Zurich / Pet Health

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SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

State: New York Filing Company: Zurich American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program -NY Refile Project Name/Number: /42615

Filing at a Glance Company: Zurich American Insurance Company Product Name: Pet Insurance Program -NY Refile State: New York TOI: 09.0 Inland Marine Sub-TOI: 09.0004 Pet Insurance Plans Filing Type: Form/Rate/Rule Date Submitted: 08/27/2019 SERFF Tr Num: ZURC-132063298 SERFF Status: Closed-Approved State Tr Num: R2019003049 State Status: Closed Co Tr Num: 42615

Effective Date 09/01/2019 Requested (New): Effective Date 09/01/2019 Requested (Renewal): Author(s): Paula Bartell Reviewer(s): Sokhna Thiam (primary) Disposition Date: 09/18/2019 Disposition Status: Approved Effective Date (New): 09/18/2019 Effective Date (Renewal):

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

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General Information Project Name: Status of Filing in Domicile: Project Number: 42615 Domicile Status Comments: Reference Organization: Reference Number: Reference Title: Advisory Org. Circular: Filing Status Changed: 09/18/2019 State Status Changed: 09/18/2019 Deemer Date: 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. This is a refile of ZURC-131918610, NY DOI Number R2019001547. This refile is being submitted as a result of the conversation we had with the NY DFS on 8/20 with Dan Sheridan (Supervising Insurance Examiner / Property Bureau), Gerald Scattaglia (Bureau Chief), Bob Pothiwala (Examiner), and Sokhna Thiam (Line Examiner).

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 Speed-To-Market Field: enter code "98" for Speed-To-Market filings. Enter "0" for N/A.: 0 Terrorism Exclusion Field: enter code "46-01" for filings which includes forms, rates or rules for the Terrorism Exclusion. Enter "0" for N/A.: 0 Mold (Fungi, Bacteria, Virus) Exclusion Field: enter code "46-02" for filings which includes forms, rates or rules for the Mold Exclusion. Enter "0" for N/A.: 0 On the Rate/Rule Schedule Tab, the "Add Rate Data" button must be changed to "yes" for all rating rules and rate filings in order for the appropriate fields to be completed. Please enter "Yes" for filings with the rate data fields completed and "No" for all other filings.: Yes

PDF Pipeline for SERFF Tracking Number ZURC-132063298 Generated 09/19/2019 12:24 PM SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

Correspondence Summary Dispositions Status Created By Created On Date Submitted Approved Sokhna Thiam 09/18/2019 09/18/2019

Objection Letters and Response Letters Objection Letters Response Letters

Status Created By Created On Date Submitted Responded By Created On Date Submitted Pending Sokhna Thiam 09/11/2019 09/12/2019 Paula Bartell 09/12/2019 09/12/2019

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Disposition

Disposition Date: 09/18/2019 Effective Date (New): 09/18/2019 Effective Date (Renewal): Status: Approved Comment: This refers to the captioned filing and subsequent correspondence which provided additional information and amended the same.

Based on your advices and confirmation, the captioned filing, as amended, is hereby approved in accordance with Article 23 of the New York Insurance Law. The Manual Pages, including New York Exception Pages, are hereby acknowledged.

Very truly yours,

LINDA A. LACEWELL Superintendent of Financial Services

By: Sokhna Thiam Insurance Examiner New York State Department of Financial Services Property Bureau (212) 709-3826 [email protected]

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-132063298 Generated 09/19/2019 12:24 PM SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

Schedule Schedule Item Schedule Item Status Public Access Supporting Document Explanatory Memorandum Yes Supporting Document Personal Inland Marine Insurance Review Standards Yes Checklist Supporting Document Inland Marine -all filings must conform to Nationwide Yes Inland Marine Definition, section 2310(b) and (c). Supporting Document Side-By-Side Comparisons Yes Supporting Document Rates and/or Rating Plans Yes Supporting Document Consent-to-rate requirements Yes Supporting Document Application Yes Supporting Document Red-Line Yes Form Zurich Pet Illness and Injury Insurance Policy Yes Declarations Page Form Zurich Pet Illness And Injury Insurance Policy Yes Form Pet Wellness Endorsement Yes Form Policy Changes - New York Yes Form (revised) New York Amendatory Yes Form New York Amendatory 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 - New York

PDF Pipeline for SERFF Tracking Number ZURC-132063298 Generated 09/19/2019 12:24 PM SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

Objection Letter Objection Letter Status Pending Objection Letter Date 09/12/2019 Submitted Date 09/12/2019 Respond By Date 09/27/2019 Dear Paula Bartell, Introduction: This refers to the captioned filing. This also refers to the conference call on 08/20/2019 regarding this filing. We have the following questions / concerns:

We note your indication that "Zurich will market the program through two different channels: Website - direct-to-consumer online platform and Worksite - employer benefit programs."

[1] - Please provide us with a copy of the policy application under the Supporting documentation; [2] - Kindly confirm that Insurance Fraud Warning Statement complies with Section 86.4 (d) of Regulation No. 95 and Section 403 of New York Insurance Law. [3] - Kindly confirm company's compliance with all requirements of Section 3425 of New York Insurance Law, with regards to cancellation notice and non-renewal.

We await your prompt reply. In the meantime, the captioned filing is not approved for use in New York State. Pursuant to the Department’s 2nd Supplement to Circular Letter No. 11 (1998), a substantive reply is expected within 15 days. If such response is not received, this file will be considered withdrawn and closed accordingly without further communication. Thereafter, to request further review of the subject matter of this filing, a new submission must be made, in accordance with the provisions of Circular Letter No. 11 (1998) and supplements (and SERFF filing submission guidelines), which should address any outstanding issues included in this and any earlier communications.

Please provide notification by e-mail at [email protected] when you have responded to an objection letter or sent a Note to Reviewer via SERFF. This will help expedite review of this filing. This e-mail address should not be used for any correspondence other than for notification that the company has sent correspondence through SERFF.

Very truly yours, Sokhna Thiam Insurance Examiner New York State Department of Financial Services Property Bureau (212) 709-3826 [email protected]

Conclusion:

Sincerely, Sokhna Thiam

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Response Letter Response Letter Status Submitted to State Response Letter Date 09/12/2019 Submitted Date 09/12/2019 Dear Sokhna Thiam, Introduction: The following information is in response to your comments.

Response 1 Comments: 1) Attached as supporting documentation

2) Confirmed. We are attaching a screen shot of the submission page to demonstrate compliance

3) We can confirm that we are in compliance with the provisions of 3425, but we have revised the attached version of U-PETZ-105 NY to make it more explicit.

