July 6th, 2016
Allstate Insurance Group
2775 Sanders Road, Suite A2
Northbrook, IL 60062
RE: State: Ohio
Company: Allstate Fire and Casualty Insurance Company
Line of Insurance: Private Passenger Auto
Company File Number: R26969
Below is our response to the Ohio Department of Insurance inquiry dated June 16, 2016, with respect to
the above captioned filing. The question is restated below in bold font and immediately followed by our
response.
Objection 1
Comments:
Have the terms & conditions document for the original Drivewise program (rule 73) been updated
due to the introduction of the new Drivewise program (rules 81 & 82)? If so, submit a copy of the
terms and conditions.
The terms and conditions document for the original Drivewise® program (rule 73) has not been updated
due to this introduction of the new Drivewise program (rules 81 & 82). The original Drivewise program
was implemented on 8/8/2011 with filing ALSE-127211142 and was subsequently updated on 2/4/2016
with filing ALSE-130434339.
Objection 2
Comments:
Can a policy that currently participates in the original program (rule 73) continue to participate in
the original program when vehicles/drivers are added/removed from the policy or must it transition
to new Drivewise program (rules 81 & 82)? Explain.
A policy that currently participates in the original Drivewise program would not have to transition to the
new Drivewise program (rules 81 & 82) upon adding/removing a vehicle/driver from the policy.
Objection 3
Comments:
If any insured on a policy that currently participates in the original program (rule 73) wishes to
participate in the new program (rules 81 & 82), must the entire policy transition from the old
program (rule 73) to the new program (rules 81 & 82).
Yes, since the new program (rules 81 & 82) is a policy-level program, the transition can only take place if
the entire policy moves to the new program. All insureds are eligible to enroll in the new program and can
enroll by downloading the app.

 Objection 4
Comments:
Explain how a policy that currently participates in the original program (rule 73) will be informed
of the new program (rules 81 & 82)?
Allstate always educates its agents about any product offering changes and encourages agents and
customers to regularly discuss if they may qualify for a new discount or benefit from a new available
product offering. Customers currently in the original Drivewise program (rule 73) who renew after
7/14/2016 can request a transition.
Objection 5
Comments:
Submit the terms and conditions document that is provided to insureds participating in the new
Drivewise program (rules 81 & 82).
Please see Attachment A for the terms and conditions document that is provided to insureds participating
in the new Drivewise program (rules 81 & 82).
Objection 6
Comments:
Compare/contrast the feedback that Allstate provides to the insureds regarding their driving
behavior in the original and the new Drivewise program.
In both the original and the new Drivewise program, Allstate provides driving feedback to customers
regarding performance factors such as their speed, time of day, and braking behavior. However, in the
new Drivewise program, customers can see this driving feedback in real time through the Drivewise
mobile app rather than having to view this performance in My Account or Allstate Mobile.
Some additional features in the Drivewise mobile app include:
Driving feedback after each trip
Insights on driving patterns
Tips on how to stay safe behind the wheel
Plus, some optional tools and services:
In-trip alerts for speeds ≤ 80 MPH and for hard braking events
Automatic text reply when driving (Android only)
Good Hands Rescue: get roadside help fast
Openbay: find a great mechanic when and where it is needed
Parking Reminder: find your way back to your parked car
Objection 7
Comments:
For the new program (rules 81 & 82), will plug-in devices be used to record the driving data or is
driving data only captured by a mobile device?
Under the new program (rules 81 & 82), new enrollees can only participate in the program through the
use of the Drivewise Mobile smartphone application. No plug-in device will be provided. Currently,

