ACCEPTED 15-25-00107-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/20/2025 4:21 PM No. 15-25-00107-CV CHRISTOPHER A. PRINE CLERK __________________________________________________________________ FILED IN 15th COURT OF APPEALS IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 6/20/2025 4:21:29 PM __________________________________________________________________ CHRISTOPHER A. PRINE Clerk
TEXAS DEPARTMENT OF INSURANCE, AND CASSIE BROWN, IN HER CAPACITY AS COMMISSIONER OF THE TEXAS DEPARTMENT OF INSURANCE,
Appellants,
v.
TEXAS LAND TITLE ASSOCIATION,
Appellee. __________________________________________________________________ On Appeal from the 345th Judicial District Court Travis County, Texas Cause No. D-1-GN-25-001663 __________________________________________________________________
APPELLEE’S UNOPPOSED EMERGENCY MOTION FOR TEMPORARY RELIEF UNDER TEX. R. APP. P. 29.3 __________________________________________________________________
Appellee, Texas Land Title Association (“TLTA”), files this unopposed
request for emergency relief on the grounds set forth below.
I. SUMMARY OF EMERGENCY MOTION
Appellants issued a rate order on February 6, 2025, (the “Order”)1 reducing title
insurance premium rates by 10% effective July 1, 2025. The Order states that the rate
1 Attached hereto as Exhibit A.
-1- 4046730.v2 cut is effective starting on July 1, 2025. TLTA sought a temporary injunction, alleging
that the Order would cause irreparable harm to the Texas title insurance industry,
represented by TLTA. TDI disputed TLTA’s claim.
After a two-day hearing on May 27 and 28, 2025, on TLTA’s requested
temporary injunction and the Texas Department of Insurance's ("TDI’s") plea to the
jurisdiction, the trial court granted TLTA’s requested temporary injunction preventing
the proposed reduced rates from going into effect on July 1, 2025, until further orders
of the court. The trial court also granted TLTA’s petition for review of the TDI Order,
remanded the matter to TDI for further proceedings, and made other orders regarding
the merits of the Order.
As an arm of the State, Appellants’ Notice of Appeal 2 to this Court has the effect
of superseding (staying) the injunction. Due to the timing of the filings of the notice
of appeal, this stay would come less than two weeks before the rate decrease would
otherwise go into effect. See In Re Tex. Educ. Agency, 619 S.W.3d 679, 680 (Tex.
2021). TLTA seeks emergency relief from this Court—i.e., reinstating the temporary
injunction or lifting the stay of the temporary injunction during the pendency of this
appeal to preserve the status quo and prevent irreparable harm to TLTA and its
2 Attached hereto as Exhibit B.
-2- 4046730.v2 members. See id. (confirming a court of appeals’ power to stay a state agency’s
supersedeas and reinstate the injunction under Tex. R. App. P. 29.3).
The requested relief is necessary to preserve the parties’ rights pending the
appeal. On June 12, 2025, TDI notified Texas title agents and companies that the Order
is enjoined and to use the prior rates until further notice. See June 12, 2025 TDI Notice,
available at https://content.govdelivery.com/accounts/TXINSUR/bulletins/3e4c842,
attached hereto as Exhibit C. Given this statewide current guidance from TDI being
relied on by title companies, it would be very difficult for Texas title agents and
underwriters to now revert to the approved reduced rates and honor the Feb 6th rate
Order on July 1st due to the time it takes to implement rate changes through pricing
software and otherwise.
The relief sought by TLTA in this motion would, while leaving in place the stay
of the trial court’s ruling on TLTA’s Petition for Review, the stay of the trial court’s
ruling remanding the matter for further proceedings, and the stay of the trial court’s
rulings on other issues in the trial court’s order, would, in a surgical emergency order,
lift the stay of the trial court’s temporary injunction solely concerning the rate order
going into effect on July 1st. This would leave in place the stay in the Court of Appeals
resulting from Appellant’s filing of the notice of appeal on the trial court’s rulings now
before the Court, while preserving the rights of the parties under the trial court’s
temporary injunction.
-3- 4046730.v2 Appellants do not oppose the relief sought in this motion. They filed a Notice of
Appeal to preserve their appellate rights on the merits, but they do not oppose TLTA’s
request for the Feb 6, 2025 rate Order to be stayed during the pendency of this appeal.
II. FACTUAL BACKGROUND In Texas, title insurance premium rates are set by the Texas insurance
commissioner. See generally, Tex. Ins. Code, Chapter 2703. In this appeal, the
Commissioner reduced premium rates by 10% after a public hearing held January 23,
2025, and a hearing announcing the reduction on February 6, 2025. After the
Commissioner denied its motion for rehearing, TLTA filed suit in Travis County
district court. TLTA sought declaratory relief under Tex. Gov’t Code § 2001.038, and
also an appeal (petition for review) of the rate order under Tex. Ins. Code § 36.202.
TLTA also sought a temporary injunction to forestall application of the Order on
grounds that it would cause irreparable harm to an industry that was already suffering
the effects of a sharp and persistent market downturn. In response, TDI filed a plea
to the jurisdiction and a response to the request for injunction.