Changed Items:

Supporting Document Schedule Item Changes Satisfied - Item: Application Comments: Attachment(s): Compressed.pdf TrustedPals_Fraud_NY_Visuals-9.12.19.pdf

Satisfied - Item: Red-Line Comments: Attachment(s): U-PETZ-0105-A NY 0719 Redline.pdf

PDF Pipeline for SERFF Tracking Number ZURC-132063298 Generated 09/19/2019 12:24 PM SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

Form Schedule Item Changes Item Form Form Edition Form Form Action Readability No. Name Number Date Type Action Specific Score Attachments Submitted Data 1 New York U-PETZ-105-A (07/19) END New U-PETZ-0105-A Date Submitted: Amendatory NY NY 0719.pdf 09/12/2019 By: Paula Bartell Previous Version 1 New York U-PETZ-105-A (07/19) END New U-PETZ-0105-A Date Submitted: Amendatory NY NY 0719.pdf 08/27/2019 By: Paula Bartell

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-132063298 Generated 09/19/2019 12:24 PM SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

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 UPETZ0101ACW Endorsement 0101-A CW 0719.pdf 4 Policy Changes - New U-PETZ- (07/19) END New 0.000 U-PETZ-0102-A York 0102-A NY NY 0719.pdf 5 New York Amendatory U-PETZ- (07/19) END New U-PETZ-0105-A 105-A NY NY 0719.pdf

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

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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

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

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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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Pet Wellness Endorsement

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 Expenses and Veterinary Services in SECTION V- DEFINITIONS are replaced with the following: Veterinary Expenses means the costs associated with 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. 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 CW (07/19) Page 1 of 1

INTERNAL USE ONLY

Policy Changes – New York

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. Type(s) of Change(s) ☐ Name(s) of Pet Owner(s) ☐ Name of Pet ☐ Phone Number, Email or Mailing Address of Pet Owner ☐ Company ☐ Policy Number ☐ Policy Period ☐ Copayment ☐ 0% ☐ 10% ☐ 20% ☐ 30% ☐ Limit ☐ $4,000 ☐ $8,000 ☐ $15,000 ☐ Unlimited ☐ Discount ☐ Deductible(s) ☐ $0 ☐ $100 ☐ $250 ☐ $500 ☐ $750 ☐ Wellness Endorsement ☐ Add Wellness Coverage ☐ Remove Wellness Coverage ☐ Waiting Period

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

U-PETZ-0102-A NY (07/19) Page 1 of 1 Includes copyrighted material of Insurance Services Office, Inc., with its permission.

New York Amendatory

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

I. SECTION III. PREMIUM PAYMENT, Subparagraph C. is replaced with the following: C. If there is a change in premium based upon a mid-term Policy change You requested, the revised premium will take effect on the first of the month following the Policy change Waiting Period. The Waiting Period for a mid- term policy change is specified on the Declarations Page. II. SECTION V. DEFINITIONS, Subparagraph X. is replaced with the following: 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 the Declarations Page. III. Section VI. CONDITIONS, Paragraph C. Cancellation, Nonrenewal and Renewal, is replaced with the following: 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 or last known address. Proof of mailing or delivery of notice will be sufficient proof of notice. 3. The cancellation will be effective as of the date shown on the Cancellation Notice, but: (a) not less than 15 days after mailing or delivery of this notice if We cancel for nonpayment of premium; or (b) not less than 30 days nor more than 120 days after mailing or delivery of this notice if We cancel for any other reason, which may include: (1) Conviction of a crime arising out of acts increasing the hazard insured against; (2) Discovery of fraud or material misrepresentation in obtaining the policy or in the presentation of a claim thereunder; (3) Discovery of willful or reckless acts or omissions increasing the hazard insured against; (4) Physical changes in the property insured occurring after issuance or last annual anniversary date of the policy which result in the property becoming uninsurable in accordance with the insurer's objective, uniformly applied underwriting standards in effect at the time the policy was issued or last voluntarily renewed; or (5) A determination by the superintendent that the continuation of the policy would violate or would place the insurer in violation of this chapter. 4. 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. 5. Nonrenewal. We may elect not to renew this Policy for one of the reasons listed above in Paragraph 3. We may do so by delivering to You written notice at least 45 days, but not more than 60 days before the expiration date of this Policy. Proof of mailing will be sufficient proof of notice.

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

6. 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. IV. Section VI. CONDITIONS, Paragraph D. Changes in Policy, is replaced with the following: 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 the Declarations Page. Certain changes made at Your request 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.

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

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

SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

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-132063298 Generated 09/19/2019 12:24 PM SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

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 1-10 New NY Rate Manual.pdf Company Pet Insurance Program Countrywide Rating Plan 2 Zurich American Insurance Pages 1 and 2 New NY exception.pdf Company Pet Insurance Program State Exception Page - New York

PDF Pipeline for SERFF Tracking Number ZURC-132063298 Generated 09/19/2019 12:24 PM Zurich American Insurance Company Exhibit MRP-1 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 Exhibit MRP-1 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 Exhibit MRP-1 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 Exhibit MRP-1 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.

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 - New York

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

(1) Base Rate The annual base rate is $831.26

(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 those who qualify as Medical Service Animals.

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

(1) Base Rate The annual base rate is $412.45

Section C - Fees

Name Description Amount Installment Fee ¹ $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 Does not apply to worksite programs

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

Territory Definitions - New York

County Territory Albany D Allegany D Bronx E Broome D Cattaraugus D Cayuga D Chautauqua D Chemung D Chenango D Clinton D Columbia E Cortland E Delaware D Dutchess E Erie G Essex D Franklin D Fulton D Genesee D Greene D Hamilton D Herkimer D Jefferson D Kings F Lewis D Livingston D Madison D Monroe F Montgomery D Nassau F New York I Niagara D Oneida D Onondaga F Ontario D Orange E Orleans D Oswego D Otsego D Putnam F Queens E Rensselaer D Richmond E Rockland E St. Lawrence D Saratoga D Schenectady D Schoharie D Schuyler D Seneca D Steuben D Suffolk F Sullivan E Tioga D Tompkins D Ulster E Warren D Washington D Wayne D Westchester F Wyoming D Yates D

7/1/19 edition - Page 2 SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

Supporting Document Schedules Satisfied - Item: Explanatory Memorandum Comments: Attachment(s): Explanatory Memo NY.pdf Item Status: Status Date:

Satisfied - Item: Personal Inland Marine Insurance Review Standards Checklist Comments: Attachment(s): NY PIM Checklist.pdf NY plcnr.pdf Item Status: Status Date:

Satisfied - Item: Inland Marine -all filings must conform to Nationwide Inland Marine Definition, section 2310(b) and (c). Comments: Acknowledge Attachment(s): Item Status: Status Date:

Satisfied - Item: Side-By-Side Comparisons Comments: Attachment(s): UPETZ0102ANY0719 Redline.pdf U-PETZ-0105-A NY 0719 Redline.pdf Item Status: Status Date:

Satisfied - Item: Rates and/or Rating Plans Comments: Attachment(s): NY Filing Sequence Checklist.pdf NY Exhibits.pdf Item Status: Status Date:

Bypassed - Item: Consent-to-rate requirements Bypass Reason: N/A Attachment(s):

PDF Pipeline for SERFF Tracking Number ZURC-132063298 Generated 09/19/2019 12:24 PM SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

Item Status: Status Date:

Satisfied - Item: Application Comments: Attachment(s): Compressed.pdf TrustedPals_Fraud_NY_Visuals-9.12.19.pdf Item Status: Status Date:

Satisfied - Item: Red-Line Comments: Attachment(s): U-PETZ-0105-A NY 0719 Redline.pdf Item Status: Status Date:

PDF Pipeline for SERFF Tracking Number ZURC-132063298 Generated 09/19/2019 12:24 PM Explanatory Memorandum Zurich American Insurance Company Zurich Pet Illness and Injury Insurance Form Filing – New York

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 NY This endorsement will be used to specify mid-term policy changes to the Zurich Pet Illness and Injury Policy or the Declarations Page. The details of the specific changes reflected by the check boxes will ultimately be included on an amended declarations page. It will not be used for changes to policy language or to premium. New York Amendatory U-PETZ-0105-A NY This form addresses deviations from the countrywide policy form required under New York law, such as Section 3425 of the New York Insurance Law.