 smartphones with Android or iOS are supported. The smartphone currently needs to be running Android
4.4 and iOS 8 or higher to be able to use the Drivewise application.
Objection 8
Comments:
Explain how the earned Performance Reward (Rule 82) process works. Is the reward percentage
applied to the expiring premium amount to determine the reward amount? Do any mid-term policy
changes that affected the premium amount affect the reward amount? How will the owner of the
policy be made aware of the amount of the reward? How does the owner of the policy redeem the
award amount? When can the owner of the policy redeem the award amount? Does the amount
have to be immediately redeemed or can owners keep a reward balance?
If a policyholder qualifies for a Performance Reward as described in Rule 82, the policy level Reward
percentage will be multiplied with the policy premium to determine a Performance Cash Reward. This
performance reward is based on Adjusted Account Premium (AAP) to date when the rewards are
calculated. AAP is defined as the full-term cost of the policy at any given time in the Policy Lifecycle. So
any mid-term policy changes to the premium amount are automatically reflected in the premium used for
reward calculation.
Projected reward % is displayed on the DW dashboard or the smartphone app and updated daily. Once a
reward is issued, the customer is also notified via an email communication and the amount is printed on
the Declarations page. The performance rewards can be redeemed based on one of the following
preferences selected by the customer:
1. Applying as a policy credit
2. Issuing a check
3. Credit to Allstate Rewards account
The owner of the policy can redeem his or her reward amount at any time after the reward has been
issued. It does not have to be immediately redeemed and can be carried forward to future policy periods if
not redeemed within the current policy period.
Objection 9
Comments:
Explain the process for redeeming the performance reward for a premium credit. To which policies
can the reward be applied? If the policy to which the reward was applied was subsequently
cancelled, how is the amount of return premium calculated?
The performance reward amount is credited to the auto policy that is participating in the Drivewise
program. In the event of a cancellation after application of an issued reward as a premium credit, it is
treated the same as a cash payment on the policy premium.
Objection 10
Comments:
If an insured cancels a policy mid-term that is participating in the performance rewards program
(rule 82) but completes the minimum trip requirements, will the policy be able to redeem rewards
earned prior to cancellation?
The performance rewards that policy holders have already earned are for them to redeem, without any
expiration date.

 In the event that a policy cancels mid-term after earning the reward, the customer is issued a check in the
amount of outstanding credit within 5-10 business days. Any mid-term policy changes to the premium
amount are automatically reflected in the premium used for reward calculation. However, if a policy
cancels before the reward is issued to the customer, this additional expected issuance of a reward would
not be prorated for the trips that the driver has made since the last reward issuance.
Objection 11
Comments:
It appears that in Exhibits 14, 19, 20, 21, 27 in Attachment XI might be missing the "evaluated at 45
days prior to the effective date" clarification for renewal business experience period evaluation. If
this is needed, revise the manual pages as needed.
Rating factors based on comprehensive claims and uninsured motorist claims are exclusive to Pollux, as
SRM6 does not include rating factors based on these types of claims. The experience period for
comprehensive claims and uninsured motorist claims is evaluated as of the date when data was pulled, not
as of the latest effective date. As a reminder, all policies have been overridden to have 0 uninsured
motorist claims.
Objection 12
Comments:
In Attachment XI, Exhibit 130 in the last paragraph, it appears that you are stating that Group 5
has 29.13% of the policies. What is the significance of providing this data for Group 5 only?
In the event that any of the fields Effective_Year, Year_Current_Address, or NTR are present in the data
as a null or missing value, the Years at Current Address at New Business variable will be assigned to
Group 5 in order to give the policy a factor of 1.000 for this component of the Pollux loss cost estimate.
Please note that not all 29.13% of the policies in Group 5 are being assigned to this group due to null
values, and that this statistic also includes policies that actually have been at their current address for 5
years as of the new business effective date.
Objection 13
Comments:
On Manual pages RP-2A, identify the coverages labeled DNC and HNC.
Coverage DNC is New Car Expanded Protection coverage for Collision and Coverage HNC is New Car
Expanded Protection coverage for Comprehensive.
Objection 14
Comments:
Identify the states in which you have submitted a rating plan that uses a CGR factor applied to the
SRM6 premium. For each of these states, identify if the CGR selection is based on the use of a
retention model (similar to what was previously used in Ohio) or if the CGR selection is based on a
formula (similar to what is currently proposed for Ohio). For each of these states, describe the
status of the Department's review of the rating plan.
In addition to Ohio, Allstate has submitted a rating plan that uses a CGR factor applied to premium in 29
states. Attachment B shows the list of these 29 states, whether or not each state is using a retention
model, and the status of the Department’s review of the rating plan. The status of each Department’s
review of the rating plan is accurate as of June 24, 2016.
Objection 15

