SEC Company Response from OLD REPUBLIC INTERNATIONAL CORP (ORI) (CIK 0000074260) (ORI) — Sep 20, 2011
OLD REPUBLIC INTERNATIONAL CORP (ORI) (CIK 0000074260)
Date: Sept. 20, 2011 · CIK: 0000074260 · Accession: 0000074260-11-000094
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-10607
Referenced dates: August 23, 2011
Letter
United States Securities and Exchange Commission Old Republic International Corporation Form 10-K, fiscal year ended December 31, 2010 Filed February 28, 2011 File No. 001-10607
Re:
Dear Mr. Rosenberg,
We have reviewed the comments on our above referenced filing in your letter dated August 23, 2011. Our Company’s response to the Commission’s comments follows. The references to “Old Republic”, “the Company”, “Republic Mortgage Insurance Company”, and “RMIC” herein, refer to Old Republic International Corporation and its subsidiaries as the context requires. All dollar amounts referenced in the Company’s response are presented in millions, except per share data.
General
Risk Factors
Fewer Coverage Rescissions, page 22
Comment 1
You state that “The Company’s mortgage insurance policy provisions permit it to rescind coverage whenever it finds evidence that a mortgage loan did not qualify for insurance coverage in the first instance, or that a material misrepresentation had been made in the loan application by the borrower, or the lender, and/or its agent.” You further disclose (page 70) that “Claims not paid by virtue of coverage rescissions and claims denials amounted to $748.8 million, $719.5 million and $211.0 million for 2010, 2009, and 2008, respectively.” Please provide us proposed disclosures to be included in MD&A under Results of Operations – Overview of Loss Reserving Process – Mortgage guarantee on page 52 in future filings that address the following:
·
Disclose, if true, that it is your legal right to unilaterally rescind coverage on your mortgage insurance policies as if such coverage never existed, and disclose the conditions that must be met in order for this right to be exercised.
·
Disclose how, as an operational matter, the rescission and claim denials work. For example, after you have determined the loan did not qualify for insurance coverage or origination documents and information you received and relied upon included material misrepresentations, do you immediately send a letter to the lender notifying them of the rescission and refund premium related to that policy?
·
Disclose how you determine claims not paid by virtue of coverage rescissions and claims denials as discussed in note (a) to the table on page 70 and its relationship to the reserves you accrued. For example, are reserves reduced when you officially communicate the rescission to the lender, or after all lender appeals are considered?
·
Disclose whether the insured has a contractual right to appeal the rescission or claim denial and describe the process, timing of reinstating rescinded policies and at what point you deem a rescission is resolved.
·
Disclose whether you have sought or are planning to seek recoveries from the beneficiaries of your mortgage insurance policies for previously paid claims. If so, please disclosure how you are accounting for such recoveries and tell us the supporting GAAP literature.
Response
In order to respond to the Commission’s comment and clarify the Company’s disclosures regarding coverage rescission and claim denial activity we propose to add the following disclosure to the 2011 MD&A under Results of Operations – Overview of the Loss Reserving Process – Mortgage Guaranty:
“The Company has the legal right to rescind mortgage insurance coverage unilaterally as expressly stated in its policy. Moreover, the two federal courts to have recently considered that policy wording have each affirmed that right (See First Tennessee Bank N.A. v. Republic Mortg. Ins. Co., Case No. 2:10-cv-02513-JPM-cgc (W.D. Tenn., Feb. 25, 2011) and JPMorgan Chase Bank N.A. v. Republic Mortg. Ins. Co., Civil Action No. 10-06141 (SRC) (D. NJ, May 4, 2011), each decision citing supporting state law legal precedent). RMIC’s mortgage insurance policy provides that the insured represents that all statements made and information provided to it in an application for coverage for a loan, without regard to who made the statements or provided the information, have been made and presented for and on behalf of the insured; and that such statements and information are neither false nor misleading in any material respect, nor omit any fact necessary to make such statements and information not false or misleading in any material respect. According to the policy, if any of those representations are materially false or misleading with respect to a loan, the Company has the right to cancel or rescind coverage for that loan retroactively to commencement of the coverage.
Where the Company determines that an application contains a material misrepresentation, it either advises the insured in writing of its findings prior to rescinding coverage or exercises its unilateral right to rescind coverage for that loan, stating the reasons for that action in writing and returning the applicable premium.