Page 1 of 1 INTERNAL USE ONLY NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES REVIEW STANDARDS FOR PERSONAL INLAND MARINE

LINE OF BUSINESS: Inland Marine LINE(S) OF INSURANCE CODES Other Personal Inland Marine 9.0006 CODE: 9.0000 Pet Insurance Plans 09.0004 Boatowners/Personal Watercraft 9.0010

IF CHECKLIST IS NOT APPLICABLE, PLEASE EXPLAIN:

REVIEW REFERENCE DESCRIPTION OF REVIEW STANDARDS REQUIREMENTS LOCATION REQUIREMENTS OF STANDARD IN FILING GENERAL The following web site represents the Department's initiative to streamline the procedures Form/Page/Para REQUIREMENTS FOR for form, rate and rule filings: Reference ALL FILINGS https://www.dfs.ny.gov/insurance/filer.htm COVER LETTER AND CL 11 (1998) A cover letter is no longer required for filings submitted through SERFF. The filing should Acknowledged EXPLANATORY include an explanatory memorandum clearly explaining the intent of the filing, and MEMORANDUM highlighting any substantive changes (such as changes in ratemaking methodology or major coverages provided). If new form(s), territories, classification(s), or rule(s) are being filed and there are similar ones currently approved for use by a Rate Service Organization (RSO) or another insurer, or has been the subject of a filing previously not approved in New York, reference should be provided to the Department's file number or SERFF tracking number and effective date of the approval, or copies of the approved items should be included, if applicable. If the filing is currently in use in another state, this should be indicated. EXCLUSIONS & LIMITATIONS Discrimination §2606, §2607, & §2608 Unfairly discrimination provisions because of race, color, creed, national origin, disability Acknowledged (including treatment of mental disability), sex, and marital status are prohibited. Intentional Acts §1101(a) The provisions of the Insurance Law do not permit coverage for Intentional Acts. Acknowledged However, coverage must be provided for the "innocent insured." FILING SUBMISSION §2305 & §2307 Forms, territories, classifications, rating rules, rates and rating plans are subject to prior CL 19 (1992) approval. Supplement No 1 to CL 11 (1998)

Compliance Questionnaires, CL 11 (1998) Please refer to the following web site for additional information: Forms and Optional "Speed Supplement No 3 to CL 11 https://www.dfs.ny.gov/insurance/serff_main.htm#Section_II (1998) to Market" Filing Procedures 1 of 6 PIM (08/2018) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES REVIEW STANDARDS FOR PERSONAL INLAND MARINE

REVIEW REFERENCE DESCRIPTION OF REVIEW STANDARDS REQUIREMENTS LOCATION REQUIREMENTS OF STANDARD IN FILING NO FILE OR FILING Article 63 A (Personal Lines Policies) policy may be written as a Class 2 risk as long as it appears Acknowledged EXEMPTIONS 11NYCRR16 (Reg. 86) on the lists of eligible Class 2 risks contained in Section 16.12(e) of Regulation No.86. An

authorized insurer must obtain a “Special Risk License” prior to writing business in the "Free Trade Zone." Although filing is not required for a Class 2 risk, rates and policy forms applied to special risks must still satisfy governing standards set forth in the Insurance Law and regulations. PROHIBITED COVERAGES While the Department does not have an exhaustive list, some examples of prohibited Acknowledged coverages include punitive damages and corporal punishment. Please refer to the following web site for additional information: https://www.dfs.ny.gov/insurance/serff_main.htm#Section_IV SIDE BY SIDE CL 11 (1998) If the filing is a revision to existing form(s), territories, classification(s) or rule(s); Except for Acknowledged COMPARISON simple, non-substantive changes, a side-by-side comparison of the form(s) or rule(s) being proposed and those currently in use in New York, with all changes clearly marked and explained in the company's cover letter or memorandum must be included. Revisions to classifications and territories should include a comparison between those currently on file (in New York) and those proposed, including relevant statistical data (experience) and any rate or rate relativity effect. There should be a reference to the Department's previous file number and/or a copy of the approval letter in which the current form(s), territories, classification(s) or rule(s) were approved/acknowledged. FORMS: POLICY §2307, §3105, §3106, , Form/Page/Para §3407, §3407-a, §3435 & Reference PROVISIONS Article 54 11 NYCRR 86 (Reg. 95) 11NYCRR153 (Reg. 135) APPLICATIONS Filing exemption §2307(b) Applications which do not become part of the policy are exempt from filing requirements Acknowledged Fraud Warning Statement §403(d) None required on Personal Inland Marine Policy Forms or applications (only claim forms) Acknowledged 11NYCRR86.4 (Reg. 95) APPRAISAL Procedure for selection of §3408 While an appraisal provision is not required, such provision must comply with the N/A umpire requirements of §3408 for selection of an umpire on failure to agree. ARBITRATION Arbitration of disputes between an insured and the insurer may not be required. N/A BLANK ENDORSEMENTS Not permitted since a blank endorsement may change policy provisions without the proper Acknowledged approval by this Department. An exception may be made for a blank form if its usage is apparent based on the title/language of the form itself (such as a change in address form). Forms containing check boxes with a space for language to be added are considered blank endorsements and are subject to these rules.

2 of 6 PIM (08/2018) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES REVIEW STANDARDS FOR PERSONAL INLAND MARINE

REVIEW REFERENCE DESCRIPTION OF REVIEW STANDARDS REQUIREMENTS LOCATION REQUIREMENTS OF STANDARD IN FILING CANCELLATION & NON- §3425 Please refer to Compliance Questionnaire No. PLCNR for detailed cancellation and Acknowledged RENEWAL nonrenewal requirements: Personal Lines (other than auto) Cancellation and Nonrenewal Form Filing Compliance Questionnaire plcnr.doc (Word Format) plcnr.pdf (PDF Format) Notice of Cancellation §3425(b), (c), & (h) The notice of cancellation must include a specific reason or reasons of such cancellation Acknowledged and must be sent to the named insured at the address shown in the policy. Please refer to Item I.A of Compliance Questionnaire No. PLCNR. Notice of Non Renewal §3425(d) The nonrenewal provisions must comply with statutory time frame for giving notice and Acknowledged must be sent to the named insured at the address shown in the policy. Please refer to Item I.B of Compliance Questionnaire No. PLCNR. Required Policy Period §3425(a)(7) & (q) Three year unless compliance with statutory reasons. Acknowledged Permissible Reasons for §3425(b) & (c) A policy may be cancelled for any valid underwriting reason during the first 60 days a Acknowledged Cancellation policy is in force. After the first 60 days, reasons for cancellation are limited to statutory references. The reason for cancellation must be specifically listed in notice. Permissible Reasons for §3425(d) & (e) A valid underwriting reason must be specifically listed in notice. Acknowledged Non Renewal Conditional Renewal §3425(d) A conditional renewal notice is required for any change in the policy less favorable to the Acknowledged policyholder. Please refer to Item II.B of Compliance Questionnaire No. PLCNR. DEFINITIONS §1113(a)(20) & §2310(b) & If a particular class or type of insurance cannot reasonably be categorized within the Acknowledged (c) Nation-Wide Marine Definition or Section 1113(a)(20) of the Insurance Law, it should not CL 22 (2000) be classified as inland marine. Please refer to Circular Letter No. 22 (2000). Inland Marine Definition Pertains to the insuring of property in transit over land; the insuring of property which is Acknowledged mobile by nature and for which there is no fixed sites; and the insuring of property which are instruments of communication or transportation such as bridges, tunnels, piers or television antennas Nation-Wide Marine The Nation-Wide Marine Definition as adopted by the National Association of Insurance N/A Definition Commissioners, describes the kinds of risks and coverages which may be classified or identified as marine, inland marine or transportation insurance. New York adopted, with exceptions, the 1976 version of the nationwide definition. Ocean Marine Definition Insurance covering damage to ships or vessels and the goods they carry while on the N/A ocean or inland waters. FORMS MISCELLANEOUS §3407(a) All Property and Casualty insurance policies must contain a provision equal or more Acknowledged favorable to the provisions of §3407(a) Numbered Forms §2307(b) All policy forms and endorsements filed with the Department must include an identification Acknowledged number.