A two-day hearing was held on the temporary injunction and on TDI’s plea to
the jurisdiction on May 27-28 in the trial court.
-4- 4046730.v2 Two days following the close of evidence the trial court entered an order
granting TLTA’s the temporary injunction. However, the court also granted TLTA’s
petition for review and remanded the Order to TDI for further proceedings. The trial
court also ruled on other merits issues and set the remainder of the case for trial on
December 1, 2025.
Appellants filed their Notice of Appeal on June 19, 2025, which had the effect
of automatically superseding (or staying) the injunction. Their Notice of Appeal
also stayed the trial court’s orders granting the Petition for Review, remanding the
case for additional proceedings, ruling on other merits issues, and setting the case
for a December hearing. The stay of the trial court’s granting of TLTA’s requested
temporary injunction is the only issue included in this emergency motion under Tex.
R. App. P. 29.3.3
TLTA seeks an emergency ruling granting temporary relief under Tex. R.
App. P. 29.3 to remove the stay of the trial court’s temporary injunction that resulted
from TDI’s filing of its notice of appeal. TLTA seeks this removal of the stay to
preserve TLTA’s and its member’s rights under the trial court’s temporary
injunction until disposition of this appeal. TLTA does not seek an emergency ruling
granting temporary relief in this motion from the stay in the Court of Appeals of the
3 The trial court’s Order Granting Plaintiff’s First Amended Application For Temporary Injunction is attached hereto as Exhibit D.
-5- 4046730.v2 trial court’s rulings on TLTA’s petition for review, on the trial court’s remand to the
Department for additional proceedings, or of the stay in the Court of Appeals of any
of the other issues addressed by the trial court in her May 30, 2025, Order Granting
III. ARGUMENTS AND AUTHORITIES
Tex. R. App. P. 29.3 applies to interlocutory appeals such as this one and allows
the court of appeals to enter temporary orders to preserve the parties’ rights pending
disposition of the appeal. It is especially appropriate in cases where no supersedeas
bond is required because the appealing party is an arm of the State as here. See In Re
Tex. Educ. Agency, 619 S.W.3d 679, 680 (Tex. 2021). The Texas Supreme Court in
In Re Tex. Educ. Agency explained that an order by the court of appeals staying the
effect of the automatic supersedeas “preserve[d] the status quo and prevent[ed]
irreparable harm.” 616 S.W.3d at 680.
The requested emergency order is necessary in this instance to preserve the
parties’ rights until disposition of this pending appeal. The reduced rates approved in
the Order will take effect on July 1, 2025, unless stayed by the trial court’s injunction
or an emergency order from this Court. For title companies, implementing a rate
change, re-programming pricing software, and trying to implement the math of the
new rates in Ex. A of the rate Order, all takes time. Recognizing this, TDI issued
guidance on its website before filing its notice of appeal that, due to the temporary
-6- 4046730.v2 injunction, the pre-Order rates should be used even on and after July 1. The discord
that would result between Appellants’ public guidance to title companies and the legal
effect of the stay of the trial court’s temporary injunction caused by Appellant’s fling
of its notice of appeal, creates a need for emergency relief to preserve the parties’ rights
pending disposition of this appeal. And again, Appellants do not oppose the emergency
relief sought herein.
IV. CONCLUSION AND PRAYER
For the reasons stated herein, Appellee TLTA prays for emergency relief from
this Court under TRAP 29.3 lifting the stay resulting from Appellant’s filing of their
notice of appeal on June 19, 2025 from the trial court’s temporary injunction.
Alternatively, TLTA prays for emergency relief from this Court under TRAP 29.3,
approving during the pendency of this appeal the temporary injunction approved by
the trial court in her May 30, 2025, Order Granting Temporary Injunction.
-7- 4046730.v2 Respectfully submitted,
By /s/ Ray Chester Ray C. Chester State Bar No. 04189065 Andrew M. Edge State Bar No. 24071446 McGinnis Lochridge LLP 1111 W. 6th Street, Bldg. B, Suite 400 Austin, Texas 78703 (512) 495-6000 (512) 495-6093 (Fax) rchester@mcginnislaw.com aedge@mcginnislaw.com
ATTORNEYS FOR APPELLEE
-8- 4046730.v2 VERIFICATION
I am lead counsel for Appellee, Texas Land Title Association, in Cause No.
D-1-GN-25-001663. I was present at the Temporary Injunction hearing on May 27-
28, 2025, and for all other proceedings in this matter. I have read the foregoing
Emergency Motion for Temporary Relief Under Tex R. App. P. 29.3, and every
factual statement made therein is within my personal knowledge and is true and
correct. Additionally, with regard to the attached exhibits, I declare as follows:
Exhibit A: This is a true and correct copy of the Texas Department of Insurance Official Order No. 2025-9125, dated February 6, 2025.
Exhibit B: This is a true and correct copy of Appellants’ Notice of Appeal to the Fifteenth Court of Appeals, filed in the trial court proceeding, Cause No. D-1-GN-25-001663, dated June 19, 2025.
