California insurance commissioner Ricardo Lara issued a Bulletin December 21, 2023 to all property and casualty insurers subject to the provisions of Proposition 103, namely personal auto insurance companies. The Bulletin is in response to complaints received by the insurance department on the use of waiting periods, questionnaires, and other practices that may be in violation of California law. The use of such methods may act as a barrier to the acceptance of otherwise qualified insureds and are being used to restrict, non-renew, or entirely refuse auto insurance coverage. The bulletin reminds insurers of statutory provisions and requirements, and the possibility of administrative enforcement actions for failure to adhere to such procedures. 

The provisions of Proposition 103 require that insurers publicly file all changes to rates, rating rules, eligibility, renewal, and underwriting guidelines prior to their implementation. Article 10, 1861.05(b) states that, "Every insurer which desires to change any rate shall file a complete rate application with the commissioner." A complete rate application includes all data referred to in selected Sections, and "such other information as the commissioner may require." This includes exhibits, templates, checklists, and questionnaires; meaning an insurer must file for and have approval before implementing these methods. An insurer's failure to file for approval may result in administrative penalties.