California Commissioner Announces Proposed Changes to Proposition 103 and Intervenor Process

Troutman Pepper Locke
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Troutman Pepper Locke

[co-author: Dani D’Annunzio]*

In a press release dated September 19, 2025, Commissioner Ricardo Lara announced proposed changes to California’s rate review and intervenor system. The state’s intervenor system, initially established by Proposition 103 in 1988 and last updated in 2006, currently authorizes “intervenors” to participate in rate review. The system allows intervenors to recover costs, expenses, and attorneys’ fees related to their intervention from insurers. By law, insurers are permitted to pass these costs on to consumers.

Lara’s proposed regulation aims to ensure that consumers only pay for contributions deemed significant to the public interest. The stated goals of the new regulation include, specifically:

  1. Clarifying the standard for determining “substantial contribution” in intervenor compensation.
  2. Implementing public reporting on the activities and compensation of intervenors.
  3. Establishing timelines for administrative law judges to render their decisions.
  4. Requiring the California Department of Insurance to publish documents for the public, including hearing calendars and decisions.

Beginning on October 3, 2025, stakeholders have 45 days to submit public comment on the proposed rule. A public hearing is scheduled for November 20, 2025, at 1 p.m., following the close of the public comment period.

The California Department of Insurance’s press release can be found here.

*not licensed to practice law in any jurisdiction; bar admission pending.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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