3 of 6 PIM (08/2018) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES REVIEW STANDARDS FOR PERSONAL INLAND MARINE

REVIEW REFERENCE DESCRIPTION OF REVIEW STANDARDS REQUIREMENTS LOCATION REQUIREMENTS OF STANDARD IN FILING Unlicensed Companies §2307(b) All policy forms and endorsements filed with the Department may only include the names Acknowledged of insurers licensed in the State of New York. LIBERALIZATION CLAUSE LOSS SETTLEMENT Action Against Company OTHER INSURANCE STANDARD PROVISIONS FOR FIRE POLICY FORM FILING SUBROGATION PARTICIPATING POLICIES §4106 A participating policy provision is not required. However, when the provision is included, Acknowledged the board of directors may make reasonable classifications of policies in order to issue payment of dividends. Such classifications must be filed for approval and be fair and not unfairly discriminatory. VOIDANCE §3105 & §3106 May not void a policy unless the misrepresentation is material. No misrepresentation Acknowledged shall be deemed material unless knowledge by the insurer of the facts misrepresented would have led to a refusal by the insurer to make such contract. . WARRANTIES §3106 A breach of warranty shall not void a policy unless the breach of warranty is material. Acknowledged RATES & RATING §2304 & §2344 All rates, rating plans, and rating rules filings must be submitted in accordance with the Form/Page/Para 11NYCRR161 (Reg. 129) instructions of Supplement No. 4 to Circular Letter 11 (1998) which outlines the new Reference PLANS Supplement No 4 to CL 11 (1998) mandatory filing procedures effective September 16, 2002. These procedures contain the minimum required information that must accompany all rate, rating plan, and rating rule filings. Rate filings must include appropriate supporting information as outlined in the Rate Filing Sequence Checklist. Please note the relevant requirements contained in Section 2304 of the New York Insurance Law. Please refer to the following web site for additional information: https://www.dfs.ny.gov/insurance/serff_main.htm#Section_II ADOPTIONS OF RATE SERVICE ORGANIZATIONS (RSO) FILINGS

4 of 6 PIM (08/2018) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES REVIEW STANDARDS FOR PERSONAL INLAND MARINE

REVIEW REFERENCE DESCRIPTION OF REVIEW STANDARDS REQUIREMENTS LOCATION REQUIREMENTS OF STANDARD IN FILING Me Too Filings §2306 The insurer may discharge its rate filing obligation by giving notice that it uses rates and N/A 11 NYCRR 161.7 rate information prepared by a designated rate service organization. Please refer to (Reg. 129) Regulation 129 for the filing of rates and the relation and role of rates published by a rate service organization and the Department’s web site for additional filing information: https://www.dfs.ny.gov/insurance/serff_main.htm#Section_II CONSENT-TO-RATE §2309 The application for an excess rate is subject to prior approval. In addition, the application N/A must include the insured's reasons and the application must be signed by the insured. PRICING §2304 & §2344 The following web site contains the mandatory filing procedures: N/A 11NYCRR161 (Reg. 129) https://www.dfs.ny.gov/insurance/serff_main.htm#Section_II CL 19 (1992) & CL 4 (1996) Minimum Premium Rules Minimum Premium Rules- the submission should evidence the relationship between the Acknowledged amount charged as a minimum premium and the costs associated with producing the policy or coverage. Return Premium/Minimum Earned Premium Rules - the submission should specify that the policy will be pro-rated or short-rated due to mid-term termination of the policy. Premium may be considered fully earned only for policies insuring special events that are only a few days in length. Multi Tiering Eligibility requirements for each tier must be submitted. The tier eligibility requirements N/A must be specific and mutually exclusive, so that no insured would be eligible for more than one tier. The rate effects of the tier eligibility requirements should not be duplicated in any rating plans. Justification must be provided for the rate differential for each tier. Payment Plans Payment plans are outside of the rating structure, and do not have to be filed with the Acknowledged Department or included as part of the manual rates. Service Charges Late payment fees, reinstatement fees, and premium installment fees are to be classified Acknowledged as service fees that are outside of the rating structure, and do not have to be filed with the Department or included as part of the manual rates. RATING PLAN §2344 Rating plans are subject to prior approval. Even if the insurer is adopting a rating plan Acknowledged REQUIREMENTS 11NYCRR161.8 (Reg. from a Rate Service Organization (RSO) without modification, such plan is subject to the 129) prior approval requirements. Expense Reduction Plan The minimum basic limits premium is $10,000. In addition, an Expense Reduction Plan Acknowledged may :(1) permit only expense reductions that can be demonstrated;(2) provide for the proper documentation by the insurer of all such expense reductions;(3) not provide for reduction in the insured's premium based upon a reduction in the otherwise applicable commission payable to the agent or broker, unless made part of the insurer's filed and approved expense reduction plan and such reductions are applied in a fair and nondiscriminatory manner to all eligible classes of risk; and(4) not provide for modification of rates in excess of minus (-) 15 percent.

5 of 6 PIM (08/2018) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES REVIEW STANDARDS FOR PERSONAL INLAND MARINE

REVIEW REFERENCE DESCRIPTION OF REVIEW STANDARDS REQUIREMENTS LOCATION REQUIREMENTS OF STANDARD IN FILING RATE/LOSS COST SUPPORTING INFORMATION Actuarial or other Rate 11NYCRR161 (Reg. 129) Rate making and supporting information for rates, rating plans, and rating rules must be Acknowledged Support CL 19 (1992) organized into exhibits, which follow a sequential numbering system. The Rate Filing Supplement No 4 to CL 11 (1998) Sequence Checklist and the related instructions prescribe the required format used to support rate, rating plan, and rating rule filings.

