) is subject to review by Zurich or by an appointed representative. Policy limits cannot be changed midterm.

3.2 RENEWAL CHANGES Policy changes are permitted at renewal subject to review of:  Claims history  Medical records  Underwriting requirements

3.3 UNDERWRITING REQUIREMENTS FOR INCREASE IN POLICY BENEFITS AT RENEWAL At the time of a request to increase policy benefits, the following criteria must be evaluated:  Any medical conditions that are serious, chronic, or may become chronic  Any undiagnosed lumps, bumps, growth, tumors or cancer  Currently ill or with an ongoing illness  A medical condition that may become a surgical condition  Any pre-cancerous or cancerous conditions

4. RENEWALS Policies will automatically renew. State notices should be sent in compliance with state statutes.

5. BILLING All policies will be agency billled.

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Underwriting Guideline

6. GLOBAL SANCTIONS SCREENING (OFAC) Global Sanctions Screening is MANDATORY on all policies. This includes new, renewal and any endorsement request to add an entity or individual to the policy. ALL ENTITIES OR INDIVIDUALS SHOWN ON THE POLICY WILL BE SCREENED. Names to be screened will include any entity or individual with an interest in the policy such as: Named Insured, any Additional Insured, Mortgagee, Lessor, etc. Instructions and guidelines for this process are listed below. You will need to execute the contract and follow all instructions. Please contact your Zurich Program underwriter if you have any questions.

6.1 PROCEED AS FOLLOWS WHEN YOU HAVE A ZTR HIT Potential matches must be sent to a Zurich Sanctions Analyst. Email communication should include:

To: [email protected] Subject: ZP OFAC – Insured Name Text: Include the Zurich Submission ID or Insured Name Attach: Screen print / documentation for the potential sanctions match (please include as much information as possible, e.g. full name, address, date of birth)

Any cleared “hit” must be appropriately documented in your underwriting file: Documentation shall include the screening date, the screening matches, and a description of how each screening match was resolved.

7. DOCUMENT RETENTION The Program Administrator has the responsibility to comply with Zurich's document retention initiatives, which governs the retention of all documents pertaining to the following:  Indications;  Quotes (bound or unbound, including all revisions to quotes and spoiled quote);  Dead/declined quotes and proposals;  Policies and related documents;  Submissions; and  Underwriting analysis, methodologies of bidding/quoting and binding and underwriting guidelines

The definition of "documents" includes drafts, notes and other formal writings. Such term shall be broadly interpreted by the Program Administrator to include electronic documents including email, applications data and metadata, as well as audio and video recordings, whether maintained in individual offices of the Program Administrator or any other off-site location, including laptop computers or other mobile devices and any other device and any device that is able to store such material.

If the program administrator is in possession of data in both hard copy and electronic format, both formats are to be preserved unless they are absolutely identical and have been verified to be so by the diligent efforts of the Program Administrator (e.g., a hard copy would be retained if it includes handwritten annotations not present in the electronic format).

The Program Administrator will retain such documents indefinitely until such time as Zurich advises the Program Administrator that it is no longer required to comply with Zurich's document retention initiatives as stated in these Underwriting Guidelines.

However, in the event the Program Administrator has been advised by Zurich that it is in posssession of specific data subject to the document retention initiatives made part of these Underwriting Guidelines, the Program Administrator shall not be required to retain such data.

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Underwriting Guideline

The underwriting information to be managed is further defined as:  Submissions and Quotes Not Bound - Records related to requests for insurance coverage by potential customers and issuance of quotes that are not bound or rejected. Includes quotes not bound, submissions, unsolicited submissions, and submissions for insurance Zurich is not eligible to write. Examples include quotes and submissions not bound or taken, Dead /declined quotes or proposals.

Submissions and Quotes Not Bound have a retention period of Active + 20 years. The retention period begins when the submission is rejected or the quote is not bound or rejected.

 Underwriting and Policy Records - Records related to policy administration and underwriting of insurance policies issued by the company. Examples include policy administration and supporting documentation, policy issuance instructions, policy documents, original applications, rate quotes, renewal information, endorsements, internal underwriting reports, loss run reports, and loss control policies, programs and procedures, site reports, service reports, progress reports and recommendations, technical recommendations, training records, and any training materials distributed to the insured.

Underwriting and Policy Records have a retention period of Active + 20. This means that the 20 year period begins when the policy is superseded or is no longer in effect.

You must retain such documents until such time as Zurich advises you that it is no longer required to comply with Zurich’s document retention initiatives as stated in these Underwriting Guidelines. In the event you have been advised by Zurich that it is not in possession of specific data subject to the document retention initiatives made part of these Underwriting Guidelines, you shall not be required to retain such data.

In the event of termination of your relationship with Zurich, in accordance with Company instructions, you shall promptly surrender to the Company all books, supplies, undelivered policies, databases, documents as defined above, information on websites created for or provided by the Company, or other property furnished by the Company to you or accessed by you with permission from the Company with an accounting thereof, pursuant to Section 15.10, Return of Company Supplies, Books and Other Property, in your Program Administrator Agreement.

The return of company materials, documents, reports, etc. as mentioned above, is in keeping with Zurich’s document retention initiatives.

Please see Section 15.10, Return of Company Supplies, Books and Other Property in your Program Administrator Agreement for additional information, or, contact your Zurich Program Underwriter for information regarding document disposal.

You also have the option to contact [email protected] for instructions on how to return Zurich records.

8. BINDING AUTHORITY Your binding authority is defined by your contract, underwriting guide and your schedule of authority. The schedule of authority will be a separate attachment to this underwriting guide. You may not delegate or assign any part of this authority to your retail agents. Your underwriters and retail agents should be advised coverage can be bound (subject to your receipt of a signed Short Term Production Application) according to the following effective date guidelines:

 Verbal requests to bind are not allowed.  Written requests may be bound the date of receipt.  Post-marked requests may be bound the date you receive the material. 4/1/2019 6 of 7

Underwriting Guideline

 Policies are effective at 12:01 A.M. Standard Time at the mailing address of the named insured.

