NY Reg comment 1.08 Reg. 79 FINAL

January 24, 2008 Buffy Cheung State of New York Insurance Department 25 Beaver Street New York, NY 10004 Re: INS-50-07-00002-P—Mandatory Underwriting Inspection Requirements for Private Passenger Automobiles On behalf of the Professional Insurance Agents of New York, I write in support of this proposed rulemaking. PIANY in general supports every type of liberalization in the current rules. Changes like those proposed in this rulemaking can provide more time and flexibility with which to accommodate the needs of our members’ clients and prevent inadvertent lapses in their physical damage coverage. While in two instances we request clarification from the Department in its adoption notice (see below), we strongly support the initiative of the Insurance Department in proposing changes to improve what we consider to be a burdensome regulation. The regulation, we recognize, is required by law. However, we believe at this point that the physical damage inspection requirement imposed by Section 3411 of the Insurance Law is a rule whose costs far outweigh its benefits at this point—a discussion that is beyond the scope of this proposed rulemaking. Specifically, we believe the change in the tolling of the five-day deferral for the inspection from the current calendar days, to business days, will benefit clients by affording them a longer period of time to have the inspections performed. We also appreciate the proposed language that would ...