Untitled Texas Attorney General Opinion

~TIXF,ATJTOFCNEY GENERAL OFTEXAS AV~TXN 1,. WEXA~ March 25, 1960 Judge Penn J. Jackson, Chalrmaa Opinion No. VW-817 State Board of Insurance InternationaI Life Building Re: Increase in premium Austh 14, Texas rates of sMb-wide mutual asSesameat eompan&s and local mutual aid as~ociatlons. Dear Sir,: We have considered your ~pinlon request of December 16, 1959, which read6 in part as follows: 6. . . .We make this general inquiry aa to the powers and duttes of stats-wtde mutual assessment associations organised and operating under the pro- visions of Chapters 13 and 14 of the Texas hnsnrancc code. “h&y such mutual assessment assoclatlons increase premiums on outstanding policy contracte without the prior or subsequent approval of the State Board of Insurance? “Under a long-established practice, such i,. mutual assessment associations make application to the State Board of Insurance for psrmlssion to increase premiums< The applicants cite Art. 14.23 of the bmar- anca Code as the Board’s authority for granting or ordering these requested increases. The present Board has contlnwd to follow tbLs departmsntal practice ln a few cases.” It Is also the understandihg of this office tit you have limited your request to those mutual companies which collect re ular and psriodlc assossmsnts La accordance with Artlcb’l4.23 o,f the Texas Insursnco Code. ,,: . ,: Mutual assessment insurance companies in Texas have the right to increase their rats6 to the extent that they are r.easonabb and hecrssary+. See Attorney General Opinion O-3367, pp. 5 (1941). Ia the absence of a controlling statute, lncroasos in asses6mento by mutual Insurancci companies 1s a matter which 1s governed by the company’s i~i charter,, by-laws or the insurance contract. See American Jnris., Vol. 29, Set; 571, pp. 8,71. Judge Penn J. Jackson, page 2 (WW-817 ) Chapters 13 and 14 of the Texas Insurance Cads governs mutual assessment companies, and Article 14.23 of the Code per- tains to assessments and rate q chedsles: “Each asaociatlon shall levy regular aad per- iodical assessments by whatever name they may be called. These assessments must be in such amounts and at such proper intervals ,as will meet the reasonable operating expenses of the associa- tion, and pay in full the claims arising under Its certificates. When or if in the course of opera- tion it shall be apparent that the claims cannot be met in full from current assessmtnts and funds w hati the amount must be Lncreastd nntil they are adeq& to meet such claims. and the Board sbab so order. When any association shall refuse to comply with ths Board’s recommendations or reqaire- muto respecting rates of assessment.s, it shall be treated as involve& and shall be dealt with as is hereinafter provided. “Each association operating under the pro- visions of this chapter shall file Its rats scbsduies with the Board of Insurance Commissioners.” (Emphasis Added). On examination, Article 14.23 reveals the State Board of Insur- .:. ante has jurisdiction to order an increase in assessment by an assocla- tion ody in the situation where the present assessment aad the funds on hand are inadequate to pay tho reasonable expenses and claims in full. The only criteria set out by Art. 14.23 as to the required amount of assessment is that it bo sufficient to meet reasonable expenses and pay tho ciaitns in full, and to realize this end the Board shall ordor the association,to iacrease the assossmoat. The association is to bo regarded as insolvent in the event the association rofbses to comply with the order of the Board. Thus, if the association takes the initiative by iacreuing the assessment, the Board is not required to pass on the propriety of this action since the onIy jurisdtctlon given the Board is to order the association to lncrehse the assessment under the particular clrcnuastaucos set out in 14.23. This interprotttion of 14.23 is strelrgthened by the fact that the prtmary purpose of Chapter 14, as revealed by Article 14.29, was to socuro to the members of the mutual rompanbs, the their claims. Prior to theenactment of thii Judge Penn J. Jackson, page 3 (WW- 817 ) assessment associations were able to pay only a percentage of the face value of their policies because the respective assessments were not adequate. To make certain that sufficient funds would be available. the Board was directed to order increases in assessments by the associa- tion when it was determined that the funds would be insufficient to pay the claims In full. In reaching this conclusion, we are not unmindful of the past departmental construction of Article 14.23, but we are of the opinion that Article 14.23 is not doubtful or ambiguous, and in the absence of ambiguity or uncertainty, contrary departmental construction of a statute is not deemed controlling. See 39 Tex. Jur. Sec. 126, pp. 235. Chapters 13 ore 14 do not control the raising of assessment rates except insofar as Article 14.23 directs the Stats Board of Insur- ance to order an assessment increase when the current assessment and funds on hand are inadequate to pay the reasonable expenses and claims. It is ollry in this situation that Article 14.23 confers the res- ponsibility on the State Board of Insurance to order an association to raise its assessments. Otherwise, it is the responsibility of the management of the mutual assessment associations to mako ,rate ln- creases subject to the provisions of their respective charters, by-laws and insurance contracts. SUEJIMARY The State Board of Insurance has jurisdiction under Article 14.23 to order a mutual assessment association to make an assessment increase only where it deter- mines that the proceeds from the current assessment and funds on hand are inadequate to pay reasonable ex- penses and claims; otherwise, mutual assessment asso- ciations may make assessment increases subject to their respective charters, by-laws and insurance con- tracts. Very truly yours, WILL WILSON Attorney Goneral of Texas BY Bob E. Shannon Assistant Attorney Gomaral .. Judge Penn J. Jackson, page 4 (WV-817) APPROVED: OPINION COMMITTEE: W. V. Gappert, Chairman ~William T. Blackburn Fred B. Werkenthh Bob Rowland Larry liargrove REVIEWED FOR THE ATTORNEY GENERAL BY: Leonard Passmore