9. BACKDATING Backdating coverage is only permitted in the event of the death of a pet.

10. POLICY TERM A policy may be written for a term of less than one year. Policies will not be written for a term longer than one (1) year.

11. REVISION HISTORY

Revision History Description of Version Number Version Date Version/Update Author of Version 1.0 4/1/2019 Original document Brian O’Neill

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Zurich American Insurance Company Pet Insurance Program California

Exhibit 7 - Rate Change Comparison

Carrier Rate Change VBW-I VB-II Notes Nationwide Minimum 16.0% 22.6% From State Trackings # 19-1271 and 19-1273, Maximum 44.7% 53.1% Prior Approval Rate Template Proposed 20.0% 20.0%

Zurich Proposed 22.5% 40.8% Exhibit 1 - Base Rate Adjustment (i) Instructions for Completing the Prior Approval Rate Template For Property & Liability Lines

Note: For information on populating the application in its entirety, including the Prior Approval Rate Application, Prior Approval Rate Template and Standard Exhibits Template, refer to the complete Prior Approval Rate Filing Instructions posted in PDF format on the CDI website, below: http://www.insurance.ca.gov/0250‐insurers/0800‐rate‐filings/

A rate change calculation page (i.e., '7.iRate Change Calculation) is required for each coverage (e.g., BI, PD, MP, UM, COLL, COMP, etc.), form (e.g., HO‐3, HO‐4, HO‐6, etc.) or program (e.g., Auto Dealers, Garagekeepers, Truckers/Motor Carriers, 1) etc.) for which a rate change is being requested. For each filing submitted, download a new Application and Rate Template ‐ do not "recycle" a template from a previously approved filing.

2) Areas of insurer input are generally identified with blue font text and/or light blue outlined boxes.

In addition to identifying the coverage, forms or programs included in this Prior Approval Rate Template , enter the insurer information common to all coverages in the "1.General" page, including Company Name; Line Type (Personal or Commercial); General Line; Marketing System Distribution (percentage of each system used, totaling 100%); Prior Effective 3) Date (of current rates); Proposed Effective Date (of proposed new rates); Data Aggregation Method used (accident year, report year, policy year); Most Recent Year of Experience Data; and Request for Variance, if applicable. Also indicate if this application reflects a new program.

Enter data from the insurer's Combined Annual Statement into unshaded boxes in pages 3 and 4 to generate Yield, Federal Income Tax on Investment Income and Excluded Expense Ratio for the insurer group. Asset yield percentages are linked to 4) an internal California Department of Insurance file. To ensure the latest yield/ROR information is used, go to Data menu in the Excel ribbon, click "Edit Links" and then click "Open Source."

For the ith coverage, form or program, enter data into unshaded boxes of the '6.iRatemaking Data' page only. Enter 5) numerical data only. For inapplicable fields, enter 0 for dollar ($) or percentage (%) fields and 1.00 for factors. For coverages, forms or programs requiring more than three years of data, click the "Expand to show six years" button.

On each '6.iRatemaking Data' page, rows for data associated with variance requests related to the efficiency standard are 6) hidden unless that request is indicated on the '1.General' page. Enter variance data, if supported by a Variance Request. Final decisions regarding variances will be made by the CDI and/or administrative hearing. On each '6.iRatemaking Data' page, rows for reinsurance data associated with lines of business for which recognition of 7) reinsurance is allowable (Earthquake and certain Medical Malpractice) are hidden unless those lines are selected on the '1.General' page. If applicable, enter all requested reinsurance information.

For results regarding the ith coverage, form or program, refer to the '7.iRate Change Calculation' page. Hyperlinks are 8) available at the bottom of the '6.iRatemaking Data' page and the corresponding '7.iRate Change Calculation' page for each coverage, form or program for convenient navigation between those pages.

If filing Advisory Organization Loss Costs with a Loss Cost Multiplier, refer to specific Instructions for Completing the LCM 9) Template , to the right.

10) Refer to the complete Prior Approval Rate Filing Instructions for additional information.

12/12/2018 Edition Prior Approval Rate Template Instructions for Completing the Loss Cost Multiplier Calculation Within the Prior Approval Rate Template

A separate LCM Calculation page is available for every coverage, form or program for which a Prior Approval Rate Template 1) is submitted. The LCM Calculation pages are hidden unless the appropriate box on the "1.General" page is selected.

For the ith coverage, form or program, enter data into unshaded boxes of the '8.iLCM Calculation' page only. Areas of 2) insurer input are generally identified with blue font text and/or light blue outlined boxes.

For new program filings, enter the following data: the CDI file number associated with the approved advisory organization filing supporting the loss costs to be adopted; the AOE or LAE load as filed by the advisory organization; and the basis of that 3) AOE or LAE load.

For existing program filings, enter the following data: the CDI file number associated with the advisory organization filing supporting the company’s currently used loss costs; the current company LCM; the CDI file number(s) associated with all 4) changes to advisory organization loss costs since the filing underlying the company’s currently used loss costs, separated by commas; and the cumulative percent change in loss costs identified by those CDI file number(s), both as originally filed and as adjusted for the company's distribution.

5) Refer to the complete Prior Approval Rate Filing Instructions for additional information.

12/12/2018 Edition Prior Approval Rate Template State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

PRIOR APPROVAL RATE TEMPLATE FOR PROPERTY & LIABILITY LINES GENERAL INFORMATION

Completed by: Date:

CDI File # (Department Use Only) :

Company Name: Zurich American Insurance Company

Marketing System Distribution: %Captive %Direct %Independent 100.0%

Line Type:

General Line :

Proposed Effective Date (new rates): 7/1/2019

New Program: LCM Calculation(s) Included: (LCM Calculation(s) is(are) hidden unless this box is checked.)

Data Aggregation:

Most Recent Year of Experience Data Ending: 20184 (Enter in YYYYQ format.) Enter name of each coverage/form/program for which a rate change is being requested in the cells below. Otherwise, leave blank. Prior Effective Proposed % Detailed Line Description(s) Coverage/Form/Program Date (current Impact rates) 2 Pet Insurance 0.0% 1 1 1 1 1 1 1 1 1

Variance Request: Does the Ratemaking Data include a Request(s) for Variance? Variance #: If yes, is Variance #3 requested for any coverage?