Exhibit C: This is a true and correct copy of the Texas Department of Insurance notice that rates under Order 2025-9125 will not go into effect on July 1, 2025.
Exhibit D: This is a true and correct copy of the trial court’s Order Granting Texas Land Title Association’s First Amended Application for Temporary Injunction, dated May 30, 2025.
My name is Ray Chester, my date of birth is August 26, 1955, and my address
is 1111 W. 6th Street, Bldg. B, Suite 400, Austin, Texas 78703. I declare under
penalty of perjury that the foregoing is true and correct.
-9- 4046730.v2 This Verification is made under Tex. Civ. Prac. & Rem. Code 132.001 in
support of Texas Land and Title Association’s Emergency Motion For Temporary
Relief Under Tex. R. App. P. 29.3.
Executed in Travis County, State of Texas on June 20, 2025,
Ray Chester
- 10 - 4046730.v2 CERTIFICATE OF CONFERENCE
I hereby certify that pursuant to Tex. R. App. P. 29.3, on the 20th day of
June, 2025, I conferred with James Brazell, counsel for Appellants, and Appellants
do not oppose the relief sought in this motion.
CERTIFICATE OF SERVICE
I hereby certify that on the 20th day of June, 2025, I electronically filed the
above and foregoing document, which will send notification of such filing to:
James Z. Brazell Administrative Law Division Office of the Attorney General of Texas P. O. Box 12548, Capitol Station Austin, Texas 78711-2548 James.Brazell@oag.texas.gov
- 11 - 4046730.v2 EXHIBIT A No. 2025-9125
Official Order of the Texas Commissioner of Insurance
Date: 02/06/2025
Subject Considered:
Title Insurance Basic Premium Rates Hearing Docket No. 2851 Petition Nos. P-1124-02 and P-1124-03
General Remarks and Official Action Taken:
The subjects of this order are the two requests to consider title insurance basic premium rates under Insurance Code § 2703.202 filed by the Texas Land Title Association (TLTA) and the Office of Public Insurance Counsel (OPIC). The commissioner sets the title insurance basic premium rates by order following a public hearing. After consideration of each matter presented in writing and orally at a public hearing, the commissioner fixes a new title insurance premium rate.
The following findings of fact and conclusions of law are adopted.
Findings of Fact
1. On September 16, 2024, the Texas Department of Insurance (TDI) published its 2024 Title Rate Report on its website. The report provides rate indications based on title experience data ending in calendar year 2022 ranging from î4.9% to î15.4%.
2. On November 1, 2024, TDI received TLTA's request to consider the title insurance basic premium rates. TLTA proposed that there be no change in the rates. Alternatively, if rates are decreased, TLTA proposed that the decrease should not be more than î1.0% and effective on July 1, 2025. In a supplemental submission provided to TDI on January 14, 2025, TLTA concluded that a rate decrease in the 2025-9125 Commissioner’s Order 2025 Title Insurance Basic Premium Rates Hearing - Docket No. 2851 Page 2 of 8
range of 0.0% to î4.7% is reasonable, but in light of data it collected on a sampling of 37 title agents' 2023 experience, suggested that a 0.0% change is most appropriate.
3. TDI assigned TLTA's request for a public hearing Petition No. P-1124-02.
4. TDI issued a notice of public hearing on TLTA's request. The notice was posted on TDI's website on November 8, 2024, and published in the November 22, 2024, issue of the Texas Register (49 TexReg 9608).
5. On November 12, 2024, TDI received OPIC's request to consider the title insurance basic premium rates. OPIC requested that TDI hold the hearing requested by TLTA, but disagreed with TLTA that the basic premium rates should not be changed. In a supplemental submission provided to TDI on January 22, 2025, OPIC concluded that a rate decrease in the range of î8.9% to î19.0% is indicated based on historical experience and is actuarially sound.
6. TDI assigned OPIC's request for a public hearing Petition No. P-1124-03.
7. Because of a forecasted snowstorm for Austin and much of the state, the commissioner postponed the hearing that was initially scheduled for January 21, 2025, until January 23, 2025, under Government Code § 551.0411.
8. On January 23, 2025, the commissioner conducted a public hearing under Insurance Code § 2703.202(c), under Docket No. 2851. Interested people attended the hearing and had the opportunity to present written and oral testimony. TLTA, OPIC, and TDI staff presented exhibits, analyses, and rate calculations summarizing and referencing the reports that each had previously submitted to the commissioner.
9. Under Insurance Code § 2703.152, when fixing a premium rate, the commissioner must "consider all relevant income and expenses of title insurance companies and title insurance agents attributable to engaging in the business of title insurance." The premium rates must be "reasonable as to the public" and "nonconfiscatory as to title insurance companies and title insurance agents." Insurance Code § 2703.152. 2025-9125 Commissioner’s Order 2025 Title Insurance Basic Premium Rates Hearing - Docket No. 2851 Page 3 of 8
Income and Expenses of Title Insurance Companies and Agents
10. The reports from TLTA, OPIC, and TDI each included a description of the actuarial methods they used to determine whether a change to the basic premium rates is indicated.