The rescission of coverage in instances of materially faulty representations or warranties provided in applications for insurance is a necessary and prevailing practice throughout the insurance industry. In the case of mortgage guaranty insurance, rescissions have occurred regularly over the years but have been generally immaterial. Since 2008, however, the Company has experienced a much greater incidence of rescissions due to increased levels of observed fraud and misrepresentations in insurance applications pertaining to business underwritten between 2004 and the early part of 2008. As a result, the Company has of necessity incorporated estimates of expected levels of coverage rescissions and claim denials in its reserving methodology since 2008. Such estimates are evaluated at each balance sheet date and take into account observed trends in rescission and denial rates.
The table below shows the estimated effects of coverage rescissions and claim denials on loss reserves and paid and incurred losses.
Estimated rescission reduction in beginning reserve
$
710.5
$
1,712.4
$
830.5
Estimated rescission reduction (increase) in losses incurred
178.3
1,601.4
Estimated rescission reduction in paid claims
(748.8)
(719.5)
Estimated reduction related to pool insurance terminations
(431.4)
-
Estimated rescission reduction in ending reserve
$
$
710.5
$
1,712.4
The estimated reduction in carried loss reserves is based on management’s judgments relative to the level of expected coverage rescissions and claim denials on loans that are in default as of each balance sheet date. The reduced benefit to incurred losses and decline in ending reserves from 2009 through 2010 attributable to rescission and claim denials is due to lower estimates of defaulted loans for which coverage is likely to be rescinded or denied. Variances between the ultimate actual rescission and claim denial rate are inherently reflected in the periods during which they occur.
Claims not paid by virtue of rescission or denial represent the Company’s estimated contractual risk, before consideration of the impacts of any reinsurance and deductibles or aggregate loss limits, on cases that are settled by the issuance of a rescission or denial notification. In 2010, the above noted release of the estimated rescissions and claim denials of $431.4 relates to certain pool insurance contracts which were terminated during the year.
Although the insured has no right under the policy to appeal, if the insured, at any time, contests in writing the Company’s findings or action with respect to a loan or a claim, the Company considers any additional information supplied by the insured. This consideration may lead to further investigation, retraction or confirmation of the initial determination. If the Company concludes that it will reinstate coverage, it advises the insured in writing that it will do so immediately upon receipt of the premium previously returned. Reserves are not adjusted for potential reversals of rescissions or adverse rulings for loans under dispute since such reversals of claim rescissions and denials have historically been immaterial to the reserve estimation process.
There is currently a single instance in which the Company seeks to recover from an insured for previously paid claims. In its counterclaim in the pending arbitration with Countrywide (Countrywide Fin’l Corp. v. Republic Mortg. Ins. Co., Case No. 72 195 Y 0011510 (AAA). The Countrywide parties are Countrywide Financial Corporation, Countrywide Home Loans, Inc., Bank of America, N.A., in its own capacity and as successor by merger of BAC Home Loan Servicing L.P.), RMIC is seeking to rescind a June 2006 amendment to a mortgage insurance policy that it contends was fraudulently induced by Countrywide. The amendment made coverage for a loan immediately incontestable for borrower misrepresentation. The Company seeks a declaration that the amendment is null and void and to recover the claim amounts totaling at least $26.6 that it paid notwithstanding the existence of borrower misrepresentations that otherwise would have supported a rescission of coverage for those loans. The Company does not anticipate recoveries from previously paid claims in its reserving process until such time as a recovery is deemed probable and the amount can be reasonably estimated.”
Notes to Consolidated Financial Statements
Note 1: Summary of Significant Accounting Policies
(d) – Investments, page 63
Comment 2
Tell us how your presentation of other-than-temporary impairment losses on the statement of income complies with ASC 320-10-45-8A and 320-10-55-21A.
Response
ASC 320-10-45-8A states that “in periods in which an entity determines that a security’s decline in fair value below its amortized cost basis is other than temporary, the entity shall present the total other-than-temporary impairment in the statement of earnings with an offset for the amount of total other-than-temporary impairment that is recognized in other comprehensive income…, if any.” ASC 320-10-55-21A illustrates the application of this guidance.