12/12/2018 Edition Prior Approval Rate Template Page 1 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine CDI File # (Department Use Only):

PRIOR APPROVAL RATE TEMPLATE FOR PROPERTY & LIABILITY LINES SUMMARY

Projected Annual Minimum Permitted Maximum Permitted Change at Minimum Change at Maximum Coverage/Form/Program Proposed % Premium ($) Earned Premium ($) Earned Premium ($) % % Pet Insurance 1,000,000 799,518 1,000,623 ‐20.0% 0.1% 0.0%

Combined 1,000,000 799,518 1,000,623 ‐20.0% 0.1% 0.0%

Combined Total Earned Exposures for Latest Year: 70

Average Earned Premium $ per Exposure Projected Earned Coverage/Form/Program Projected Minimum Permitted Maximum Permitted Proposed Exposures

Pet Insurance 680.27 543.89 680.70 680.27 1,470

Combined 14,285.71 11,421.69 14,294.61 14,285.71 70

Projected Annual Projected Annual Projected Annual Coverage/Form/Program Ultimate Loss & DCCE Ultimate Loss & DCCE Premium ($) ($) Ratio Pet Insurance 1,000,000 675,000 67.5%

Combined 1,000,000 675,000 67.5%

12/12/2018 Edition Prior Approval Rate Template Page 2 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine CDI File # (Department Use Only):

PROJECTED YIELD AND FEDERAL INCOME TAX RATE ON INVESTMENT INCOME

Short‐Term Assets Intermediate‐Term Assets Long‐Term Assets No Maturity

Over 1 Year thru 5 Over 5 Years thru Over 10 Years Line Description 1 Year or Less Over 20 Years Date Years 10 Years thru 20 Years

1.7 U.S. Governments 683,410,126 2,672,073,290 859,671,917 25,837,225 118,316,817

2.7 All Other Governments 240,842,042 699,637,198 275,025,791 0 249,475

States, Territories and 3.7 69,903,533 77,832,844 171,039,459 12,962,499 3,990,984 Possessions

4.7 Political Subdivisions 12,077,715 83,316,543 292,459,656 28,498,053 20,767,596

Special Revenue and 5.7 356,218,614 1,069,598,093 1,581,876,389 611,466,699 695,450,228 Assessment Obligations

6.7 Industrial and Miscellaneous 661,637,840 3,588,644,311 3,096,424,933 432,756,648 129,716,373

7.7 Hybrid Securities 0 0 0 17,828,439 391,163

Parent, Subsidiaries and 8.7 00000 Affiliates

9.7 SVO Identified Funds

Source: Schedule D, Part 1A, Section 1 of the insurer group's most recent consolidated (combined) statutory Annual Statement.

Short‐Term Assets Intermediate‐Term Assets Long‐Term Assets

1 Year or Less Over 1 Year thru 10 Years Over 10 Years

Government Bonds (Sum of (1) 924,252,168 4,506,408,196 144,403,517 Lines 1.7 & 2.7)

Other Taxable Bonds (Sum of (2) Lines 6.7, 7.7, 8.7 and one‐half 839,747,147 8,010,806,485 1,234,151,087 of Line 5.7)1 Tax‐Exempt Bonds (Sum of (3) Lines 3.7, 4.7 and one‐half of 260,090,555 1,950,385,743 719,677,596 Line 5.7) (Note: CCR §2644.20 refers to bond asset classes of "Credit Tenant Loans" and "Public Utilities" that are no longer recorded in the NAIC Annual Statement Schedule D, Part 1A, Section 1. Assets included in "Other Taxable Bonds" conform to the current NAIC Annual Statement Blank.) 1 SVO Identified Funds are treated as Other Taxable Long‐Term Bonds.

12/12/2018 Edition Prior Approval Rate Template Page 3.1 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine CDI File # (Department Use Only):

PROJECTED YIELD AND FEDERAL INCOME TAX RATE ON INVESTMENT INCOME (continued) Currently Return on Federal Income Federal Income Invested Assets1 Available Yield2 Invested Assets Tax Rate Taxes [1] [2] [3] = [1] * [2] [4] [5) = [3] * [4] (1) U.S. Government Bonds (i) Short‐Term 924,252,168 2.4% 22,520,944 21.00% 4,729,398 (ii) Intermediate‐Term 4,506,408,196 2.7% 119,570,031 21.00% 25,109,706 (iii) Long‐Term 144,403,517 2.9% 4,120,314 21.00% 865,266 (2) Other Taxable Bonds (i) Short‐Term 839,747,147 2.5% 21,161,628 21.00% 4,443,942 (ii) Intermediate‐Term 8,010,806,485 3.5% 276,527,418 21.00% 58,070,758 (iii) Long‐Term 1,234,151,087 4.2% 51,543,954 21.00% 10,824,230 (3) Tax‐Exempt Bonds (i) Short‐Term 260,090,555 2.0% 5,177,883 5.25% 271,839 (ii) Intermediate‐Term 1,950,385,743 2.3% 44,090,124 5.25% 2,314,731 (iii) Long‐Term 719,677,596 3.3% 23,600,871 5.25% 1,239,046 (4) Common Stock 2,059,730,304 (i) Dividends 2.2% 44,956,154 13.13% 5,900,495 (ii) Capital Gains 8.4% 173,009,084 21.00% 36,331,908 (5) Preferred Stock Dividends 0 4.9% 0 13.13% 0 (6) Mortgage Loans 0 4.2% 0 21.00% 0 (7) Real Estate 1,169,333,479 4.6% 53,581,459 21.00% 11,252,106 (8) Cash (117,626,391) 2.4% (2,866,163) 21.00% (601,894) (9) Other 1,769,506,688 (i) Dividends 2.2% 38,621,666 13.13% 5,069,094 (ii) Capital Gains 8.4% 148,631,464 21.00% 31,212,607 (10) Total Gross Invested Assets 23,470,866,573 1,024,246,830 197,033,233 (11) Investment Expense3 60,977,577 21.00% 12,805,291 (12) Total Net Invested Assets 23,470,866,573 963,269,253 184,227,942 (13) Federal Income Tax: Line (12); column [5]/column [3] 19.1% Projected Yield on Invested Assets: Line (12), column (14) 4.1% [3]/column [1] Most Recent Calendar Year (15) Loss Reserves4 11,166,505,223 (16) Loss Adjustment Expense Reserves4 2,958,796,672 (17) Unearned Premium Reserves4 4,274,053,819 (18) Surplus as Regards to Policyholders4 7,619,035,873 (19) Total Reserves and Surplus 26,018,391,587 Projected Yield adjusted to Reserve and Surplus Base: Line (20) (14), column [2]*Line (12), column [1]/Line (19), column [1] 3.7% 1 Source for Column [1], Lines (4) through (9): Page 2 (Assets) of the insurer group's most recent consolidated (combined) statutory Annual Statement. ‐ Line (8) Cash: Page 2 (Assets) Line 5, cash only; cash equivalents and short‐term investments are included in Schedule D. ‐ Line (9) Other: Page 2 (Assets) Sum of Lines 6, 8, 9 and 11. 2 Currently available yields are defined in CCR §2644.20. Latest values are posted at: http://www.insurance.ca.gov/0250‐insurers/0800‐rate‐filings/0200‐prior‐approval‐factors/ Month/Year (Yield): March 2019 3 Source: Page 11, Line 25 of the insurer group's most recent consolidated statutory Annual Statement. Entered as a positive expense. 4 Source for Column [1], Lines (15) through (18): Page 3 (Liabilities, Surplus and Other Funds) of the insurer group's most recent consolidated statutory Annual Statement, Lines 1, 3, 9 and 37, respectively.

