OPINION
SHORT, Judge.
Altra Auto Rental, Inc., a division of Agency Rent-A-Car, Inc. (Altra), appeals the trial court’s determination that Altra’s self-insurance plan provides primary liability coverage in this action up to the full amount of its self-insured retention, $500,-000. Altra argues that it should provide primary liability coverage only in the amount mandated by statute, $30,000 per person and $60,000 per accident. We agree and reverse.
FACTS
The facts of this case are not in dispute. In 1986, four college-aged women planned to take a spring vacation to Padre Island in Texas. One of them, Shannon Murphy, contacted Altra, inquiring about renting a car. The agent told Murphy the least expensive rental rate could be obtained if the rental car were a substitute for an out-of-service vehicle owned and insured by the renter. Murphy told the agent that another of the foursome, Michelle McClain, had an out-of-service Volkswagen. The agent delivered the rental car on March 21. McClain was not available, so Christine Meyers, the only member of the group over age 21, signed the rental agreement. Meyers and Murphy informed the agent that McClain had an insurance policy with Fireman’s Fund Insurance. The agent later filled in the rental form with an invented policy number, agent’s name, and agency phone number. The form indicated that Altra did not provide liability insurance, and that the vehicle was to be insured by the lessee.
On March 30, at 4:00 a.m., the four women were passing through Missouri on their way back to Minnesota. Respondent Bridget Begley fell asleep at the wheel, and collided with a vehicle parked at the side of the interstate. McClain, riding in the front passenger seat, was killed. When the rental agent learned of the accident, he blotted out the false information on the rental form.
Claudia McClain, trustee for the heirs of Michelle McClain, brought a wrongful death action against Begley, Meyers, and Altra. Begley was insured on her parent’s policy with Allstate. Altra commenced a declaratory judgment action against Allstate and Fireman’s Fund to determine the priority of coverage. The claim against Fireman’s Fund was dismissed, apparently because McClain did not have a valid policy with Fireman’s at the time of the rental.
McClain, Begley, Meyers and Allstate moved for partial summary judgment in the wrongful death action, seeking a declaration that Altra provided primary liability coverage up to its self-insured retention limit of $500,000. The trial court granted the motion, and this court denied a petition for discretionary review.
The parties then stipulated that McClain’s death was caused by Begley’s negligence, that the total amount of damages was $155,000, and that the wrongful death and declaratory judgment actions would be consolidated. Judgment was entered accordingly. The sole issue on appeal is the extent of Altra’s liability. Altra argues it is liable only in the amount statutorily mandated, or $30,000, and that Allstate is secondarily liable for its full amount of coverage, $100,000. Under this scenario, McClain’s estate will go uncompensated for $25,000. Respondents argue that Altra is liable to the limits of its self-insured retention, or $500,000. Under this scenario, McClain’s estate will be fully compensated for the stipulated amount of damages, and Allstate will have no liability.
ISSUE
Is a self-insurer liable to the limits of its self-insured retention if it fails to specify lower liability limits?
ANALYSIS
Where the sole issue on appeal is the trial court’s application of law, this [232]*232court reviews the judgment de novo. A.J. Chromy Construction Co. v. Commercial Mechanical Services, Inc., 260 N.W.2d 579, 582 (Minn.1977). The trial court in this case construed the Minnesota No-Fault Automobile Insurance Act, Minn.Stat. §§ 65B.41-.71 (1986), as imposing liability on a self-insurer up to its self-insured retention limits. We believe this result is inconsistent with the no-fault act and with Minnesota case law.
The source of Altra’s obligation to provide coverage is the statutory mandate that every owner of a vehicle licensed in this state maintain a plan of reparation security under terms approved by the insurance commissioner. Minn.Stat. § 65B.48, subd. 1. The reparation plan must insure against loss resulting from liability imposed by law for injury sustained by any person arising out of the operation of the vehicle. Id. The reparation plan must contain stated limits of liability, not less than $30,000 for bodily injury per person, and $60,000 per accident. Minn.Stat. § 65B.49, subd. 3.
