The “flex band” system allows carriers certain leeway within a fixed percentage to raise or lower rates at will without regulatory approval, while the two systems involving filing and using still retain some regulatory oversight to a varying degree for all changes.

In a joint letter from the Washington-based Consumer Federation of America and the Austin, Texas-based Center for Economic Justice, CEJ executive director Birny Birnbaum said the proposed model fails to recognize that new risk classification systems have far more impact on premiums than actual rate schemes.

In addition, the model's requirement that a regulator must find a market “not competitive is a needless barrier to regulatory protection of consumers,” Mr. Birnbaum wrote.

Moreover, competition does not protect consumers when it comes to policy forms. “It is not reasonable to separate out competition for rates from competition for policy forms because any comparison of rates must rely on an understanding of the coverage associated with those rates,” Mr. Birnbaum wrote.

David Parsons, working group chairman and Alabama deputy commissioner, said at the panel's meeting in June that he hopes to have a model ready for adoption by the annual winter meeting in December.

The action on personal lines regulatory reform has returned the issue to the NAIC's front burner after an absence of five years.