 Comments:
Confirm that Attachment XI, Exhibit 79's first column labeled Insurance Score is actually Rule 231's Policy Group number.
That is correct, Insurance Score is synonymous with Policy Group, as defined in Rule 23.
Objection 16
Comments:
Is the CGR factor applied to the DNC and HNC coverages?
Yes, CGR factors are applied to both DNC and HNC coverages. This is shown on RP-2A, Rating Step 42
for DNC and HNC coverages.
Objection 17
Comments:
In Attachment XI, Exhibit 78, a row is labeled 0. Would row 0 be used when the HLDI data is not
obtained or is not available?
That is correct. In addition, the HLDI data for this variable also only goes back to 1967, so any model
years prior to that year will return a value of 0 for this variable.
Objection 18
Comments:
Attachment XI, Exhibit 89, page 3 incorrectly refers to Attachment XI for more information about
Length of Vehicle. It should read Attachment XIII.
Within Attachment XI, all incorrect references to Attachment XI have now been updated to correctly refer
to Attachment XIII.
Objection 19
Comments:
Attachment XI, Exhibit 103, page 3 incorrectly refers to Attachment XI for more information
about an Allstate Motor Club Policy. It should read Attachment XIII.
Within Attachment XI, all incorrect references to Attachment XI have now been updated to correctly refer
to Attachment XIII.
Objection 20
Comments:
Confirm that future revisions will include an exhibit similar to Attachment II with regards to
compliance with Bulletin 2015-01.
With future revisions to the Complementary Group Assignments, Allstate will submit an exhibit similar
to Attachment II.
Objection 21
Comments:
Confirm that future revisions will include an exhibit similar to Attachment IX.
With future revisions to the Complementary Group Assignments, Allstate will submit an exhibit similar
to Attachment IX.

 Objection 22
Comments:
On Attachment VI, page 2, confirm that the indicated change to the policy premium is based on the
Pollux indicated premium relative to the current premium. In addition, confirm that the CGR
factor applied to a given policy can only approximate the adjusted change because of the limitations
of the number of CGR factors available. In other words, since there is not an individual CGR factor
for every policy, the CGR factor used can only approximate the estimated change.
In addition, discuss how an indicated change between zero and one percent is applied to the policy
premium.
That is correct, the indicated change to the policy premium is based on the Pollux Indicated Premium
relative to current premium. The Pollux Indicated Premium is determined for the 6 major coverages using
frequency and severity models described on Attachment V Page 2, plus the proposed premium for fixed
expenses and other coverages.
It is also correct that, since there is not an individual CGR factor for every policy, the CGR factor used
can only approximate the estimated change.
For a micro-segment that has an indicated change to policy premium between zero and one percent, the
policy premium will increase up to the indicated change, subject to the CGR factors available.
For example, on Attachment X, Exhibit 1, Page 1, M-S 169236 is indicated to increase by 0.44%.
However, due to the limited number of available CGR factors, M-S 169236 experiences a premium
change of 0.36%. For this example, relativities have been brought out to 4 decimal places to better show
the underlying indicated and selected factor changes.
MicroSegment
(1)

Current
Premium
Relativity
(2)

Pollux Indicated
Premium Relativity
(3)

Pollux Indicated
Change
(4) = (3)/(2) - 1

Final Premium
Relativity
(5)

Final Change
(6) = (5)/(2) -1

M-S 169236

0.5228

0.5251

0.44%

0.5247

0.36%

Objection 23
Comments:
Discuss how the various related indicated factors for various rating variables do not cause reversals
for a given rating variable, such as the Collision Deductible.
The indicated factors of the Pollux generalized linear model were not smoothed to incorporate any
assumed directional movement within a rating variable or adjusted for any assumed similarities of a
particular rating variable between coverages. By not adjusting the indicated factors of the generalized
linear model, we kept this predictive model at its most predictive position. Manual adjustments to any
indicated factors in this model could create results that are not as predictive of loss.
Because different deductibles have different causes of loss, different frequencies, and different average
severities, it is reasonable to believe that factors would vary by deductible. There are different types of
customers at the different deductibles that have different profiles. The GLM is simply reflecting the
differences in total loss expectations for the risks at the different deductibles while also accounting for the
multivariate effect of other rating variables.

 While it is certainly reasonable to “smooth” the resulting factors by deductible or other rating variables,
we chose to keep the model as predictive as possible.