The requirement to maintain a reparation plan may be satisfied by registering and qualifying as a self-insurer. Minn.Stat. § 65B.48, subd. 2. Self-insurance is effected by filing with the insurance commissioner documents demonstrating the following:
(1) a continuing undertaking by the owner or other appropriate person to pay tort liabilities or basic economic loss benefits, or both, and to perform all other obligations imposed by sections 65B.41 to 65B.71;
(2) evidence that appropriate provision exists for prompt administration of all claims, benefits, and obligations provided by sections 65B.41 to 65B.71;
(3) evidence that reliable financial arrangements, deposits, or commitments exist providing assurance, substantially equivalent to that afforded by a policy of insurance complying with sections 65B.41 to 65B.71, for payment of tort liabilities, basic economic loss benefits, and all other obligations imposed by sections 65B.41 to 65B.71; and
(4)a nonrefundable application fee of $500.
Minn.Stat. § 65B.48, subd. 3 (1986).
The commissioner is empowered to adopt rules to assure the adequacy of the financing and administration of self-insurance plans. Minn.Stat. § 65B.48, subd. 3a. These rules are designed to ensure that self-insurers “have the financial and administrative resources needed to satisfy all obligations and responsibilities” under the No-Fault Act. Minn.R. 2770.6100 (1985).
Altra’s self-insurance plan was effected by filling out a form developed by the insurance commissioner. The form nowhere requests that the self-insurer provide express liability limits. However, the form requests the following:
List all excess insurance applicable to motor vehicle accidents, with name(s) of insurer(s), policy number(s) and limits of liability.
Altra provided the following information:
Lexington Insurance Company Policy No. 552 8742 Effective: 12-31-86/87 Amount of Insurance: $2,500,000 in excess of $500,000 S.I.R. [self-insured retention]
Allstate’s argument is that Al-tra’s statement that it had $500,000 of self-insured retention is a statement of intent to provide $500,000 of liability coverage to each accident. We disagree for several reasons. First, a self-insurance plan is not construed strictly against the drafter, as insurance policies are. Anderson v. Northwestern Bell Telephone Co., 443 N.W.2d 546, 549 (Minn.App.1989).
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OPINION
SHORT, Judge.
Altra Auto Rental, Inc., a division of Agency Rent-A-Car, Inc. (Altra), appeals the trial court’s determination that Altra’s self-insurance plan provides primary liability coverage in this action up to the full amount of its self-insured retention, $500,-000. Altra argues that it should provide primary liability coverage only in the amount mandated by statute, $30,000 per person and $60,000 per accident. We agree and reverse.
FACTS
The facts of this case are not in dispute. In 1986, four college-aged women planned to take a spring vacation to Padre Island in Texas. One of them, Shannon Murphy, contacted Altra, inquiring about renting a car. The agent told Murphy the least expensive rental rate could be obtained if the rental car were a substitute for an out-of-service vehicle owned and insured by the renter. Murphy told the agent that another of the foursome, Michelle McClain, had an out-of-service Volkswagen. The agent delivered the rental car on March 21. McClain was not available, so Christine Meyers, the only member of the group over age 21, signed the rental agreement. Meyers and Murphy informed the agent that McClain had an insurance policy with Fireman’s Fund Insurance. The agent later filled in the rental form with an invented policy number, agent’s name, and agency phone number. The form indicated that Altra did not provide liability insurance, and that the vehicle was to be insured by the lessee.
On March 30, at 4:00 a.m., the four women were passing through Missouri on their way back to Minnesota. Respondent Bridget Begley fell asleep at the wheel, and collided with a vehicle parked at the side of the interstate. McClain, riding in the front passenger seat, was killed. When the rental agent learned of the accident, he blotted out the false information on the rental form.