The Company’s other-than-temporary-impairment (OTTI) losses are presented within a single line item on the consolidated statements of income. This single line item presentation has been adopted in all periods presented since 100% of the OTTI losses were recognized in the statements of income and no offset applied for amounts recognized in other comprehensive income.
(h) – Losses, Claims and Settlement Expenses, page 70
Comment 3
Refer to the table on page 70. It is not clear to us what is included in “Incurred claims and claim adjustment expenses” for mortgage guaranty. For example, regarding the “change in provision for insured events of prior years” for mortgage guaranty in 2010, 2009 and 2008, footnote (a) would appear to infer that included in this line item is $1,001.9 million, ($881.9) million and ($830.5) million for the years ended December 31, 2010, 2009 and 2008 due to the effect of changes in anticipated coverage rescissions and claims denials. In this regard, if this is not the case, provide us proposed disclosure to be included in future filings as to where in the three lines denoted with an (a) in the table the amounts of $1,001.9 million, ($881.9) million and ($830.5) million in 2010, 2009 and 2008, respectively, in footnote (a) are included. If it is the case that these amounts are included in the line item “change in provision for insured events of prior years.” Tell us:
·
What caused changes of this magnitude;
·
What other changes are included in each period. For example, if $1,001.9 million increase is included in the ($15.2) million in 2010, what is the remainder of ($1,017.1) million decrease and what caused these changes.
Further, with respect to amounts due to the effect of changes in anticipated coverage rescissions and claims denials, please tell us why it is appropriate under GAAP to increase (reduce) your loss reserves by estimating rescissions and claims denials. In addition, please provide us proposed disclosure to be included in future filings that addresses the following:
·
How you determine your estimates of rescissions and claims denials.
·
Whether your reserve estimate includes an assumption for reinstatement of previously rescinded policies, and if not, your basis for not including such an assumption. If included, please quantify the amounts for the periods presented.
·
Address how you considered your ongoing litigation and arbitration proceedings with, for example, Bank of America, Countrywide and Chase Bank.
Response
ASC 944-40, “Unpaid Claim Costs” states: “A liability for unpaid claim costs relating to insurance contracts, other than title insurance contracts, shall be accrued when insured events occur. This amount shall include an estimate of costs relating to claims incurred but not reported. The liability for unpaid claims shall be based on the estimated ultimate cost of settling the claims.”
For each of its lines of insurance, the Company establishes loss reserves at each balance sheet date based on estimates of the ultimate cost of settling valid claims. The reserve setting process encompasses a wide range of variables and management judgments including, among others, anticipated levels of mortgage insurance coverage rescissions and claim denials. Where the Company determines that an application contains a material misrepresentation and rescinds coverage, the estimated cost to settle a claim is limited to investigative costs and the return of premium, both of which are incorporated into the Company’s loss reserving methodology.
To respond to the Commission’s comments, we propose to replace footnote 1(h), Losses, Claims and Settlement Expenses – Mortgage Guaranty on page 69 of the 2010 Form 10-K with the following disclosure on a prospective basis beginning with the Company’s 2011 Form 10-K:
“Mortgage guaranty insurance reserves for unpaid claims and claim adjustment expenses are recognized only upon an instance of default, defined as an insured mortgage loan for which two or more consecutive monthly payments have been missed. Loss reserves are based on statistical calculations that take into account the number of reported insured mortgage loan defaults as of each balance sheet date, as well as experience-based estimates of loan defaults that have occurred but have not as yet been reported ("IBNR"). Further, the loss reserve estimating process takes into account a large number of variables including trends in claim severity, potential salvage recoveries, expected cure rates for reported loan delinquencies at various stages of default, the level of coverage rescissions and claims denials due to material misrepresentation in key underwriting information or non-compliance with prescribed underwriting guidelines, and management judgments relative to future employment levels, housing market activity, and mortgage loan interest costs, demand, and extensions.
Historically coverage rescissions and claims denials resulting from material misrepresentation in key underwriting information or non-compliance with terms of the master policy have not been material. Since 2008, however, in response to the significant increase in fraud and misrepresentation, the Company has incorporated into its reserving methodology certain assumptions regarding the expected levels of coverage rescissions and claim denials. Such estimates, which are evaluated as of each balance sheet date, take into account observed trends in rescission and denial rates.
The table below shows the estimated impact coverage rescissions and claim denials have had on loss reserves and paid and incurred losses.
