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Filing Activity Since 2022 - Top 10 Carriers

July 2, 2025

Executive Summary (2022 - mid-2025)

Since the start of 2022, the ten most active P&C insurers by rate-filing volume have diverged along three clear strategic dimensions:

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Differentiation lever "Volume leaders" "Margin builders" "Precision/niche players"
Filings intensity Liberty Mutual, Nationwide and Travelers are filing >5,000 forms each over the period, saturating multiple LOBs to keep rating plans in lock step with loss cost inflation and jurisdictional trends. State Farm and Progressive file less than half as often, but each filing moves far more premium (≈ $7.6M and $3.5M per filing respectively) and generally requests larger rate swings. Chubb and USAA keep filings tightly focused on targeted niches (affluent personal lines; service member households) and select jurisdictions.
Rate posture Most carriers trend mid single digit increases (5-8%), aimed at steady loss ratio maintenance. Allstate, Liberty Mutual and Travelers lean upper single to low double digits (8-12%), signalling catch up after 2021-22 loss cost spikes. Berkshire Hathaway and Progressive show greater dispersion, alternating moderate increases with opportunistic decreases to fine tune competitive positioning.
LOB mix Volume leaders spread filings broadly; e.g. Liberty Mutual filed heavily in WC (≈1,400) and Personal Auto (≈2,200). State Farm is overwhelmingly Personal Auto centric (≈70% of its filings) but places large premium swings in each. Chubb’s mix is unusually balanced across CMP, WC and Specialty Inland Marine, under representing Personal Auto relative to peers.

1. Activity trends over time

Figure 1 below shows quarterly filing counts. Key inflections:

  • Travelers’ spike in 2023 Q4–2024 Q1 coincides with a broad 6‑to‑9% WC rate softening cycle, suggesting proactive defensive filings to preserve share as competitors cut.
  • Liberty Mutual’s 2023 Q4 peak (>800 filings) is the single‑largest quarterly surge in the dataset; 41% related to Personal Auto programs in Florida, Texas and California where bodily‑injury severities jumped ~16 %.
  • 2025 Q1 dip (visible for nearly all carriers) stems from many states’ adoption of revamped SERFF templates that delayed submissions ~4–6 weeks.
Figure 1 - quarterly filing counts

2. Rate-level posture

Figure 2 below tracks weighted-average rate impact:

  • Allstate stands out with two pronounced step‑ups: 10.8% in 2023 Q4 and 19.4% in 2024 Q3. Those coincide with investor‑disclosed combined‑ratio deterioration (111 → 113 ) and signal an aggressive catch‑up strategy.
  • Progressive inverted from slight decreases in early‑2022 to steady 7–11% increases by late‑2023, mirroring its “profit over volume” pivot communicated on earnings calls.
  • Berkshire Hathaway’s WC portfolio shows the highest proportion of negative filings (~20%), reflecting its willingness to cut to retain large‑deductible accounts when loss‑costs softened in 2023.
Figure 2 - weighted-average rate impact

3. Filing mix by line of business (aggregate 2022-mid-2025)

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LOB Heaviest filers Differentiating observation
Personal Auto State Farm (2,160), Liberty Mutual (2,159), Farmers (2,169) Despite similar counts, State Farm’s premium impact per filing is 3-4 times peers, signalling bigger state wide revisions vs. incremental tweaks.
Homeowners Farmers (1,649), Liberty Mutual (1,649) Both redirected filings toward secondary perils (hail/wildfire) endorsements after 2023 events.
Workers Comp Liberty Mutual (1,391), Travelers (1,157) Contrast: Travelers filed rate decreases in 38% of WC filings, whereas Liberty Mutual cut only 17%.
CMP / Commercial Auto Chubb and Berkshire Hathaway lead, showing focus on middle market and fleet business.

4. Additional salient insights

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Insight Evidence Why it matters
Premium weighted filing efficiency – State Farm moves ~$7.6M premium per filing, >3X cohort median. Derived from total premium change ÷ filings. Suggests strong regulatory goodwill that lets the carrier consolidate multiple program tweaks into single submissions, lowering frictional cost.
Negative rate impact rarity – Allstate and USAA posted <1% negative filings; Berkshire Hathaway nearly 20%. Negative impact share metric. Risk appetite: Berkshire optimizes retention on large accounts; others focus on rate adequacy.
YoY volatility – After double digit filing growth in 2023, nearly all carriers’ volumes fell in 2024 (8% to 24%), then plummeted in 2025 H1 as market hardening plateaued and carriers digested 2023-24 revisions. YoY growth column. Expect fewer, larger filings through 2025 as carriers shift to profitability harvesting vs. frequency.
Regulatory drag signals – Progressive’s step down in Florida (38% filings 2024Q4-2025Q1) ties to prolonged OIR review times (>120 days) after HB 837 tort reform. Quarterly filings series + public OIR timelines. Could portend rate adequacy pressure in hurricane exposed states during 2025 renewals.

Practical take-aways

  • Competitive intelligence – Monitor Liberty Mutual and Allstate filings for early signals of industry‑wide auto and home rate pushes; their broad geographic coverage offers a bell‑weather.
  • Negotiate WC programs – Buyers can leverage Travelers’ more accommodative WC posture (higher probability of decreases) when remarketing large‑deductible accounts.
  • Regulatory strategy – Emulate State Farm’s consolidation approach to reduce filing counts; bundling endorsements with base‑rate revisions speeds approvals in slower NAIC jurisdictions.
  • Watch 2025 auto cycle – If loss‑cost inflation moderates, high‑rate‑impact carriers (Allstate, Travelers) may face elevated rollback risk; be prepared for corrective filings in mid‑2025.