Rate Filing Sequence Checklist newrate.doc (Word Format) newrate.pdf (PDF Format)

Instructions for Rate Filing Sequence Checklist instr.doc (Word Format) instr.pdf (PDF Format)

6 of 6 PIM (08/2018) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES PERSONAL LINES (OTHER THAN AUTO) CANCELLATION AND NONRENEWAL FORM FILING COMPLIANCE QUESTIONNAIRE

COMPANY Zurich American Insurance Company Co. File No. 42615 Company Contact: Paula Bartell Phone Number: 847-605-6177 E-Mail Address: [email protected]

Instructions: All applicable items must be answered. Responses in the shaded area indicate non- compliance with Section 3425 of the Insurance Law. Form, page and paragraph references that bring the submission into compliance must be included. Failure to complete all items, or responses in the shaded area, will result in this filing being returned without further review.

I. CANCELLATIONS a. If cancellation occurs during the first 60 days, the policy should specify a reasonable time frame for giving notice of cancellation. YES NO

b. After the first 60 days, cancellation is permitted only for reasons stated in §3425(c)(2). The policy should specify a reasonable time frame for giving notice of cancellation. YES NO

c. Payment to the insurer or an authorized agent or broker shall be considered timely if made within 15 days after the mailing to the insured of a notice of cancellation for nonpayment of premium. YES NO

II. NONRENEWAL/CONDITIONAL RENEWALS

a. Notice must give a minimum of 45 and maximum of 60 days notice YES NO

b. Conditional Renewal notice must be sent in the event of:

1. Change of Limits YES NO

2. Elimination of any coverage YES NO

c. If change of limits or elimination of any coverage is in lieu of policy cancellation, at least 20 days notice must be given. YES NO

NOTE: All citations in Brackets are to the applicable Section 3425 of the Insurance Law.

Form Number: PLCNR (Ed.08/2018)

Policy Changes – New York

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) ☐ Name of Pet ☐ Name(s) of Pet ☐ Phone Number, Email or Mailing Address of Pet Owner Deleted Cells Owner(s) Deleted Cells ☐ Name of Pet ☐ Company ☐ Policy Number ☐ Policy Period ☐ Limit Deleted Cells ☐ Copayment ☐ 0% ☐ 10% ☐ 20% ☐ 30% Deleted Cells ☐ Limit ☐ $4,000 ☐ $8,000 ☐ $15,0 ☐ Unlimite 00 d ☐ Policy Number ☐ Discount Deleted Cells ☐ Copayment ☐ Deductible( ☐ $0 ☐ $100 ☐ $250 ☐ $50 ☐ $750 Deleted Cells s) 0 Inserted Cells ☐ Premium ☐ Wellness ☐ Add Wellness Coverage ☐ Remove Wellness Endorseme Coverage Inserted Cells nt(s) Inserted Cells ☐ Waiting Period ☐ Other Inserted Cells

Inserted Cells Inserted Cells Inserted Cells Inserted Cells Inserted Cells Inserted Cells Inserted Cells Inserted Cells Deleted Cells Deleted Cells

U-PETZ-0102-A NY (07/19) Page 1 of 2 Includes copyrighted material of Insurance Services Office, Inc., with its permission.

CHANGES

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

U-PETZ-0102-A NY (07/19) Page 2 of 2 Includes copyrighted material of Insurance Services Office, Inc., with its permission.

New York Amendatory

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

I. SECTION III. PREMIUM PAYMENT, Subparagraph C. is replaced with the following: C. If there is a change in premium based upon a mid-term Policy change You requested, the change in premium, as specified on either the Declarations Page or the Policy Changes endorsement, revised premium will take effect on the first of the month following the Policy change Waiting Period. The Waiting Period for a mid-term policy change is specified on the Declarations Page. II. SECTION V. DEFINITIONS, Subparagraph X. is replaced with the following: 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.

III. Section VI. CONDITIONS, Paragraph C. Cancellation, Nonrenewal and Renewal, is replaced with the following: 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 or last known address. Proof of mailing or delivery of notice will be sufficient proof of notice. 3. The cancellation will be effective as of the date shown on the Cancellation Notice, but: (a) not less than 15 days after mailing or delivery of this notice if We cancel for nonpayment of premium; or (b) not less than 30 days nor more than 120 days after mailing or delivery of this notice if We cancel for any other reason. 4. 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. 5. Nonrenewal. We may elect not to renew this Policy. We may do so by delivering to You written notice at least 45 days, but not more than 60 days before the expiration date of this Policy. Proof of mailing will be sufficient proof of notice. 6. 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. IV. Section VI. CONDITIONS, Paragraph D. Changes in Policy, is replaced with the following: 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

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

Page or the Policy Changes endorsement. Certain changes made at Your request 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.

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

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

NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES Rate Filing Sequence Checklist Insurer Name: Insurer File No.:

TOI: Sub-TOI:

Exhibit Name Exhibit Description Included Exhibits (all must be checked yes or no) Master List of Compliance Checklists Exhibit STM-1 YES NO (Not a speed-to-market filing) PDF Rate and/or Rating Plan Compliance Exhibit STM-2 YES NO (Not a speed-to-market filing) Certification PDF Supplemental Explanatory YES NO (General filing information on Transmittal Exhibit RF-1 Memorandum Document is complete) Exhibit RF-2 Actuarial Memorandum YES NO (Filing contains no actuarial data) YES NO (Filing pertains only to rating plans as defined by Exhibit RF-3 Expenses Section 161.1 of Regulation 129) Exhibit RF-4 Investment Income YES NO (Exhibit RF-3 not required) YES NO (Filing pertains only to rating plans as defined by Exhibit RT-1 Side-By-Side Comparison Section 161.1 of Regulation 129) Exhibit RT-2 Policyholder Rate Level Changes YES NO (No existing policyholders for this program) Exhibit RT-3 Policyholder Counts YES NO (No existing policyholders for this program) Exhibit RT-4 Insurer & Program Information YES NO (Exempt per detailed instructions) Exhibit RT-5 Flex-Rating Information YES NO (Filing not subject to flex-rating) Exhibit RSO-1 Rate Service Organization Adoptions YES NO (Independent rates or no RSO adoption) Exhibit RSO-2 Loss Cost Modification Support YES NO (Filing does not contain loss costs) YES NO (Filing support is based exclusively on judgment Exhibit EXP-1 Overall Rate Indications and/or competition) Exhibit EXP-2 Earned Premium Adjustments YES NO (Exhibit EXP-1 not required) Exhibit EXP-3 Incurred Loss Adjustments YES NO (Exhibit EXP-1 not required) Exhibit EXP-4 Credibility YES NO (Exhibit EXP-1 not required) Exhibit EXP-5 Class & Territory Indications YES NO (Exhibit EXP-1 not required) Rating Factor, Debit, Credit or Other Exhibit EXP-6 YES NO (Exhibit EXP-1 not required) Rating Charge Indications YES NO (Filing does not propose or modify a multi-tier Exhibit SUPP-1 Multi-Tier Programs program) Personal Lines Catastrophe YES NO (Filing is not a personal lines property filing or no Exhibit SUPP-2 Reinsurance Loads catastrophe reinsurance load applies) Homeowners Catastrophe & Hurricane YES NO (Filing does not propose or modify homeowners Exhibit SUPP-3 Deductibles catastrophe or hurricane deductibles) YES NO (Filing support is based exclusively on experience Exhibit JDG-1 Explanation of Key Areas of Judgment and/or competition) Exhibit JDG-2 Raw Loss Experience YES NO (No NY experience to provide) YES NO (Filing support is based exclusively on experience Exhibit CMP-1 Company Analysis and/or judgment) Exhibit CMP-2 Base Rate & Rating Factor Comparison YES NO (Exhibit CMP-1 does not apply) Exhibit CMP-3 Rate Analysis YES NO (Exhibit CMP-1 does not apply) Exhibit CMP-4 Raw Loss Experience YES NO (No NY experience to provide) YES NO (Filing does not include rating plans as defined by Exhibit RP-1 Rating Plans Section 161.1 of Regulation 129) YES NO (Filing does not include Experience, Retrospective Exhibit RP-2 Rating Plan Expected Loss Ratios or Composite Rating Plans of an RSO) Supplemental Experience Rating Plan YES NO (Filing does not include an independent Exhibit RP-3 Requirements Experience Rating Plan) YES NO (Filing only includes rating plans as defined by Exhibit MRP-1 Manual Rate Pages Section 161.1 of Regulation 129)