12/12/2018 Edition Prior Approval Rate Template Page 3.2 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine CDI File # (Department Use Only):

EXCLUDED EXPENSE RATIO Countrywide Insurer Group Data

2nd Prior Calendar 1st Prior Calendar Most Recent Year Year Calendar Year 2015 2016 2017 Countrywide direct earned premium for lines of business subject to Proposition 8,418,463,000 7,930,302,000 7,770,533,000 103 ($): Countrywide direct earned premium for lines of business not subject to 3,340,537,000 3,308,835,000 3,327,620,000 Proposition 103 ($): Total countrywide direct earned premium ($): 11,759,000,000 11,239,137,000 11,098,153,000 (Note: Total must reconcile to the countrywide direct earned premium in the Insurance Expense Exhibit, Part 3 for the insurer group .) Check box if the excluded expenses entered in this page are derived on a countrywide, group basis CCR §2644.10 (b): Executive Compensation

2nd Prior Calendar Year 1st Prior Calendar Year Most Recent Calendar Year 2015 2016 2017 Cash & Salary Bonus Cash & Salary Bonus Cash & Salary Bonus 1st Highest Paid 1,082,623 3,269,486 1,102,149 495,000 3,042,986 1,080,000 2nd Highest Paid 503,715 1,204,797 1,007,006 133,100 1,207,425 380,688 3rd Highest Paid 501,885 1,060,400 580,190 127,875 1,018,891 544,200 4th Highest Paid 589,290 898,876 535,838 170,280 1,082,373 330,000 5th Highest Paid 571,593 905,417 550,138 148,500 1,012,632 310,200

2nd Prior Calendar Year 1st Prior Calendar Year Most Recent Calendar Year 2015 2016 2017 Maximum Maximum Maximum Excessive Amount Excessive Amount Excessive Amount Permissible Permissible Permissible 1st Highest Paid 1,218,597 3,133,512 1,189,398 407,751 1,179,611 2,943,375 2nd Highest Paid 654,820 1,053,692 641,310 498,796 636,771 951,342 3rd Highest Paid 578,968 983,317 565,906 142,159 561,523 1,001,568 4th Highest Paid 483,559 1,004,607 473,327 232,791 469,891 942,482 5th Highest Paid 417,489 1,059,521 409,047 289,591 406,209 916,623 Total Excessive 7,234,649 1,571,088 6,755,390

CCR §2644.10 (f): Institutional Advertising

2nd Prior Calendar Year 1st Prior Calendar Year Most Recent Calendar Year 2015 2016 2017 Institutional Non‐Institutional Institutional Non‐Institutional Institutional Non‐Institutional Total Advertising1 26,774,191 23,920,515 22,399,055 1 Note: For each calendar year, the sum of Institutional and Non‐Institutional advertising expenses must reconcile to the total advertising expenses reported in the Insurance Expense Exhibit, Part 1, Line 4 for the insurer group .

12/12/2018 Edition Prior Approval Rate Template Page 4.1 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine CDI File # (Department Use Only):

EXCLUDED EXPENSE RATIO (continued) Countrywide Insurer Group Data

Check box if the excluded expenses entered in this page are derived on a countrywide, group basis 2nd Prior 1st Prior Most Recent Calendar Year Calendar Year Calendar Year 2015 2016 2017 CCR §2644.10 (a): Political contribution and lobbying 83,530 46,582 62,000

CCR §2644.10 (b): Excessive Executive Compensation (Page 4.1) 7,234,649 1,571,088 6,755,390

CCR §2644.10 (c): Bad faith judgments and associated DCCE 1,591,038 4,959,212 2,568,925

CCR §2644.10 (d): All costs for unsuccessful defense of discrimination claims 000

CCR §2644.10 (e): Fines and penalties 000

CCR §2644.10 (f): Institutional advertising expenses (Page 4.1) 26,774,191 23,920,515 22,399,055

CCR §2644.10 (g): Excessive payments to affiliates 000

Total Excluded Expenses 35,683,408 30,497,397 31,785,370

Excluded Expense Ratio 0.3% 0.3% 0.3%

Three‐Year Average Excluded Expense Ratio 0.3%

12/12/2018 Edition Prior Approval Rate Template Page 4.2 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine CDI File #:

FINAL ADJUSTED CDI PARAMETERS

Efficiency Standard Marketing System Distribution 0.0% 0.0% 100.0% Final Adjusted Line Weighted Variance Excluded Detailed Line Description Coverage/Form Captive Direct Independent Efficiency Code Average Adjustment Expense Ratio Standard Inland Marine 9 Pet Insurance 28.3% 28.9% 28.3% 28.3% 0.0% 0.3% 28.0%