Estimated rescission reduction in beginning reserve
$
710.5
$
1,712.4
$
830.5
Estimated rescission reducti
Show Raw Text
CORRESP
1
filename1.htm
secletter092011.htm
September 20, 2011
Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re:
Old Republic International Corporation
Form 10-K, fiscal year ended December 31, 2010
Filed February 28, 2011
File No. 001-10607
Dear Mr. Rosenberg,
We have reviewed the comments on our above referenced filing in your letter dated August 23, 2011. Our Company’s response to the Commission’s comments follows. The references to “Old Republic”, “the Company”, “Republic Mortgage Insurance Company”, and “RMIC” herein, refer to Old Republic International Corporation and its subsidiaries as the context requires. All dollar amounts referenced in the Company’s response are presented in millions, except per share data.
General
Risk Factors
Fewer Coverage Rescissions, page 22
Comment 1
You state that “The Company’s mortgage insurance policy provisions permit it to rescind coverage whenever it finds evidence that a mortgage loan did not qualify for insurance coverage in the first instance, or that a material misrepresentation had been made in the loan application by the borrower, or the lender, and/or its agent.” You further disclose (page 70) that “Claims not paid by virtue of coverage rescissions and claims denials amounted to $748.8 million, $719.5 million and $211.0 million for 2010, 2009, and 2008, respectively.” Please provide us proposed disclosures to be included in MD&A under Results of Operations – Overview of Loss Reserving Process – Mortgage guarantee on page 52 in future filings that address the following:
·
Disclose, if true, that it is your legal right to unilaterally rescind coverage on your mortgage insurance policies as if such coverage never existed, and disclose the conditions that must be met in order for this right to be exercised.
·
Disclose how, as an operational matter, the rescission and claim denials work. For example, after you have determined the loan did not qualify for insurance coverage or origination documents and information you received and relied upon included material misrepresentations, do you immediately send a letter to the lender notifying them of the rescission and refund premium related to that policy?
·
Disclose how you determine claims not paid by virtue of coverage rescissions and claims denials as discussed in note (a) to the table on page 70 and its relationship to the reserves you accrued. For example, are reserves reduced when you officially communicate the rescission to the lender, or after all lender appeals are considered?
·
Disclose whether the insured has a contractual right to appeal the rescission or claim denial and describe the process, timing of reinstating rescinded policies and at what point you deem a rescission is resolved.
·
Disclose whether you have sought or are planning to seek recoveries from the beneficiaries of your mortgage insurance policies for previously paid claims. If so, please disclosure how you are accounting for such recoveries and tell us the supporting GAAP literature.
Response
In order to respond to the Commission’s comment and clarify the Company’s disclosures regarding coverage rescission and claim denial activity we propose to add the following disclosure to the 2011 MD&A under Results of Operations – Overview of the Loss Reserving Process – Mortgage Guaranty:
“The Company has the legal right to rescind mortgage insurance coverage unilaterally as expressly stated in its policy. Moreover, the two federal courts to have recently considered that policy wording have each affirmed that right (See First Tennessee Bank N.A. v. Republic Mortg. Ins. Co., Case No. 2:10-cv-02513-JPM-cgc (W.D. Tenn., Feb. 25, 2011) and JPMorgan Chase Bank N.A. v. Republic Mortg. Ins. Co., Civil Action No. 10-06141 (SRC) (D. NJ, May 4, 2011), each decision citing supporting state law legal precedent). RMIC’s mortgage insurance policy provides that the insured represents that all statements made and information provided to it in an application for coverage for a loan, without regard to who made the statements or provided the information, have been made and presented for and on behalf of the insured; and that such statements and information are neither false nor misleading in any material respect, nor omit any fact necessary to make such statements and information not false or misleading in any material respect. According to the policy, if any of those representations are materially false or misleading with respect to a loan, the Company has the right to cancel or rescind coverage for that loan retroactively to commencement of the coverage.
Where the Company determines that an application contains a material misrepresentation, it either advises the insured in writing of its findings prior to rescinding coverage or exercises its unilateral right to rescind coverage for that loan, stating the reasons for that action in writing and returning the applicable premium.