Claudia McClain, trustee for the heirs of Michelle McClain, brought a wrongful death action against Begley, Meyers, and Altra. Begley was insured on her parent’s policy with Allstate. Altra commenced a declaratory judgment action against Allstate and Fireman’s Fund to determine the priority of coverage. The claim against Fireman’s Fund was dismissed, apparently because McClain did not have a valid policy with Fireman’s at the time of the rental.
McClain, Begley, Meyers and Allstate moved for partial summary judgment in the wrongful death action, seeking a declaration that Altra provided primary liability coverage up to its self-insured retention limit of $500,000. The trial court granted the motion, and this court denied a petition for discretionary review.
The parties then stipulated that McClain’s death was caused by Begley’s negligence, that the total amount of damages was $155,000, and that the wrongful death and declaratory judgment actions would be consolidated. Judgment was entered accordingly. The sole issue on appeal is the extent of Altra’s liability. Altra argues it is liable only in the amount statutorily mandated, or $30,000, and that Allstate is secondarily liable for its full amount of coverage, $100,000. Under this scenario, McClain’s estate will go uncompensated for $25,000. Respondents argue that Altra is liable to the limits of its self-insured retention, or $500,000. Under this scenario, McClain’s estate will be fully compensated for the stipulated amount of damages, and Allstate will have no liability.
ISSUE
Is a self-insurer liable to the limits of its self-insured retention if it fails to specify lower liability limits?
ANALYSIS
Where the sole issue on appeal is the trial court’s application of law, this [232]*232court reviews the judgment de novo. A.J. Chromy Construction Co. v. Commercial Mechanical Services, Inc., 260 N.W.2d 579, 582 (Minn.1977). The trial court in this case construed the Minnesota No-Fault Automobile Insurance Act, Minn.Stat. §§ 65B.41-.71 (1986), as imposing liability on a self-insurer up to its self-insured retention limits. We believe this result is inconsistent with the no-fault act and with Minnesota case law.
The source of Altra’s obligation to provide coverage is the statutory mandate that every owner of a vehicle licensed in this state maintain a plan of reparation security under terms approved by the insurance commissioner. Minn.Stat. § 65B.48, subd. 1. The reparation plan must insure against loss resulting from liability imposed by law for injury sustained by any person arising out of the operation of the vehicle. Id. The reparation plan must contain stated limits of liability, not less than $30,000 for bodily injury per person, and $60,000 per accident. Minn.Stat. § 65B.49, subd. 3.
The requirement to maintain a reparation plan may be satisfied by registering and qualifying as a self-insurer. Minn.Stat. § 65B.48, subd. 2. Self-insurance is effected by filing with the insurance commissioner documents demonstrating the following:
(1) a continuing undertaking by the owner or other appropriate person to pay tort liabilities or basic economic loss benefits, or both, and to perform all other obligations imposed by sections 65B.41 to 65B.71;
(2) evidence that appropriate provision exists for prompt administration of all claims, benefits, and obligations provided by sections 65B.41 to 65B.71;
(3) evidence that reliable financial arrangements, deposits, or commitments exist providing assurance, substantially equivalent to that afforded by a policy of insurance complying with sections 65B.41 to 65B.71, for payment of tort liabilities, basic economic loss benefits, and all other obligations imposed by sections 65B.41 to 65B.71; and
(4)a nonrefundable application fee of $500.
Minn.Stat. § 65B.48, subd. 3 (1986).
The commissioner is empowered to adopt rules to assure the adequacy of the financing and administration of self-insurance plans. Minn.Stat. § 65B.48, subd. 3a. These rules are designed to ensure that self-insurers “have the financial and administrative resources needed to satisfy all obligations and responsibilities” under the No-Fault Act. Minn.R. 2770.6100 (1985).