 About Drivewise®
Welcome to the Allstate Drivewise program. Drivewise is a voluntary program designed by Allstate
Insurance Company and its affiliates (“Allstate”) to improve driver safety and self-awareness. Through
your use of Allstate approved data collection technology, Allstate issues rewards and provides services
based on your and/or your vehicle’s driving performance and preferences.
The premise of Drivewise is to provide rewards in the form of a discount, monetary reward, or both
(collectively referred to as “rewards”) on the auto insurance policy to customers who exhibit safe
driving behaviors. Data is collected through the Drivewise Mobile application installed on a compatible
mobile device. A participant downloads the Drivewise Mobile application and may earn a percentage of
the policy’s premium back as a reward based on driving performance data recorded by the Drivewise
Mobile application.
Drivewise Participation Requirements
You can enroll in Drivewise through your Allstate agent or by calling 1-800-ALLSTATE (1-800-2557828). You can also enroll your policy into the Drivewise Mobile Application program directly in My
Account on Allstate.com or via the Drivewise Mobile application. In order to participate in Drivewise
and earn all of the rewards and services that Drivewise has to offer, you must: (1) be the legal,
authorized owner of the vehicle(s) on your policy and have the right to enroll listed vehicles or drivers
on your policy in Drivewise; (2) take all of the appropriate steps necessary to ensure a sufficient amount
of driving data is recorded as outlined in this document; (3) provide an active and valid email address for
yourself and all enrolled drivers to ensure proper communication. Allstate reserves the right to amend,
modify, waive, or supplement these terms, or terminate your Drivewise participation at any time and for
any reason.
Enrollment in Drivewise is dependent on our receipt of driving performance data, so you must
accept and comply with the terms of any agreement that governs the method of recording data
such as the Drivewise Terms of Service in order to participate in Drivewise.
Eligibility Requirements
At least one driver must be fully enrolled to qualify for any Drivewise benefits. In the event that an
enrolled driver is added or replaced, you are responsible for notifying Allstate and taking the necessary
steps to ensure proper data recording, as defined below. Any delay in these steps may impact your
eligibility for Drivewise rewards.
Drivewise Mobile Application Program Eligibility
To be eligible to receive policy rewards through the Drivewise Mobile application program, a driver
must:
1. Be a listed operator on the policy
2. Provide a valid and active email address and phone number
3. Have a compatible personal device, such as a smartphone, and install the Drivewise Mobile
application
4. Accept the Terms of Service of the Drivewise Mobile application
DP2004

 5. Enable location services on the phone
6. Keep the Drivewise Mobile application on the phone and eligible to run in the background; and
7. Record a minimum of 50 trips throughout the performance cycle
The Drivewise Participation Discount
Customers enrolled in Drivewise are eligible to receive a discount for their participation in the program.
In order to maintain the discount, you must complete all of the program enrollment steps listed above,
and also have at least one trip recorded on the Drivewise Mobile application every six months of the
policy cycle.
Participation Calculation
The Drivewise participation discount is calculated and applied as a percentage of the policy’s premium
amount based on the effective date of the enrollment, regardless of the number of vehicles enrolled.
Changes to your policy affecting the amount of total policy or vehicle premium may impact the discount
amount.
Performance Rewards
You may qualify for a performance reward every six months based on your driving performance,
provided that you have taken at least 50 trips within the performance cycle. The performance reward is
calculated as a percentage of your auto policy's premium at the time of the calculation, based on the
driving performance data recorded by the Drivewise Mobile application. The performance reward
calculation takes into account the proportion of qualifying drivers to the total number of drivers listed on
the policy.
Performance
For each driver enrolled, Drivewise uses up to 12 months of driving performance data (on a rolling
calendar basis) to apply the performance reward on your policy. To determine the performance reward,
we look at driving behaviors such as speed, braking and the time of day when you drive. We may
periodically update the driving behaviors we consider in calculating the reward as we gather more
information about how driving behavior relates to safety. A list of driving behaviors we currently look
at to calculate any rewards is available at www.allstate.com/landingpages/drivewiseapp.aspx.
Performance cycles are six months long and begin once a trip has been taken. A minimum of 50 trips is
required within the performance cycle in order to be eligible for a performance reward. Upon
enrollment, once 50 trips have been taken, including any trips that may have been taken while using the
Drivewise Mobile application prior to enrolling your policy into Drivewise, an initial performance
reward is issued, if earned. This initial performance reward calculation does not take into account the
proportion of qualifying drivers and is instead applied to the entire auto policy’s premium. Performance
is then re-evaluated every six months thereafter, requiring a minimum of 50 trips per operator to qualify
and taking into account the proportion of qualifying drivers to calculate a performance reward. Your
performance reward may vary from one period to another based on aggregate driving performance.
Changes to your policy affecting the amount of total policy premium may also impact the performance
reward.
DP2004