The rescission of coverage in instances of materially faulty representations or warranties provided in applications for insurance is a necessary and prevailing practice throughout the insurance industry. In the case of mortgage guaranty insurance, rescissions have occurred regularly over the years but have been generally immaterial. Since 2008, however, the Company has experienced a much greater incidence of rescissions due to increased levels of observed fraud and misrepresentations in insurance applications pertaining to business underwritten between 2004 and the early part of 2008. As a result, the Company has of necessity incorporated estimates of expected levels of coverage rescissions and claim denials in its reserving methodology since 2008. Such estimates are evaluated at each balance sheet date and take into account observed trends in rescission and denial rates.
2
The table below shows the estimated effects of coverage rescissions and claim denials on loss reserves and paid and incurred losses.
2011
2010
2009
Estimated rescission reduction in beginning reserve
$
710.5
$
1,712.4
$
830.5
Estimated rescission reduction (increase) in losses incurred
178.3
1,601.4
Estimated rescission reduction in paid claims
(748.8)
(719.5)
Estimated reduction related to pool insurance terminations
(431.4)
-
Estimated rescission reduction in ending reserve
$
$
710.5
$
1,712.4
The estimated reduction in carried loss reserves is based on management’s judgments relative to the level of expected coverage rescissions and claim denials on loans that are in default as of each balance sheet date. The reduced benefit to incurred losses and decline in ending reserves from 2009 through 2010 attributable to rescission and claim denials is due to lower estimates of defaulted loans for which coverage is likely to be rescinded or denied. Variances between the ultimate actual rescission and claim denial rate are inherently reflected in the periods during which they occur.
Claims not paid by virtue of rescission or denial represent the Company’s estimated contractual risk, before consideration of the impacts of any reinsurance and deductibles or aggregate loss limits, on cases that are settled by the issuance of a rescission or denial notification. In 2010, the above noted release of the estimated rescissions and claim denials of $431.4 relates to certain pool insurance contracts which were terminated during the year.
Although the insured has no right under the policy to appeal, if the insured, at any time, contests in writing the Company’s findings or action with respect to a loan or a claim, the Company considers any additional information supplied by the insured. This consideration may lead to further investigation, retraction or confirmation of the initial determination. If the Company concludes that it will reinstate coverage, it advises the insured in writing that it will do so immediately upon receipt of the premium previously returned. Reserves are not adjusted for potential reversals of rescissions or adverse rulings for loans under dispute since such reversals of claim rescissions and denials have historically been immaterial to the reserve estimation process.
There is currently a single instance in which the Company seeks to recover from an insured for previously paid claims. In its counterclaim in the pending arbitration with Countrywide (Countrywide Fin’l Corp. v. Republic Mortg. Ins. Co., Case No. 72 195 Y 0011510 (AAA). The Countrywide parties are Countrywide Financial Corporation, Countrywide Home Loans, Inc., Bank of America, N.A., in its own capacity and as successor by merger of BAC Home Loan Servicing L.P.), RMIC is seeking to rescind a June 2006 amendment to a mortgage insurance policy that it contends was fraudulently induced by Countrywide. The amendment made coverage for a loan immediately incontestable for borrower misrepresentation. The Company seeks a declaration that the amendment is null and void and to recover the claim amounts totaling at least $26.6 that it paid notwithstanding the existence of borrower misrepresentations that otherwise would have supported a rescission of coverage for those loans. The Company does not anticipate recoveries from previously paid claims in its reserving process until such time as a recovery is deemed probable and the amount can be reasonably estimated.”
3
Notes to Consolidated Financial Statements
Note 1: Summary of Significant Accounting Policies
(d) – Investments, page 63
Comment 2
Tell us how your presentation of other-than-temporary impairment losses on the statement of income complies with ASC 320-10-45-8A and 320-10-55-21A.
Response
ASC 320-10-45-8A states that “in periods in which an entity determines that a security’s decline in fair value below its amortized cost basis is other than temporary, the entity shall present the total other-than-temporary impairment in the statement of earnings with an offset for the amount of total other-than-temporary impairment that is recognized in other comprehensive income…, if any.” ASC 320-10-55-21A illustrates the application of this guidance.
The Company’s other-than-temporary-impairment (OTTI) losses are presented within a single line item on the consolidated statements of income. This single line item presentation has been adopted in all periods presented since 100% of the OTTI losses were recognized in the statements of income and no offset applied for amounts recognized in other comprehensive income.