Leverage Factor Yields, Rate of Return Reserves Ratio & Premium Tax Values (Variance 3 not applied) as of March 2019

Unearned Final Adjusted Line Variance Detailed Line Description Coverage/Form Premium Loss Reserves Raw Factor Leverage Yield 3.7% Code Adjustment Reserves Factor Inland Marine 9 Pet Insurance 0.2530 0.3440 1.1022 1.0000 1.1022 FIT 19.1%

Premium Tax 2.4% Rate

Risk Free Rate 2.6% of Return

12/12/2018 Edition Prior Approval Rate Template Page 5 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine CDI File # (Department Use Only):

RATEMAKING DATA

Completed by: Variance #(s): Date Completed:

Detailed Line Description: Inland Marine Coverage: Pet Insurance

2nd Prior Year 1st Prior Year Most Recent Year Line Description Source Projected1 New Program2 Ending Ending Ending (0) Year 20164 20174 20184

(1) California Direct Written Premium 950,000

(2) California Direct Earned Premium 950,000

(3) Premium Adjustment Factor Exh 4 (4) Premium Trend Factor1 Exh 5 Miscellaneous Fees and Flat (5) Exh 6 50,000 Charges not included in Line (2) (6) Earned Exposure Units 1,470 (7) Historic Losses 675,000 Historic Defense and Cost (8) 0 Containment Expense (DCCE) (9) Loss Development Factor Exh 7 (10) DCCE Development Factor Exh 7 (11) Loss Trend Factor1 Exh 8 (12) DCCE Trend Factor1 Exh 8 (13) Catastrophe Adjustment Factor Exh 9 (14) Experience Credibility Exh 10 (15) Ancillary Income Exh 11 0 1 1 1 100 0% 100 0% Lines 16‐18 link directly to pages 3 and 4 of the rate template. (16) Excluded Expense Ratio Pg 4.2 0.3% Projected Federal Income Tax Rate (17) Pg 3.2 19.1% on Investment Income (18) Projected Yield Pg 3.2 3.7%

1 The Projected column should reflect the annual trend expressed as a percentage for premium, loss and DCCE trends, and credibility. 2 Refer to Section III.C. of the Prior Approval Rate Filing Instructions for New Program requirements.

12/12/2018 Edition Prior Approval Rate Template Page 6.1 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine CDI File # (Department Use Only): VARIANCE ‐ NONE RATE CHANGE CALCULATION

Completed by: Date Completed: Prior Effective Date: Proposed Effective Date: 7/1/2019 Detailed Line Description: Inland Marine Coverage: Pet Insurance

Data Provided by Filer 20164 20174 20184 Projected Prem_Written 950,000 Prem_Earned 950,000 Prem_Adj Prem_Trend 0.0% Misc_Fees 50,000 Exposures_Earned 1,470 Losses 675,000 DCCE 0 Loss_Devt DCCE_Devt Loss_Trend 0.0% DCCE_Trend 0.0% CAT_Adj Anc_Income 0 Credibility 100.0% ExpRatio_Excluded 0.3% FIT_Inv 19.1% Yield 3.7% CDI Parameters FIT_UW 21.0% EffStd_Final Data as of: 2017 28.0% LevFact_Final Data as of: 2017 1.10 PremTaxRate 2.4% SurplusRatio 0.91 ResRatio_UPR Data as of: 2017 0.25 ResRatio_Loss Data as of: 2017 0.34 ROR_RiskFree Data as of: March 2019 2.6% ROR_Min ‐6.0% ROR_Max 8.6% Calculations 20164 20174 20184 Prem_Adjusted 1,000,000 Losses_Adjusted 675,000 DCCE_Adjusted 0 LossDCCERatio_Adjusted 67.5% TCRLP_perExp 680.27 LossDCCE_perExp 459.18 CompLossDCCE_perExp 458.90 CredLoss_perExp 459.18 Anc_Inc_perExp 0.00 InvInc_Fixed 1.3% InvInc_Variable 4.4% Net_AnnualTrend 0.0% Comp_Trend 0.0% Max_Profit 9.9% Min_Profit ‐6.9% UW_Profit 4.6% Min_Denom 0.83 Max_Denom 0.67 Min_Premium $543.89 Max_Premium $680.70 CHANGE_AT_MIN ‐20.0% CHANGE_AT_MAX 0.1% 12/12/2018 Edition Prior Approval Rate Template Page 7.1 Instructions for Completing the Prior Approval Rate Application

Note: For information on populating the application in its entirety, including the Prior Approval Rate Application, Prior Approval Rate Template and Standard Exhibits Template, refer to the complete Prior Approval Rate Filing Instructions posted in PDF format on the CDI website, below: http://www.insurance.ca.gov/0250‐insurers/0800‐rate‐filings/

Enter general filing characteristics associated with this application as well as company‐specific information on the "1.General" page. Areas of insurer input are generally identified with blue font text and/or light blue outlined boxes. If this filing contains 1) group data, select the appropriate indicator on the "1.General" page. The "2.Group" page will automatically unhide to allow for the identification of each company to which this filing applies.

Enter the type of filing to which this application applies. Complete all exhibits and Prior Approval Rate Application pages 2) required for the designated type of filing on the "3.Filing Type" page, in addition to the Prior Approval Rate Template and Standard Exhibits Template, where applicable. Refer to the Prior Approval Filing Instructions for more information.

On the "6.Program Detail" page, provide premium, loss and DCCE information for the entire line of business as shown in your company's Annual Statement as well as for each separate program that comprises your company's line of business. Programs 3) with less than $25M in premium each can be combined into one entry. The total of all programs must reconcile to the total Annual Statement line of business for each year provided. Click the "Add 5 Programs" button if additional programs are required. If filing to be submitted is a group filing, populate the page with group data.

If this filing includes a variance request, select the appropriate indicator on the "1.General" page. The "11.Variance Request" 4) page will automatically unhide to allow for the identification and impact of each variance being requested. Final decisions regarding variances will be made by the CDI and/or administrative hearing.