11. All three reports included rate indications determined using the loss ratio method. The loss ratio method takes into account the title industry's expense ratio, the loss and loss adjustment expense (LAE) ratio, the catastrophe loss provision, and the profit provision. 1
a. To determine the expense ratio, the reports compiled data on expenses related to the business of title insurance and divided that by the amount of premium collected. The expense ratio provides for all reasonable costs associated with a title insurance policy other than profits and losses.
b. To determine the loss and loss adjustment expense ratio, the reports compiled data on losses and loss adjustment expenses and divided that by the amount of premium collected.
c. The catastrophe loss provision is selected to account for the possibility of the market experiencing widespread losses that are significantly higher than what has been experienced historically.
d. To determine the profit provision, the reports first determined a target cost of capital. Returns from investments are subtracted from the target cost of capital and then adjusted for the industry's premium-to-capital leverage ratio.
e. To determine the expense ratio, the loss and loss adjustment expense ratio, and the catastrophe loss provision, TLTA, OPIC, and TDI used data submitted to TDI under Insurance Code § 2703.153.
1 The formula for the rate indication using the loss ratio method is: [(L+E+C)/(1-P)] - 1 Where L = loss and loss adjustment expense ratio = losses and LAE/premium; E = expense ratio = expenses/premium; C = catastrophe loss provision; and P = underwriting profit provision = profit/premium. 2025-9125 Commissioner’s Order 2025 Title Insurance Basic Premium Rates Hearing - Docket No. 2851 Page 4 of 8
12. The reports from TLTA, OPIC, and TDI each contained multiple rate indications using the loss ratio method. The various rate indications make up the reports' ranges. The main difference in the indications are from the profit provisions and experience periods used.
a. For the profit provision, TLTA used 12.0%, OPIC used 7.0%, and TDI used 11.0%. These differences are mainly from the values used for the target cost of capital and the size premium adjustments. OPIC asserts that Texas title insurance is less risky and less variable than the average line of property and casualty insurance, so a lower cost of capital is reasonable, and no size premium adjustment is needed.
b. OPIC and TDI provided indications that used 5-year, 10-year, 15-year, and 20-year experience periods; each ending in 2022. In general, a shorter period tends to be responsive to recent market conditions in the experience period, whereas a longer period tends to capture a broad spectrum of economic conditions.
c. TLTA's indications used a 3-year period ending in 2019, a 5-year period ending in 2019, and a 20-year period ending in 2022. TLTA stated its experience periods avoid giving too much weight to the pandemic periods of 2020–2022, which were outlier years.
d. TLTA also provided an indication using a standalone estimate of the 2023 expense ratio because it asserted that the available data through 2022 does not include the full impact from the downturn in the title insurance market that started in the fall of 2022. Because TDI has not received all 2023 data under Insurance Code § 2703.153, 2 TLTA surveyed 37 agents that it said make up about 50% of total Texas premiums and used that data to estimate the expense ratio for 2023.
e. TLTA also provided an indication using linear regression. It created a scatter plot of the expense ratio and retained premium data between 1998 and 2022 and then determined a line of best fit to estimate the expense ratio on the basis of on-level retained premiums.
2 While the deadline to submit the data has passed as of the date of this order, TDI is working with agents and agencies that missed the deadline or that need to provide data corrections. 2025-9125 Commissioner’s Order 2025 Title Insurance Basic Premium Rates Hearing - Docket No. 2851 Page 5 of 8
f. TDI and OPIC used the same experience periods, resulting in them using the same expense ratios, averaging 77.0%. TLTA's expense ratios were mostly higher, averaging 81.7%; this was attributable to the different experience periods and methods TLTA used.
g. The loss and loss adjustment expense ratios used by all parties were similar, 2.3% for TLTA and 2.0% for OPIC and TDI, since this ratio shows little volatility over the various experience periods.
h. For the catastrophe loss provision, all parties used 1.0%.
13. The various actuarial methods yielded the following results:
Loss Ratio Methods TLTA OPIC TDI 5-year ending 2022 î19.0% î15.4% 10-year ending 2022 î15.6% î11.8% 15-year ending 2022 î12.5% î8.6% 20-year ending 2022 î3.8% î8.9% î4.9% 5-year ending 2019 î4.6% 3-year ending 2019 î4.7% Linear regression î4.0% 2023 estimate 0.0% Overall range 0.0% to î4.7% -8.9% to î19.0% î4.9% to î15.4%
14. The commissioner has reviewed and evaluated all the information submitted in the TLTA, OPIC, and TDI reports. This information reflects the relevant income and expenses experienced by all title insurance companies and title insurance agents engaged in the business of title insurance in Texas.