Form Number NEWRATE (Ed. 03/2009) Exhibit RF-2 Zurich American Insurance Company Pet Insurance Program

Actuarial Memorandum New York

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 permissible 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. Exhibit RF-3 Zurich North America Inland Marine New York

Calculation of Expected Loss Ratio

(1) Commissions 23.0% (2) Taxes, Licenses, and Fees 2.5% (3) General Expenses 1.9% (4) Other Acquisition Expense 3.2% (5) Profit/Contingency incl. Investment Income 4.5% (6) TOTAL 35.2%

(7) Loss + All Loss Adjustment 64.8% Exhibit RF-3 Zurich North America Inland Marine New York

Determination of Expense Provisions

(1) (2) (3) (4) (5) (6) (7) 3-Year Expense Item Source 2014 2015 2016 2017 2018 Average Selected

General IEE (% of Earned Prem) 3.8% 1.4% 1.5% 1.7% 2.6% 1.9% 1.9%

Other Acquisition IEE (% of Written Prem) 5.7% 3.2% 3.3% 3.4% 3.0% 3.2% 3.2%

Commissions Selected Rate 23.0%

Taxes, Licenses, Fees 2.5% Calculation of the Profit & Contingency Provision - Inland Marine Exhibit RF-4

Year: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 (1) Written Premium 10,000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (2) Change in UEP 5,000 (5,000) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (3) Earned Premium 5,000 5,000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (4) Losses & LAE Paid 1,802 2,895 1,266 346 173 0 0 0 0 0 0 0 0 0 0 0 0 (5) Chg in Loss Reserve 1,438 346 (1,266) (346) (173) 0 0 0 0 0 0 0 0 0 0 0 0 (6) Losses Incurred 3,241 3,241 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (7) Expenses Paid 768 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (8) Res. Mkt Assmnt Pd 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (9) Commissions Paid 2,300 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (10) Underwriting Income (1,309) 1,759 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (11) Investment Income 123 186 72 13 3 0 0 0 0 0 0 0 0 0 0 0 0 (12) Policyholder Div Reserve 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (13) P-H Dividends Paid 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (14) Federal Income Tax (35) 200 12 2 0 0 0 0 0 0 0 0 0 0 0 0 0 (15) Operating Income (1,151) 1,745 61 12 3 0 0 0 0 0 0 0 0 0 0 0 0 Liabilities (16) UE Prem Reserve 5,000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (17) Loss & LAE Reserve 1,438 1,784 519 173 0 0 0 0 0 0 0 0 0 0 0 0 0 (18) Surplus 2,667 2,815 223 74 0 0 0 0 0 0 0 0 0 0 0 0 0 (19) Total Liabilities 9,105 4,600 742 247 0 0 0 0 0 0 0 0 0 0 0 0 0 (20) Tax Basis Reserve 1,420 1,760 512 172 0 0 0 0 0 0 0 0 0 0 0 0 0 (21) Change in Surplus 2,667 149 (2,592) (149) (74) 0 0 0 0 0 0 0 0 0 0 0 0 (22a) Excess Cash Flow (3,818) 1,597 2,653 161 77 0 0 0 0 0 0 0 0 0 0 0 0 (22b) Internal ROR 10.00%

(23) Prem Earning Pattern .5000 .5000 (24) Prem Coll. Pattern 1.0000 .0000 .0000 .0000 .0000 .0000 .0000 .0000 .0000 .0000 (25) Loss_Payout_Pattern .5561 .3372 .0533 .0533 .0000 .0000 .0000 .0000 .0000 .0000 .0000 .0000 .0000 .0000 .0000 .0000

(26) Loss/LAE Ratio: 64.82% (27) Expense Ratio: 7.68% (34) Indicated Profit/Contingency Provision 4.5% (28) Commission Ratio: 23.00% (28.1) Residual Mkt Load: 0.00% (29) Dividend Ratio: 0.00% (30a) Invest Rate on Reserves: 2.71% (30b) Invest Rate on Surplus: 2.71% (31a) Reserve/Surplus 2.32 (31b) Premium/Surplus 2.44 (32) Discount Rate: 1.56% (33) Tax Rate: 21.00% Zurich North America Inland Marine Calculation of the Profit & Contingency Provision

Explanatory Memorandum for Exhibit RF-4

The purpose of this document is to describe the method used to calculate a profit and contingency factor as shown in the ROE exhibit(s).

The approach relies on a simulation of cash flows for a specific type of business. The internal rate of return (IRR) for these cash flows is equal to the target return on equity (ROE). Using a trial and error process, the permissible loss and all loss adjustment ratio is varied until the target ROE is reached. Given the loss and loss adjustment ratio which produces the target ROE, the profit/contingency factor is then determined (profit/contingency = 100% - (Loss + LAE) - Underwriting Expenses).

Key assumptions used in the calculations are as follows: * Target ROE for all LOB is: 10.0% * All premium is collected at policy inception. * Expenses are paid at policy inception (production, general, taxes, licenses & fees).

* Losses paid and loss reserves are set according to selected payment pattern for specific line of business. *All sources of investment income including surplus are reflected.

* The investment rate for reserves (policyholder dividend reserves, UEPR, and loss and LAE reserves) and surplus is the most current normalized swap rate with applicable maturity to the selected line of business: Current normalized swap rate with a two-year maturity. *One dollar of surplus is committed for each $2.32 of loss and LAE reserves for this line of business. One dollar of surplus is committed for each $2.44 of earned premium for this line of business. * Federal Income Tax is charged against investment income, underwriting income, 20% of the change in the unearned premium reserve and the change in the reserve discount—a 21% tax rate applies in all instances. * The 2018 IRS rate -- 1.56% -- was used to discount reserves. * The IRR is determined by "Excess Cash Flows" which equal Operating Income + Change in Surplus.

A more detailed explanation on each line of the calculations is provided below:

1. Written Premium: Annual written premium.

2. Change in UEP: Change in unearned premium reserve assuming even distribution of writings through the year.

3. Earned Premium: Calculated by assuming an even distribution of writings.

4. Loss & LAE Paid: Loss & LAE Paid: [Prior Year Loss & LAE + Line (3) * Line (25) * Line (26)]

5. Change in Loss Reserve: Line (6) - Line (4).

6. Losses Incurred: Line (3) x Line (26).

7. Expenses Paid: Line (1) x Line (27). 8. Residual Market Assessment Paid: Does not apply.

9. Commissions Paid: Line (1) x Line (28).

10. Underwriting Income: Line (3) - Line (6) - Line (7) - Line (8) - Line (9).

11. Investment Income: {Average of Lines (12), (16), and (17) for current & prior year} x Line (30a) +{Average of Line (18) for current & prior year} x Line (30b).