1/25/2019 Edition Prior Approval Rate Application State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

PRIOR APPROVAL RATE APPLICATION FOR PROPERTY & LIABILITY LINES GENERAL INFORMATION

Completed by: Date:

Your File #: (15 Character Maximum)

Filing Characteristics DEPARTMENT USE ONLY

Does this filing include a variance request? (Page 11 hidden) CDI File #:

If yes, SERFF #:

Is this a variance request submitted after the prior Filed Date:

approval application to which it applies? Compliance Date:

Provide the applicable CDI File #: Public Notice Date:

Does this file contain group data? If yes, complete Page 2. (Page 2 hidden) Deemer Date:

Is this a specialty filing? Intake Analyst: Line Type: Bureau/Senior:

General Line : Group Filing?: Yes No

Subline: X‐Reference #:

Program: Pet Insurance Filing Type: Rate Rule

Provide the most recent applicable CDI file # in this line, Form Variance

subline and/or program: New Program

% Change:

Company Information

Company Name: Zurich American Insurance Company Group Name: Zurich North America

NAIC Company Code: 16535 NAIC Group Code: 212

Organized under the laws of the State of: New York

Home Office: 1299 Zurich Way, Schaumburg IL 60196

Contact Name/Title:

Toll Free Phone #: Fax #:

Email Address:

Mailing Address:

I declare under penalty of perjury under the laws of the State of California, that the information filed is true, complete, and correct, and that price optimization methods or models have not been used in the development of the final rates for any segment of the filed rating plan.

Authorized Signature Date of Filing Telephone #

Refer to CDI website below for the most current rate template and prior approval factors: http://www.insurance.ca.gov/0250‐insurers/0800‐rate‐filings/ 1/25/2019 Edition Prior Approval Rate Application Page 1 1/25/2019 Edition Prior Approval Rate Application Page 1 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

FILING TYPE

The purpose of this filing is (check all that apply):

Type of Filing Required Documentation1,2,3 Pages 1 through 4, 8 through 10 & New Program (Includes adoption of advisory organization loss costs, forms and rules.) 12, Exhibit 16 plus Prior Approval Rate Template

Rates (Includes adoption of advisory organization loss costs.)

Pages 1 through 8 & 12, Exhibits 1‐ Rate increase 17 & 20, plus Prior Approval Rate Template

Pages 1 through 8 & 12, Exhibits 1‐ Rate decrease 17 & 20, plus Prior Approval Rate Template

Pages 1 through 8 & 12, Exhibits 1‐ Revenue‐neutral change (zero percent overall impact) 17 & 20, plus Prior Approval Rate Template

Variance Request

Page 11, Exhibit 13 plus Prior Filed together with the prior approval application to which it applies. Approval Rate Template

Pages 1 through 4, 11 & 12, Exhibit Filed after the prior approval application to which it applies. 13 plus Prior Approval Rate Template

Coverage Forms (Includes adoption of advisory organization forms.)

Pages 1 through 9 & 12, Exhibits 1‐ With rate impact 17 & 20 plus Prior Approval Rate Template

Without rate impact Pages 1 through 4, 9 & 12

Rules and Underwriting Guidelines (Includes adoption of advisory organization rules.)

Pages 1 through 8, 10 & 12, With rate impact Exhibits 1‐18 & 20 plus Prior Approval Rate Template

Pages 1 through 4, 10 & 12 plus Without rate impact Exhibit 18

1 Page numbers refer to pages of the Prior Approval Rate Application. Where Exhibits 5, 7 and 8 are required, applications must also include a completed Standard Exhibits Template. Exhibit 21 must be included for all Specialty filing applications. 2 All Private Passenger Automobile class plans must be filed separately from the Prior Approval Rate Applications. 3 Page 6 of the Prior Approval Rate Application is required solely for insurers submitting filings for a subset of their Homeowners Multiple Peril line.

1/25/2019 Edition Prior Approval Rate Application Page 3 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

IMPACT OF PROPOSED CHANGES

Proposed Overall Rate Change: 0.0% Proposed Earned Premium Per Exposure: $680.27 Proposed Effective Date: 07/01/19

Indicated % Proposed % Coverage/Form/Program1 Adjusted Earned Premium3,4 Projected Earned Premium4 Change Change2

(1) Pet Insurance 0.0% 0.0% $1,000,000 $1,000,000

(2) $0

(3) $0

(4) $0

(5) $0

(6) $0

(7) $0

(8) $0

(9) $0

(10) $0

Total 0.0% 0.0% $1,000,000 $1,000,000

1 Commercial Auto Liability and Physical Damage must be combined in one application, with separate Rate Calculation pages in the Prior Approval Rate Template for liability and physical damage coverages.

2 If this filing contains group data, fill in the proposed impact for each individual company on Prior Approval Rate Application Page 2. The total rate impact shown on this page will not necessarily be equal to any ofthe individual company premium impacts shown on Prior Approval Rate Application Page 2. 3 Adjusted earned premium is the historical earned premium for the most recent year adjusted to the current rate level and trended to the average earned date of the proposed rating period. These figures should reconcile to the Prior Approval Rate Template. 4 Total earned premium must include all income derived from miscellaneous fees and other charges.

1/25/2019 Edition Prior Approval Rate Application Page 4 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

RECONCILIATION OF DIRECT EARNED PREMIUM DATA Annual Statement Statutory Page 14 Calendar Year Data

Latest CDI 2nd Prior 1st Prior Calendar Most Recent Coverage/Form/Program1 Filing #2 Calendar Year Year Calendar Year #VALUE! #VALUE! YYYY

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

(10)

Total 000

Statutory Page 14

Difference 000

Explain any differences:

1 This page requires insurers to itemize each coverage/form/program until all data is reconciled to the corresponding annual statement line of insurance. The level of granularity of this page should be consistent with the number of Ratemaking Data sheets in the Prior Approval Rate Template and any other coverages/forms/programs that roll up to the annual statement line of insurance, once aggregated. 2 For residual market data, a filing number is not required.