Reasonable as to the Public
15. In recent history, the title industry's actual profit ratio has been consistently, and at times dramatically, above the target profit ratio used in setting the basic premium rates. The actual profit ratios earned by title agents and underwriters in Texas over different periods are as follows: 2025-9125 Commissioner’s Order 2025 Title Insurance Basic Premium Rates Hearing - Docket No. 2851 Page 6 of 8
Years of Data Included Average Profit Ratio 2003–2022 (20 years) 17.5% 2008–2022 (15 years) 19.8% 2013–2022 (10 years) 24.6% 2018–2022 (5 years) 26.2% 2015–2019 (5 years) 22.2% 2022 (1 year) 26.6%
16. While the housing market saw a downturn in late 2022, due in part to increases in mortgage rates and median home prices, the average rate of return was 26.6%. When you compare this with the profit provisions used in TLTA's (12.0%), OPIC's (7.0%), and TDI's (11.0%) actuarial analyses, it shows that even as the market declines, there is a sizeable difference between what is considered an acceptable target for profit levels and the actual profits the market has been experiencing.
17. Sustaining the current levels of profits in the current real estate market with the current levels of inflation would not be reasonable as to the public. Texans are being affected by housing affordability across the state. A reduction in title insurance basic premium rates would likely help bring the actual profit ratio closer to the target.
Nonconfiscatory as to Title Insurance Companies and Agents
18. A confiscatory rate is one that is too low to allow a regulated company to "not only recover its operating expenses, but also to realize reasonable returns on its investments." 3
19. The commissioner did not receive "clear and convincing evidence" 4 that a reduction in rates would lead the average title insurance company or title insurance agent to experience insolvency or earn an unreasonable rate of return.
3 Geeslin v. State Farm Lloyds, 255 S.W.3d 786, 795 (Tex. App.—Austin 2008), citing Duquesne Light Co. v. Barasch, 488 U.S. 299, 307, 109 S.Ct. 609, 102 L.ED.2d 646 (1989); Railroad Comm'n v. Houston Natural Gas Corp., 155 Tex. 502, 289 S.W.2d 559, 572 (1956). 4 Id. at 795. 2025-9125 Commissioner’s Order 2025 Title Insurance Basic Premium Rates Hearing - Docket No. 2851 Page 7 of 8
20. Between 2020 and 2022, the title industry in Texas experienced significant growth. The COVID pandemic and a dramatic reduction in interest rates led to an unprecedented increase in housing purchases and refinances.
21. To accommodate that increase, agencies have expanded, and more agents have entered the market. Since 2019, the number of licensed title agents in Texas has grown by 29%—from 614 agents in 2019 to 794 agents in 2024.
22. Industry-wide premiums went from $2.27 billion in 2019, to $2.69 billion in 2020, and $3.69 billion in 2021. In 2022, there was a slight decline to $3.38 billion, and 2023 saw a return to pre-pandemic premium levels at $2.38 billion. While the market has declined, the industry is still collecting significant premium.
23. While the rates must be nonconfiscatory for the industry, that does not mean that every licensed agent and agency should expect the same level of profitability. The average profit must be reasonable, but, as OPIC noted in its report, that is likely to result in some agents making large profits while others do not. Irrespective of the basic premium rate, the downturn in the market may result in underperforming agents seeing a lack of profitability.
24. Aside from TLTA's method that included its sampling of 2023 data, each of the methods from TLTA, OPIC, and TDI indicated a reduction in rates from –4.7% to î19.0%. Those methods used profit provisions of 12.0%, 7.0%, and 11.0%, respectively; and each entity's report asserts that its respective profit provision would be a reasonable rate of return.
Conclusions of Law
1. The commissioner has jurisdiction over this matter under Insurance Code §§ 31.021, 2501.001–2501.008, 2551.003, and 2703.001–2703.208.
2. TDI gave proper and timely notice of the January 21, 2025, public hearing required by Insurance Code § 2703.203 and of its continuation to January 23, 2025, under Government Code § 551.0411.
3. Insurance Code § 2501.002 states that the purpose of the Texas Title Insurance Act is "to completely regulate the business of title insurance . . . to protect consumers and purchasers of title insurance policies and provide adequate and reasonable rates of return for title insurance companies and title insurance agents." 2025-9125 Commissioner’s Order 2025 Title Insurance Basic Premium Rates Hearing - Docket No. 2851 Page 8 of 8
4. Insurance Code § 2703.151 requires the commissioner to fix and promulgate the premium rates to be charged by title insurance companies and title insurance agents.
5. Insurance Code § 2703.152 states that when fixing premium rates, the commissioner must "consider all relevant income and expenses of title insurance companies and title insurance agents attributable to engaging in the business of title insurance." The premium rates must be "reasonable as to the public and nonconfiscatory as to title insurance companies and title insurance agents."
6. After considering the data collected under Insurance Code § 2703.153 and the reports provided by TLTA, OPIC, and TDI staff, the commissioner has determined that a 10% reduction in the title insurance basic premium rates takes all relevant income and expenses into account, is reasonable to the public, and is nonconfiscatory to title insurance companies and agents. This reduction will save Texas consumers an estimated $238 million per year.
Order
It is ordered that, effective July 1, 2025, title insurance companies and title insurance agents must use the basic premium rates reflected in Exhibit A.