 Auto Policy Updates and the Impact to Drivewise
You are responsible for notifying Allstate of any changes to vehicle or operator information. If multiple
drivers are listed on a policy, one or more drivers may enroll in Drivewise. The performance reward will
be limited if all listed drivers are not enrolled. Enrolling more drivers increases the potential rewards
that can be earned.
How Allstate Receives Drivewise Data
Allstate enters into arrangements with other companies to obtain driving information to administer
Drivewise. The company administering the Drivewise program receives your driving data which may be
analyzed or scored by that company in order to provide rewards and incentives based on safe driving
behavior. The agreement which governs the collection of driving information describes how that data is
collected and used by the collecting company. All vendors supporting the Drivewise program adhere to
the strict privacy and data security standards within Allstate protocol.
If you have questions about how your Drivewise data is gathered or no longer wish to have your data
collected or shared with Allstate, contact (877) 431-7670 to un-enroll from the Drivewise program.
How Allstate Uses Drivewise Data
Allstate receives the driving performance data for each participating operator and will provide you with
savings and rewards as part of your auto insurance policy in accordance with the rules and rates on file
with the state insurance department where your vehicle is garaged. Data may be retained indefinitely.
Driving data used to calculate the performance score can be viewed at myaccount.allstate.com by the
person who enrolled the policy or through the Drivewise Mobile application. We may provide your
Drivewise data to insurance regulators to support rate or other insurance related filings. Allstate, at its
discretion, may also review Drivewise data as part of its investigation of an automobile accident.
Additionally, Allstate may use your Drivewise data to improve our insurance pricing and underwriting
models.
Tampering
You may not tamper (alter, modify, change, disassemble, reverse engineer, copy, or duplicate in any
manner) with the Drivewise Mobile application or any other technology used to gather the Drivewise
data. When detected, you may be removed from any or all rewards and service offerings in which you
are participating, and you may forfeit any rewards or offerings owed to you at the time of tampering. In
addition, you may be subject to legal action and denied future participation in any Allstate offerings.
Ending Participation in Drivewise
You can cancel your participation in Drivewise at any time by notifying your Allstate agent or an
Allstate representative at 1-800-ALLSTATE (800-255-7828). We will update your policy information.
A driver that has voluntarily withdrawn may be permitted to re-enroll in Drivewise.
Drivewise Support
If you have any questions, comments, or concerns about the Drivewise program or how it applies to the
policy, you can contact the Drivewise customer team at (877) 431-7670 from 7:00 a.m. - 7:00 p.m. CT,
Monday - Friday, or contact your Allstate agent.
DP2004

 Attachment A

State
Arizona
Arkansas
Colorado
Delaware
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Maryland
Michigan
Minnesota
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Mexico
Oklahoma
Oregon
South Carolina *
Tennessee
Texas
Utah
Virginia **
West Virginia
Wisconsin
Wyoming

Underlying Rating Plan is SRM6?
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
No
Yes
Yes
Yes

Filing Law
Use and File
File and Use
File and Use
File and Use
Use and File
Use and File
File and Use
File and Use
File and Use
Use and File
Prior Approval
File and Use
File and Use
Use and File
File and Use
File and Use
Prior Approval
File and Use
File and Use
Use and File
File and Use
Prior Approval
File and Use
File and Use
Use and File
File and Use
Prior Approval
File and Use
No File

Filing Status
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Active Review
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Active Review
Filing Acknowledged and Closed
Active Review
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Approved
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Acknowledged and Closed
Filing Approved
Filing Acknowledged and Closed
Active Review
Active Review
Filing Acknowledged and Closed
Filing Approved
Filing Acknowledged and Closed
No File State

Retention Model Used?
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes

* In South Carolina, the CGR structure is currently being used as a mechanism to mitigate rate impacts as a result of other factor changes.
** In Virginia, the CGR structure is currently being used to improve new business competitive position.