1/25/2019 Edition Prior Approval Rate Application Page 5 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

ANNUAL STATEMENT LINE ‐ Inland Marine

Year Written Premium Earned Premium Incurred Loss IL% DCCE DCCE% IL+DCCE IL+DCCE % (1) YYYY 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! (2) #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! (3) #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! (4) 3 Yr Avg 0 0 0#DIV/0! 0#DIV/0! 0#DIV/0!

#VALUE! Note: Programs with less than $25M in premium each can be combined into one entry. Note: Ratios are weighted averages. Dollars are arithmetic averages.

Total ‐ All Programs

Year Written Premium Earned Premium Incurred Loss IL% DCCE DCCE% IL+DCCE IL+DCCE % (5) YYYY 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0! (6) #VALUE! 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0! (7) #VALUE! 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0! (8) 3 Yr Avg 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0!

Difference ‐ ‐ ‐ #DIV/0! ‐ #DIV/0! ‐ #DIV/0!

(specify program)

Year Written Premium Earned Premium Incurred Loss IL% DCCE DCCE% IL+DCCE IL+DCCE % YYYY 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! 3 Yr Avg 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0!

(specify program)

Year Written Premium Earned Premium Incurred Loss IL% DCCE DCCE% IL+DCCE IL+DCCE % YYYY 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! 3 Yr Avg 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0!

(specify program)

Year Written Premium Earned Premium Incurred Loss IL% DCCE DCCE% IL+DCCE IL+DCCE % YYYY 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! 3 Yr Avg 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0!

(specify program)

Year Written Premium Earned Premium Incurred Loss IL% DCCE DCCE% IL+DCCE IL+DCCE % YYYY 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! 3 Yr Avg 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0!

(specify program)

Year Written Premium Earned Premium Incurred Loss IL% DCCE DCCE% IL+DCCE IL+DCCE % YYYY 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! #VALUE! 00 0#DIV/0! 0 #DIV/0! 0 #DIV/0! 3 Yr Avg 0 0 0 #DIV/0! 0 #DIV/0! 0 #DIV/0!

1/25/2019 Edition Prior Approval Rate Application Page 6 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

1/25/2019 Edition Prior Approval Rate Application Page 6 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

ADDITIONAL CALENDAR YEAR DATA REQUIRED BY STATUTE

Refer to CIC §1857.7, CIC §1857.9 and CIC §1864 for more information.

Most Recent Calendar Line Type of Data Year (0) Calendar Year YYYY (1) Number of claims outstanding at beginning of year (2) Number of claims during the year (3) Number of claims closed during the year (4) Number of claims outstanding at year's end [ (1) + (2) ‐ (3) ] 0 (5) Unearned Premiums (6) Dollar amount of claims paid (7) Net loss reserves for outstanding claims excluding claims incurred but not reported (case reserves) (8) Net loss reserves for claims incurred but not reported (IBNR) (9) Losses incurred as a percentage of premiums earned, including IBNR (10) Net investment gain or loss and other income or gain or loss allocated to the line (11) Net income before federal and foreign income taxes [ (10) + (15) ] $0 (12) Total number of policies in force on the last day of the reporting period (13) Total number of policies canceled (14) Total number of policies non‐renewed (15) Net underwriting gain or loss ( = CY earned premiums less CY incurred loss less CY incurred expense ) (16) Separate allocations of expenses for: (17) (a) commissions and brokerage expense (18) (b) other acquisition costs (19) (c) general office expenses (20) (d) taxes, licenses and fees (21) (e) loss adjustment expense (DCCE & AOE) (22) (f) other expenses

1/25/2019 Edition Prior Approval Rate Application Page 7 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

MISCELLANEOUS FEES AND OTHER CHARGES

Check all fees that apply and identify the amount charged for each transaction. If no fees apply to this program, check here:

Miscellaneous Fees

New Business Renewal Business

Policy Fee Installment Fee (Fixed $) $12.00 $12.00 Endorsement Fee Inspection Fee Cancellation Fee Reinstatement Fee $10.00 $10.00 Late Fee SR‐22 Other Fees (specify below) New Customer Enrollment Fee $30.00 Fee 2 Fee 3 Fee 4

Ancillary Income

New Business Renewal Business

Installment Finance Charge (APR %) Non‐Sufficient Funds (NSF) Fee Membership Dues Premium Finance Revenues Other Fees (specify below) Fee 1 Fee 2 Fee 3 Fee 4

Use Exhibit 6 if additional space is needed to explain fees not listed above.

1/25/2019 Edition Prior Approval Rate Application Page 8 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

FORMS

Applicable Form Source of Form Coverage Change Reflects Coverage Change Includes Factor or Charge # Title Type Source CDI File #1 Category Restriction?2 Broadening? Rate Impact? % Impact ($, % or Description) Zurich Pet Illness and Injury Insurance Policy Proposed UPETZD001A CW (07/19) 43 1 N N (1) Declarations Page Current Proposed UPETZ0100‐A CW (07/19) Zurich Pet Illness and Injury Insurance Policy 3 3 2 N Y Y Included in Rating Plan (2) Current Proposed UPETZ0101ACA (07 19) Pet Wellness Endorsement ‐ California 2 3 2 N Y Y Included in Rating Plan (3) Current Proposed UPETZ0102A CW (07/19) Policy Changes 2 3 2 N N N (4) Current Proposed UPETZ105A CA (07/19) California Amendatory 2 3 1 N N N (5) Current Proposed UPETZ‐106‐A CW (07/19) Insurer Disclosure of Important Policy Provisions 4 3 1 N N (6) Current Proposed (7) Current Proposed (8) Current Proposed (9) Current Proposed (10) Current 1 If Source selected is ISO or Other Advisory Organization, provide the CDI File # of applicable filing from which the form is being adopted. If Source selected is Company and Category is Replacement, provide the CDI File # under which current form is approved. 2 Forms that restrict, exclude or delete coverage require consideration of a rate offset/credit. Provide the amount of prior losses incurred associated with the impacted coverage, if any. Legend of Response Codes Type Code Source Code Category Code (1) Application (1) Insurance Services Organization (ISO) (1) New, mandatory (5) Withdrawn, mandatory (2) Endorsement (2) Other Advisory Organization (2) New, optional (6) Withdrawn, optional (3) Policy (3) Company (3) Replacement, mandatory (4) Other (Describe in filing memorandum) (4) Other (Describe in filing memorandum) (4) Replacement, optional

1/25/2019 Edition Prior Approval Rate Application Page 9.1 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

RULES AND UNDERWRITING GUIDELINES

Insurers submitting a rule change filing must provide the information identified below. Complete Exhibit 18 as necessary to fulfill this requirement.