12. Policyholder Dividends Reserve: Not Applicable.

13. Policyholder Dividends Paid: Not Applicable.

14. Federal Income Tax: 0.21 x {{Line (5) - [Change in Line (20)] + [0.20 x Line (2)] + Line (10) + Line(11)} - {Change in Line (12)} - Line (13)}.

15. Operating Income: Line (10) + Line (11) - [Change in Line (12)] - Line (13) - Line (14).

16. Unearned Premium Reserve: 50% of written premium for the year (assumes premiums are written equally throughout the year).

17. Loss & LAE Reserve: Inception-to-date total of Line (5).

18. Surplus: {Line (17) / Line (31a) + Line (3) / Line (31b)}.

19. Total Liabilities (including Surplus): Line (12) + Line (16) + Line (17) + Line (18).

20. Tax Basis Reserve: Future paid losses discounted by the rate in Line (32).

21. Change in Surplus: Change in Line (18) from prior year.

22a. Excess Cash Flow: Line (15) - Line (21).

22b. Internal Rate Of Return: Rate which causes the net present value of the cash flows in Line (22a) to be equal to 0.

23. Premium Earning Pattern: Assumes that 50% of written premiums are earned in the first year and 50% in the following year.

24. Premium Collection Pattern: Assumes that all premiums are collected in the year written.

25. Loss Payout Pattern: loss payment patterns based on company data are assumed.

26. Loss & LAE Ratio: Adjusted until target IRR is achieved.

27. Expense Ratio: Provision for general, other acquisition and premium taxes.

28. Commission Ratio: Provision for commissions.

29. Dividend Ratio: Not Applicable.

30a. Investment Rate on Reserves: Pretax return for duration matched swap rate.

30b. Investment Rate on Surplus: Pretax return for duration matched swap rate. 31a. Reserve-to-Surplus Ratio: Reflects amount of surplus committed to reserves based on historical company averages.

31b. Premium-to-Surplus Ratio: Reflects amount of surplus committed to premium based on historical company averages.

32. Discount Rate: Current IRS discount rate.

33. Tax Rate: Current IRS corporate tax rate.

34. Indicated Profit/Contingency Provision: 100% - Line (26) - Line (27) - Line (28) – Line (28.1) – Line (29). Exhibit RT-4

Zurich North America Pet Insurance Insurer and Program Exhibit

Zurich American Insurance Company is submitting a filing for our new Pet Illness and Injury Policy and Veterinary Wellness Endorsement, intended to provide the reimbursement for reasonable and necessary veterinary expenses incurred due to the pet’s illness, injury and preventative medicine treatment.

This is a new product for Zurich. It fits with Zurich’s overall business plan to expand relationships with existing program administrators. Each of our programs could be considered a specialty or niche market. We plan to market this program in the continental United States through a program administrator and our prospective outlook for this program is favorable. Claims will be managed by a TPA with oversight provided by Zurich.

There is no reinsurance associated with the program at this time. This program does not specifically provide for under-served or substandard risks.

We estimate that the written premium for New York will be about $100,000 this year and about $1,000,000 next year. As this is a new rating plan, there are no previous filings. Zurich’s approximate market share for the pet insurance market will be less than 1%. Zurich’s approximate market share for this line of insurance is 3%. Exhibit CMP-1

Zurich North America Pet Insurance Company Analysis

Zurich American Insurance Company is submitting a filing for our new Pet Illness and Injury Policy (U-PETZ-0100-A) and Pet Wellness Endorsement (U-PETZ-0101-A), intended to provide the reimbursement for reasonable and necessary veterinary expenses incurred due to the pet’s illness, injury and preventative medicine treatment.

The proposed rating plan utilizes a combination of the rating plans currently filed and used by National Casualty Company (NCC) and Indemnity Insurance Company of North America (IICNA). The majority of the factors in this filing are based on NCC. The exception is the territory factors, which are based on IICNA.

We have chosen to base our filing on those of NCC and IICNA as they are both market leaders for these types of products. NCC’s VBW-I and VB-II products provide coverages that are closely associated with the coverages we are offering. IICNA was selected to supplement the NCC filings to reflect expected cost differences by territory.

The major coverage provisions of the company and the competitor(s).

The major coverage provisions of the Zurich Pet Illness and Injury Policy and Pet Wellness Endorsement are directly comparable to those provided by NCC. Our coverage is based on the NCC’s VS-G-13 (VBW-I) and VS-G-14 (VB-II) forms.

Major Provisions NCC Zurich Pet Illness & Injury Yes Yes Examination Yes Yes Prescribed Behavioral Training, Therapy or Treatment Yes Yes Prescribed Drugs Yes Yes Prescribed Nutritional Supplements Yes Yes Prescribed Pet Food Yes Yes Preventative treatment Yes-VBW-I Yes-Endorsement Hip Dysplasia / Cruciate Ligament Yes After 12-Months Mortality Benefit Yes Yes Boarding or Kennel Fees Yes No Advertising or Reward Yes No Loss due to Theft or Straying Yes No

The NCC products provide a $7,500 policy limit, deductible options ($0, $100, $250), reimbursement options (70%, 80%, 90%) and an optional $500 sublimit for preventative care (VBW-II only).

Exhibit CMP-1

The Zurich product provides policy limit options ($4,000, $8,000, $15,000, unlimited), deductible options ($0, $100, $250, $500, $750), reimbursement options (70%, 80%, 90%, 100%) and a $750 sublimit for preventative care (wellness endorsement).

The agency distribution system of the company and the competitor(s)

Zurich will market the program through two different channels: Website - direct-to-consumer online platform and Worksite - employer benefit programs.

Similar options are also utilized by NCC and IICNA.

The target market of the company and the competitor(s).

Our target market will be dog and cat owners, similar to IICNA. In addition to this, some of NCC’s products are also available for exotic pets.

The market share of the competitor(s) for the classes of business in which the company will focus its writings.

Nationwide’s (NCC) market share for pet insurance is currently ~36%. Chubb’s (IICNA) market share for pet insurance is currently ~12%.

The date and Department File Number in which the rates for each competitor were approved/acknowledged for use in New York State.

The proposed rates are based on those currently filed and used by NCC. The rates were approved on 7/17/2018, Department File # R2018001434. Factors for age and breed come from Department File # R2017000685, approved on 5/16/2017.

The proposed territory factors are based on factors currently filed and used by IICNA. They were approved on 3/8/18, Department File # R2017004087.

Exhibit CMP-2

Comparison to National Casualty Company

Zurich’s total expense provision of 35.2% is very similar to Nationwide’s provision of 35.8%.

The following tables compare the proposed rating plan with the rating plan for Nationwide’s VB-II and VBW-I products. While the proposed rating plan is related to Nationwide’s plan, they are not identical.