(h) – Losses, Claims and Settlement Expenses, page 70
Comment 3
Refer to the table on page 70. It is not clear to us what is included in “Incurred claims and claim adjustment expenses” for mortgage guaranty. For example, regarding the “change in provision for insured events of prior years” for mortgage guaranty in 2010, 2009 and 2008, footnote (a) would appear to infer that included in this line item is $1,001.9 million, ($881.9) million and ($830.5) million for the years ended December 31, 2010, 2009 and 2008 due to the effect of changes in anticipated coverage rescissions and claims denials. In this regard, if this is not the case, provide us proposed disclosure to be included in future filings as to where in the three lines denoted with an (a) in the table the amounts of $1,001.9 million, ($881.9) million and ($830.5) million in 2010, 2009 and 2008, respectively, in footnote (a) are included. If it is the case that these amounts are included in the line item “change in provision for insured events of prior years.” Tell us:
·
What caused changes of this magnitude;
·
What other changes are included in each period. For example, if $1,001.9 million increase is included in the ($15.2) million in 2010, what is the remainder of ($1,017.1) million decrease and what caused these changes.
Further, with respect to amounts due to the effect of changes in anticipated coverage rescissions and claims denials, please tell us why it is appropriate under GAAP to increase (reduce) your loss reserves by estimating rescissions and claims denials. In addition, please provide us proposed disclosure to be included in future filings that addresses the following:
·
How you determine your estimates of rescissions and claims denials.
·
Whether your reserve estimate includes an assumption for reinstatement of previously rescinded policies, and if not, your basis for not including such an assumption. If included, please quantify the amounts for the periods presented.
·
Address how you considered your ongoing litigation and arbitration proceedings with, for example, Bank of America, Countrywide and Chase Bank.
4
Response
ASC 944-40, “Unpaid Claim Costs” states: “A liability for unpaid claim costs relating to insurance contracts, other than title insurance contracts, shall be accrued when insured events occur. This amount shall include an estimate of costs relating to claims incurred but not reported. The liability for unpaid claims shall be based on the estimated ultimate cost of settling the claims.”
For each of its lines of insurance, the Company establishes loss reserves at each balance sheet date based on estimates of the ultimate cost of settling valid claims. The reserve setting process encompasses a wide range of variables and management judgments including, among others, anticipated levels of mortgage insurance coverage rescissions and claim denials. Where the Company determines that an application contains a material misrepresentation and rescinds coverage, the estimated cost to settle a claim is limited to investigative costs and the return of premium, both of which are incorporated into the Company’s loss reserving methodology.
To respond to the Commission’s comments, we propose to replace footnote 1(h), Losses, Claims and Settlement Expenses – Mortgage Guaranty on page 69 of the 2010 Form 10-K with the following disclosure on a prospective basis beginning with the Company’s 2011 Form 10-K:
“Mortgage guaranty insurance reserves for unpaid claims and claim adjustment expenses are recognized only upon an instance of default, defined as an insured mortgage loan for which two or more consecutive monthly payments have been missed. Loss reserves are based on statistical calculations that take into account the number of reported insured mortgage loan defaults as of each balance sheet date, as well as experience-based estimates of loan defaults that have occurred but have not as yet been reported ("IBNR"). Further, the loss reserve estimating process takes into account a large number of variables including trends in claim severity, potential salvage recoveries, expected cure rates for reported loan delinquencies at various stages of default, the level of coverage rescissions and claims denials due to material misrepresentation in key underwriting information or non-compliance with prescribed underwriting guidelines, and management judgments relative to future employment levels, housing market activity, and mortgage loan interest costs, demand, and extensions.
Historically coverage rescissions and claims denials resulting from material misrepresentation in key underwriting information or non-compliance with terms of the master policy have not been material. Since 2008, however, in response to the significant increase in fraud and misrepresentation, the Company has incorporated into its reserving methodology certain assumptions regarding the expected levels of coverage rescissions and claim denials. Such estimates, which are evaluated as of each balance sheet date, take into account observed trends in rescission and denial rates.
The table below shows the estimated impact coverage rescissions and claim denials have had on loss reserves and paid and incurred losses.
2011
2010
2009
Estimated rescission reduction in beginning reserve
$
710.5
$
1,712.4
$
830.5
Estimated rescission reducti