Check all that apply: (1) Introducing a new rule(s)

(2) Revising an existing rule(s)

(3) Adopting an approved Advisory Organization (AO) rule(s)

(4) Withdrawing an approved rule(s)

(5) Introducing or revising an underwriting guideline(s)1

If (1), (2) or (5) above is checked, provide the following: (a) The purpose for the rule or underwriting guideline or an explanation for revising an existing rule

or underwriting guideline (Exhibit 18)

(b) A copy of the current and proposed manual page corresponding to the rule or underwriting guideline

(c) The proposed charge for the rule, and justification of the charge including

the rate or premium development method (Exhibit 18)

(d) The rate impact of the rule or underwriting guideline on the current book of business, with

corresponding calculation of that impact (Exhibit 18)

(e) Advise if the rule is: (i) Optional (ii) Mandatory

If (3) above is checked, specify the approved CDI File #(s) of the AO rule:

If (4) above is checked, provide the following: (a) An explanation for the withdrawal of the rule (Exhibit 18)

(b) A copy of the current and proposed manual page corresponding to the withdrawn rule

(c) The rate impact of withdrawing the rule on the current book of business, with

corresponding calculation of that impact (Exhibit 18)

For all rule and underwriting guideline changes, provide any additional comments necessary to adequately explain the rule change (Exhibit 18).

1 Underwriting guidelines included in this filing are reviewed only insofar as they relate to rates contained in this filing or currently on file with the California Department of Insurance.

1/25/2019 Edition Prior Approval Rate Application Page 10 State of California Company: Zurich American Insurance Company Department of Insurance (CDI) Line: Inland Marine

FILING CHECKLIST

Use this checklist to assemble a complete application:

Prior Approval Rate Application Supporting Exhibits

General Information, Page 1 Exhibit 1 ‐ Filing History

Insurer Group Information, Page 2 Exhibit 2 ‐ Rate Level History

Filing Type, Page 3 Exhibit 3 ‐ Policy Term Distribution

Proposed Impact, Page 4 Exhibit 4 ‐ Premium Adjustment Factor

Reconciliation of Direct Earned Premium to Statutory Exhibit 5 ‐ Premium Trend Factor3 Data, Page 5

Program Detail, Page 6 Exhibit 6 ‐ Miscellaneous Fees and Other Charges

Additional Calendar Year Data Required by Statute, Exhibit 7 ‐ Loss and Defense & Cost Containment Page 7 Expense (DCCE) Development Factors3

Miscellaneous Fees and Other Charges, Page 8 Exhibit 8 ‐ Loss and DCCE Trend3

Forms, Page 9 Exhibit 9 ‐ Catastrophe Adjustment

Rules and Underwriting Guidelines, Page 10 Exhibit 10 ‐ Credibility Adjustment

Variance Request, Page 11 Exhibit 11 ‐ Ancillary Income

Filing Checklist, Page 12 Exhibit 12 ‐ Reinsurance Premium and Recoverables

Filing Memorandum Exhibit 13 ‐ Variance Request

Prior Approval Rate Template1 Exhibit 14 ‐ Rate Distribution

Standard Exhibits Template1 Exhibit 15 ‐ Rate Classification Relativities

Printed Rate and Rule Manual Pages1 Exhibit 16 ‐ New Program

Exhibit 17 ‐ Super Group Corporate Structure Underwriting Guidelines1 Verification (PPA only)

Forms1,2 Exhibit 18 ‐ Rules and Underwriting Guidelines

Copies of Reinsurance Agreements1 Exhibit 19 ‐ Supplemental Information

1 See Prior Approval Rate Filing Instructions. Exhibit 20 ‐ Customer Dislocation 2 Attach all independent forms and list all advisory organization forms. 3 Provide Standard Exhibits Template for these exhibits. Exhibit 21 ‐ Insurer's Ratemaking Calculations for Specialty Filings

1/25/2019 Edition Prior Approval Rate Application Page 12 SERFF Tracking #: ZURC-131915450 State Tracking #: 19-1596 Company Tracking #: 42557

State: California Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: /42557

Superseded Schedule Items Please note that all items on the following pages are items, which have been replaced by a newer version. The newest version is located with the appropriate schedule on previous pages. These items are in date order with most recent first.

Schedule Item Replacement Creation Date Status Schedule Schedule Item Name Creation Date Attached Document(s) 07/26/2019 Supporting New Prior Approval Rate Application 08/27/2019 CA Exhibit 18 Rules.pdf Document CA Exhibit 16 New Program.pdf CA.pdf Explanatory Memo CW 041019.pdf CW Memo.pdf Underwriting Guidelines Pet - California v5.pdf PriorAppRateAPL_Ed01-25- 2019.pdf PriorAppRateAPL_Ed01-25- 2019.xlsm PriorAppRateTl_Ed12-12-2018.pdf PriorAppRateTl_Ed12-12-2018.xlsm 04/25/2019 Supporting New Prior Approval Rate Application 07/26/2019 CA Exhibit 18 Rules.pdf Document CA Exhibit 16 New Program.pdf CA.pdf Explanatory Memo CW 041019.pdf CW Memo.pdf Underwriting Guidelines Pet - California v5.pdf PriorAppRateAPL_Ed01-25- 2019.pdf (Superceded) PriorAppRateAPL_Ed01-25- 2019.xlsm (Superceded) PriorAppRateTl_Ed12-12-2018.pdf (Superceded) PriorAppRateTl_Ed12-12-2018.xlsm (Superceded)

PDF Pipeline for SERFF Tracking Number ZURC-131915450 Generated 10/01/2019 02:47 AM