Zurich Nationwide

Form Rate Form Rate Accident & Illness Policy 831.26 VB-II 846.72 Wellness Endorsement 412.45 Total 1,243.71 VBW-I 1,415.52

Species Factor Species Factor Canine 0.64 Canine 1.00 Feline 0.43 Feline 0.60

Breed Group Factor Not used for VBW-I / VB-II, identical to POI A 1.00 B 1.13 C 1.47 D 1.93 X1 0.99 X2 1.25 A2 1.00 B2 1.72

Age Canine Feline Not used for VBW-I / VB-II, identical to POI 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

Exhibit CMP-2

Zurich Nationwide

Territory Factor Not used for VBW-I / VB-II, based on IICNA 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

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

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

Limit Factor Not used for VBW-I / VB-II, $7,500 limit $4,000 0.90 $8,000 1.00 $15,000 1.10 Unlimited 1.30 up to a 15% discount up to a 20% discount

Exhibit CMP-3

Zurich North America Pet Insurance - Rate Analysis

The proposed rates were developed by using the base rates and projected loss ratios for Nationwide’s (NCC) VBW-I and VB-II products. The base rates were adjusted to reflect differences in trend, expenses and coverage. The derivation of the base rates can be found in Exhibit 1. The rating plan also introduces factors for breed, age and territory. Breed and age factors were taken from the rating plan from another Nationwide product (POI). Nationwide’s species factor were adjusted by the average age and breed factors to ensure that this change was revenue-neutral.

The following table compares our proposed rates with those of NCC:

Zurich Nationwide Differences Species Policy Endorsement Total VB-II VBW-I VB-II ¹ VBW-I ² Canine Base Rate 831.26 412.45 846.72 1,415.52 Avg. Territory Factor 1.08 1.08 1.00 1.00 Avg. Age Factor 1.17 1.17 1.00 1.00 Avg. Breed Factor 1.35 1.35 1.00 1.00 Species Factor 0.64 0.64 1.00 1.00 904.03 448.56 1,352.58 846.72 1,415.52 6.8% -4.4% Feline Base Rate 831.26 412.45 846.72 1,415.52 Avg. Territory Factor 1.08 1.08 1.00 1.00 Avg. Age Factor 1.19 1.19 1.00 1.00 Avg. Breed Factor 1.17 1.17 1.00 1.00 Species Factor 0.43 0.43 0.60 0.60 534.37 265.14 799.51 508.03 849.31 5.2% -5.9%

¹ Compared to Zurich's base policy ² Compared to the total for Zurich's base policy and endorsement

Territory factors were developed by using another carrier, IICNA. IICNA’s territories are defined by zip code. Our proposed territories are defined by county to smooth out some of the differences seen in neighboring zip codes. The proposed factor for each county was determined by using a weighted average of the zip code factors within the county. Similar to the species factors, the base rates include an adjustment to reflect the average territory factor.

Zurich American Insurance Company Pet Insurance Program

New York Exhibit 1 - Base Rate Development

VBW-I VB-II Notes Nationwide a Projected Loss Ratio 77.9% 85.1% From SCTT-131476422 b Filed Rate Change 20.0% 20.0% From SCTT-131476422 c Revised Loss Ratio 64.9% 70.9% a / (1 + b) d Average Accident Date 6/21/2019 6/21/2019 From SCTT-131476422 e Annual Loss Ratio Trend 6.0% 11.3% From SCTT-131476422

Zurich f Average Accident Date 7/1/2020 7/1/2020 g Implied Loss Ratio 68.9% 79.2% c × (1 + e) ^ [(f - d) / 365.25] h Permissible Loss Ratio 64.8% 64.8% From Exhibit A i Base Rate Adjustment 6.4% 22.2% g / h -1

j Current Base Rate 1,415.52 846.72 From SCTT-131476422 k Base Rate Adjustment 6.4% 22.2% i l Coverage Differences -7.9% -13.1% From Exhibit 2 m Off-Balance -7.5% -7.5% From Exhibit 3 n Implied Base Rate 1,282.18 831.26 j × (1 + k) × (1 + l) × (1 + m)

o Pet Illness and Injury Policy (U-PETZ-0100-A) 831.26 n (VB-II)

p Pet Wellness Endorsement (no sublimit) 450.92 n (VBW-I) - n (VB-II) q Impact of $750 Sublimit 38.47 From Exhibit 4 r Pet Wellness Endorsement U-PETZ-0101-A ($750 sublimit) 412.45 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

New York Exhibit 3 - Off-Balance Factors

Territory Factor Distribution A 0.85 0.0% B 0.90 0.0% C 0.95 0.0% D 1.00 19.0% E 1.05 28.6% F 1.10 39.3% G 1.15 4.7% H 1.20 0.0% I 1.25 8.4% J 1.30 0.0% K 1.35 0.0% L 1.40 0.0% M 1.45 0.0% N 1.50 0.0% 1.08 100.0%

Adjustment: -7.5% = 1 / 1.08 - 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: 1,282.18 Exhibit 1: o + p With $750 Wellness Sublimit - 3% credit on total premium: 1,243.71 = .97 × 1,282.18 Total premium reduction: 38.47 = 1,282.18 - 1,243.71 Fraud Page Statement NY - DRAFT Contact us

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Marley's cover Hide breakdown $92.00

Accident & Illness $32.00 Limit ($8,000) Co-pay (10%) Deductible ($250)

New Customer Enrollment Fee $30.00

Wellness cover $30.00

Lulu’s cover Show breakdown $72.00

Subtotal for all pets $164.00

5% discount (MultiPaw) -$8.20

Installment Fee $1.00

Multipaw Policy total $157.80 a month

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The information entered on this electronic enrollment (including the consent above) is accurate. I agree to submit my enrollment electronically and understand that my electronic signature on these materials is binding. I understand and agree, that the payment method used at enrollment will be via Marsh’s auto pay system and will be used for the initial enrollment payment and recurring billing (renewal of the policy, midterm policy change endorsements, and annual premium true-up). Any person who knowingly and with intent to defraud any insurance company or other person files an application for insurance or statement of claim containing any materially false information, or conceals for the purpose of misleading, information concerning any fact material thereto, commits a fraudulent insurance act, which is a crime and shall also be subject to a civil penalty not to exceed five thousand dollars and the stated value of the claim for each such violation.

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Copyright © 2019 Trusted Pals LLC. All rights reserved. Insurance provided by Trusted Pals, Address here, City, State 00000. Trusted Pals is acting as the agent of Marsh Inc. in selling this insurance policy. It receives compensation based on the premiums for the insurance policies it sells. Further Velocity logo information is available upon request. Pet Illness and Injury Insurance Application

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U-PETZ 0103 A CW 07/19 U-PETZ 0103 A CW 07/19 U-PETZ 0103 A CW 07/19 Contact us

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Marley's cover Hide breakdown $92.00

Accident & Illness $32.00 Limit ($8,000) Co-pay (10%) Deductible ($250)

Policy admin fee $30.00

Wellness cover $30.00

Lulu’s cover Show breakdown $72.00

Subtotal for all pets $164.00

5% discount (MultiPaw) -$8.20

Credit card fee $2.00

Multipaw Policy total $157.80 a month

We'll support pets in need

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New York Amendatory

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

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

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

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

SERFF Tracking #: ZURC-132063298 State Tracking #: R2019003049 Company Tracking #: 42615

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) 08/27/2019 Form New York Amendatory 09/12/2019 U-PETZ-0105-A NY 0719.pdf (Superceded)

PDF Pipeline for SERFF Tracking Number ZURC-132063298 Generated 09/19/2019 12:24 PM