Altra’s self-insurance plan was effected by filling out a form developed by the insurance commissioner. The form nowhere requests that the self-insurer provide express liability limits. However, the form requests the following:
List all excess insurance applicable to motor vehicle accidents, with name(s) of insurer(s), policy number(s) and limits of liability.
Altra provided the following information:
Lexington Insurance Company Policy No. 552 8742 Effective: 12-31-86/87 Amount of Insurance: $2,500,000 in excess of $500,000 S.I.R. [self-insured retention]
Allstate’s argument is that Al-tra’s statement that it had $500,000 of self-insured retention is a statement of intent to provide $500,000 of liability coverage to each accident. We disagree for several reasons. First, a self-insurance plan is not construed strictly against the drafter, as insurance policies are. Anderson v. Northwestern Bell Telephone Co., 443 N.W.2d 546, 549 (Minn.App.1989). Thus, we review the form in the light of the purposes it was intended to serve, i.e., to assure the state that Altra would be able to meet its burden to provide the statutorily required coverage. Id. Second, Altra’s statement that it had $500,000 of self-insured retention was not responsive to the question asked. It would be ironic if Al-. tra’s gratuitous provision of unrequested information became the basis of an obligation to pay $125,000 more than the legal obligation it carried. The statement that Altra was obligated to provide $500,000 of [233]*233coverage before invoking its excess insurance plan does not logically imply that Al-tea intended to provide coverage in each accident for that amount. It is obvious that Altea did not intend this entry .as its “stated limits of liability,” required by Minn.Stat. § 65B.49, subd. 3. Further, it can hardly be suggested that McClain relied on the self-insurance plan in failing to obtain her own insurance. The self-insurance form is not intended to create obligations between the public and the self-insurer. Rather, it assures the state that the self-insurer can meet the obligations imposed by statute.
Our conclusion is bolstered by the insurance commissioner’s conclusion that Altea was in violation of the no-fault act because it had not maintained a plan of reparation security on its vehicles. The commissioner specifically concluded Altea had not provided liability coverage as required by Minn. Stat. § 65B.49, subd. 3. The commissioner revoked Altra’s self-insurance authorization, pursuant to its statutory authority.
The next logical issue is what consequences should follow from Altra’s failure to provide specific liability limits. The commissioner has already taken administrative action against Altea, and we have no authority to take further punitive measures. We note that the insurance commissioner could prevent disputes such as the one before us by requiring self-insurers to state express coverages in their self-insurance plan. The commissioner could reject requests for self-insurance that do not contain express limits of coverage.
This court has previously determined that in the absence of specific limits of underinsured motorist (UIM) coverage in a self-insurance plan, the statutory minimum will be imposed by law. Anderson, 443 N.W.2d at 548. UIM coverage, like liability coverage, must be contained in all plans of reparation security. Minn.Stat. § 65B.49, subd. 3a(l). Thus, in Anderson this court refused to penalize the self-insurer for its failure to provide express limits on its UIM coverage. Instead, this court imposed the statutorily required minimum amounts of coverage. Anderson, 443 N.W.2d at 548.
Similarly, we hold that in the absence of express limitations on liability coverage contained in a self-insurance plan, the statutory minimum amount of coverage will be imposed. This court held in State Farm Mutual Automobile Insurance Co. v. Budget Rent-A-Car Systems, Inc., 359 N.W.2d 673, 676 (Minn.App.1984) that a rental agency is primarily liable for liability coverage, up to its full self-insured retention amount of $100,000, and the driver’s insurer is secondarily liable. The argument made here, that the rental agency's liability should be limited to the statutory minimum amount of coverage, was not addressed in State Farm Mutual. It is possible that the self-insurance plan there expressly provided for $100,000 of coverage for each accident — the opinion does not provide this information. The holding in State Farm Mutual, therefore, is not inconsistent with our holding in this case.
DECISION
In the absence of express limitations on liability coverage contained in its self-insurance plan, a self-insurer is liable only in the amounts mandated by statute.
Reversed.
NORTON, J., dissents.