_______________________________ Cassie Brown Commissioner of Insurance
Recommended and reviewed by:
_________________________________ Mark Worman, Deputy Commissioner
__________________________________ Jessica Barta, General Counsel 2025-9125
Exhibit A 2025-9125
TEXAS TITLE INSURANCE BASIC PREMIUM RATES ÍťôŜϙ(ƯôèťĖŽôϙVŪīƅϙ͐Ϡϙ͑͏͔͑ ĺīĖèƅϙ>Íèôϙ ĺīĖèƅϙ>Íèôϙ ĺīĖèƅϙ>Íèôϙ ĺīĖèƅϙ>Íèôϙ ıĺŪIJťϙŕϙťĺϙÍIJîϙ ÍŜĖèϙ ıĺŪIJťϙŕϙťĺϙÍIJîϙ ÍŜĖèϙ ıĺŪIJťϙŕϙťĺϙÍIJîϙ ÍŜĖèϙ ıĺŪIJťϙŕϙťĺϙÍIJîϙ ÍŜĖèϙ IIJèīŪîĖIJČ ŘôıĖŪı IIJèīŪîĖIJČ ŘôıĖŪı IIJèīŪîĖIJČ ŘôıĖŪı IIJèīŪîĖIJČ ŘôıĖŪı щ͔͑Ϡ͏͏͏ϙ щ͔͑͘ϙ щ͓͓Ϡ͏͏͏ щ͓͐͏ϙ щ͕͒Ϡ͏͏͏ щ͔͔͑ϙ щ͗͑Ϡ͏͏͏ щ͕͓͏ϙ ͔͑Ϡ͔͏͏ ͑͗͘ϙ ͓͓Ϡ͔͏͏ ͓͐͒ϙ ͕͒Ϡ͔͏͏ ͔͑͗ϙ ͗͑Ϡ͔͏͏ 644 ͕͑Ϡ͏͏͏ ͒͏͑ϙ ͓͔Ϡ͏͏͏ ͓͖͐ϙ ͕͓Ϡ͏͏͏ ͔͒͑ϙ ͗͒Ϡ͏͏͏ 648 ͕͑Ϡ͔͏͏ ͒͏͓ϙ ͓͔Ϡ͔͏͏ ͓͐͘ϙ ͕͓Ϡ͔͏͏ ͔͔͒ϙ ͗͒Ϡ͔͏͏ ͕͔͏ϙ ͖͑Ϡ͏͏͏ ͒͏͕ϙ ͓͕Ϡ͏͏͏ ͓͑͑ϙ ͕͔Ϡ͏͏͏ ͔͖͒ϙ ͓͗Ϡ͏͏͏ ͕͔͒ϙ ͖͑Ϡ͔͏͏ ͒͏͘ϙ ͓͕Ϡ͔͏͏ ͓͕͑ϙ ͕͔Ϡ͔͏͏ ͔͓͏ϙ ͓͗Ϡ͔͏͏ ͕͔͕ϙ ͑͗Ϡ͏͏͏ ͒͐͑ϙ ͓͖Ϡ͏͏͏ ͓͑͗ϙ ͕͕Ϡ͏͏͏ ͔͓͓ϙ ͔͗Ϡ͏͏͏ ͕͔͘ϙ ͑͗Ϡ͔͏͏ ͔͒͐ϙ ͓͖Ϡ͔͏͏ ͓͒͏ϙ ͕͕Ϡ͔͏͏ ͔͓͗ϙ ͔͗Ϡ͔͏͏ ͕͕͑ϙ ͑͘Ϡ͏͏͏ ͒͑͏ϙ ͓͗Ϡ͏͏͏ ͓͔͒ϙ ͕͖Ϡ͏͏͏ ͔͔͐ϙ ͕͗Ϡ͏͏͏ 664 ͑͘Ϡ͔͏͏ ͒͑͑ϙ ͓͗Ϡ͔͏͏ 438 ͕͖Ϡ͔͏͏ ͔͔͑ϙ ͕͗Ϡ͔͏͏ ͕͕͘ϙ ͒͏Ϡ͏͏͏ ͔͒͑ϙ ͓͘Ϡ͏͏͏ ͓͓͐ϙ ͕͗Ϡ͏͏͏ ͔͔͔ϙ ͖͗Ϡ͏͏͏ ͕͖͑ϙ ͒͏Ϡ͔͏͏ ͒͑͗ϙ ͓͘Ϡ͔͏͏ 444 ͕͗Ϡ͔͏͏ ͔͔͘ϙ ͖͗Ϡ͔͏͏ ͕͖͓ϙ ͒͐Ϡ͏͏͏ ͒͒͐ϙ ͔͏Ϡ͏͏͏ 446 ͕͘Ϡ͏͏͏ ͔͕͑ϙ ͗͗Ϡ͏͏͏ ͕͖͖ϙ ͒͐Ϡ͔͏͏ 334 ͔͏Ϡ͔͏͏ ͓͓͘ϙ ͕͘Ϡ͔͏͏ ͔͕͓ϙ ͗͗Ϡ͔͏͏ ͕͗͏ϙ ͒͑Ϡ͏͏͏ ͖͒͒ϙ ͔͐Ϡ͏͏͏ ͓͔͐ϙ ͖͏Ϡ͏͏͏ ͔͕͗ϙ ͗͘Ϡ͏͏͏ 684 ͒͑Ϡ͔͏͏ ͓͒͏ϙ ͔͐Ϡ͔͏͏ ͓͔͔ϙ ͖͏Ϡ͔͏͏ ͔͖͑ϙ ͗͘Ϡ͔͏͏ 686 ͒͒Ϡ͏͏͏ 343 ͔͑Ϡ͏͏͏ ͓͔͘ϙ ͖͐Ϡ͏͏͏ ͔͖͔ϙ ͘͏Ϡ͏͏͏ ͕͗͘ϙ ͒͒Ϡ͔͏͏ ͓͖͒ϙ ͔͑Ϡ͔͏͏ 463 ͖͐Ϡ͔͏͏ ͔͖͖ϙ ͘͏Ϡ͔͏͏ ͕͑͘ϙ ͓͒Ϡ͏͏͏ ͓͒͘ϙ ͔͒Ϡ͏͏͏ 464 ͖͑Ϡ͏͏͏ ͔͗͏ϙ ͐͘Ϡ͏͏͏ ͕͕͘ϙ ͓͒Ϡ͔͏͏ ͔͒͒ϙ ͔͒Ϡ͔͏͏ 468 ͖͑Ϡ͔͏͏ ͔͗͒ϙ ͐͘Ϡ͔͏͏ ͕͘͘ϙ ͔͒Ϡ͏͏͏ ͔͕͒ϙ ͔͓Ϡ͏͏͏ ͓͖͐ϙ ͖͒Ϡ͏͏͏ ͔͕͗ϙ ͑͘Ϡ͏͏͏ ͖͏͐ϙ ͔͒Ϡ͔͏͏ ͔͒͗ϙ ͔͓Ϡ͔͏͏ ͓͖͒ϙ ͖͒Ϡ͔͏͏ ͔͗͘ϙ ͑͘Ϡ͔͏͏ ͖͏͔ϙ ͕͒Ϡ͏͏͏ ͕͒͐ϙ ͔͔Ϡ͏͏͏ϙ ͓͖͕ϙ ͖͓Ϡ͏͏͏ ͔͑͘ϙ ͒͘Ϡ͏͏͏ ͖͏͖ϙ ͕͒Ϡ͔͏͏ ͕͔͒ϙ ͔͔Ϡ͔͏͏ ͓͖͘ϙ ͖͓Ϡ͔͏͏ ͔͕͘ϙ ͒͘Ϡ͔͏͏ ͖͐͐ϙ ͖͒Ϡ͏͏͏ ͕͖͒ϙ ͔͕Ϡ͏͏͏ 483 ͖͔Ϡ͏͏͏ ͔͘͘ϙ ͓͘Ϡ͏͏͏ ͖͐͑ϙ ͖͒Ϡ͔͏͏ ͖͒͐ϙ ͔͕Ϡ͔͏͏ 486 ͖͔Ϡ͔͏͏ ͕͏͐ϙ ͓͘Ϡ͔͏͏ ͖͕͐ϙ ͒͗Ϡ͏͏͏ ͖͓͒ϙ ͔͖Ϡ͏͏͏ ͓͗͘ϙ ͖͕Ϡ͏͏͏ ͕͏͓ϙ ͔͘Ϡ͏͏͏ ͖͑͐ϙ ͒͗Ϡ͔͏͏ ͖͖͒ϙ ͔͖Ϡ͔͏͏ ͓͑͘ϙ ͖͕Ϡ͔͏͏ ͕͏͖ϙ ͔͘Ϡ͔͏͏ ͖͓͑ϙ ͒͘Ϡ͏͏͏ ͖͒͘ϙ ͔͗Ϡ͏͏͏ ͓͕͘ϙ ͖͖Ϡ͏͏͏ ͕͐͏ϙ ͕͘Ϡ͏͏͏ ͖͔͑ϙ ͒͘Ϡ͔͏͏ 383 ͔͗Ϡ͔͏͏ ͓͗͘ϙ ͖͖Ϡ͔͏͏ϙ ͕͐͒ϙ ͕͘Ϡ͔͏͏ ͖͑͗ϙ ͓͏Ϡ͏͏͏ ͔͒͗ϙ ͔͘Ϡ͏͏͏ ͔͏͏ϙ ͖͗Ϡ͏͏͏ ͕͖͐ϙ ͖͘Ϡ͏͏͏ ͖͒͑ϙ ͓͏Ϡ͔͏͏ ͒͘͏ϙ ͔͘Ϡ͔͏͏ ͔͏͓ϙ ͖͗Ϡ͔͏͏ ͕͑͏ϙ ͖͘Ϡ͔͏͏ ͖͔͒ϙ ͓͐Ϡ͏͏͏ ͒͑͘ϙ ͕͏Ϡ͏͏͏ ͔͏͗ϙ ͖͘Ϡ͏͏͏ ͕͓͑ϙ ͗͘Ϡ͏͏͏ ͖͒͗ϙ ͓͐Ϡ͔͏͏ ͔͒͘ϙ ͕͏Ϡ͔͏͏ ͔͐͐ϙ ͖͘Ϡ͔͏͏ ͕͔͑ϙ ͗͘Ϡ͔͏͏ ͖͓͑ϙ ͓͑Ϡ͏͏͏ ͒͗͘ϙ ͕͐Ϡ͏͏͏ ͔͓͐ϙ ͗͏Ϡ͏͏͏ ͕͑͗ϙ ͘͘Ϡ͏͏͏ ͖͓͓ϙ ͓͑Ϡ͔͏͏ ͓͏͐ϙ ͕͐Ϡ͔͏͏ ͔͕͐ϙ ͗͏Ϡ͔͏͏ ͕͒͑ϙ ͘͘Ϡ͔͏͏ ͖͓͖ϙ ͓͒Ϡ͏͏͏ ͓͏͒ϙ ͕͑Ϡ͏͏͏ ͔͐͘ϙ ͗͐Ϡ͏͏͏ ͕͔͒ϙ ͐͏͏Ϡ͏͏͏ ͖͓͘ϙ ͓͒Ϡ͔͏͏ ͓͏͖ϙ ͕͑Ϡ͔͏͏ ͔͑͒ϙ ͗͐Ϡ͔͏͏ ͕͖͒ϙ 2025-9125
ĖťīôϙÍŜĖèϙŘôıĖŪıϙ ÍīèŪīÍťĖĺIJϙċĺŘϙĺīĖèĖôŜϙĖIJ (ƄèôŜŜϙĺċϙщ͐͏͏Ϡ͏͏͏
ŜĖIJČϙťēôϙťÍæīôϙæôīĺſϠϙÍŕŕīƅϙťēôŜôϙŜťôŕŜϙťĺϙîôťôŘıĖIJôϙæÍŜĖèϙŕŘôıĖŪıϙċĺŘϙŕĺīĖèĖôŜϙÍæĺŽôϙ щ͐͏͏Ϡ͏͏͏ϡ
ťôŕϙ͐ϙ IIJϙèĺīŪıIJϙϼ͐ϽϠϙƱIJîϙťēôϙŘÍIJČôϙťēÍťϙĖIJèīŪîôŜϙťēôϙŕĺīĖèƅЍŜϙċÍèôϙŽÍīŪôϟ ťôŕϙ͑ϙ ŪæťŘÍèťϙťēôϙŽÍīŪôϙĖIJϙèĺīŪıIJϙϼ͑ϽϙċŘĺıϙťēôϙŕĺīĖèƅЍŜϙċÍèôϙŽÍīŪôϟ ťôŕϙ͒ϙ aŪīťĖŕīƅϙťēôϙŘôŜŪīťϙĖIJϙťôŕϙ͑ϙæƅϙťēôϙŽÍīŪôϙĖIJϙèĺīŪıIJϙϼ͒ϽϠϙÍIJîϙŘĺŪIJîϙťĺϙťēôϙ IJôÍŘôŜťϙîĺīīÍŘϟ ťôŕϙ͓ϙ îîϙťēôϙŽÍīŪôϙĖIJϙèĺīŪıIJϙϼ͓ϽϙťĺϙťēôϙŘôŜŪīťϙĺċϙťēôϙŽÍīŪôϙċŘĺıϙťôŕϙ͒ϟ
ϼôôϙôƄÍıŕīôŜϙċĺīīĺſĖIJČϙťēôϙťÍæīôϟϽ
ĖťīôϙÍŜĖèϙŘôıĖŪıϙ ÍīèŪīÍťĖĺIJϙċĺŘϙĺīĖèĖôŜϙĖIJϙ(ƄèôŜŜϙĺċϙщ͐͏͏Ϡ͏͏͏ϙ
ϼ͐Ͻ ϼ͑Ͻ ϼ͒Ͻ ϼ͓Ͻ ĺīĖèƅϙÍIJČôϙ ŪæťŘÍèťϙ aŪīťĖŕīƅϙæƅ îî Ѐщ͐͏͏Ϡ͏͏͐ϙ- щ͐Ϡ͏͏͏Ϡ͏͏͏Ёϙ ͐͏͏Ϡ͏͏͏ϙ ͏ϟ͏͏͓͖͓ϙ щ͖͓͘ Ѐщ͐Ϡ͏͏͏Ϡ͏͏͐ϙ-щ͔Ϡ͏͏͏Ϡ͏͏͏Ёϙ ͐Ϡ͏͏͏Ϡ͏͏͏ϙ ͏ϟ͏͏͒͘͏ щ͔Ϡ͏͐͗ Ѐщ͔Ϡ͏͏͏Ϡ͏͏͐ϙ- щ͔͐Ϡ͏͏͏Ϡ͏͏͏Ёϙ ͔Ϡ͏͏͏Ϡ͏͏͏ϙ ͏ϟ͏͏͒͑͐ щ͑͏Ϡ͕͏͕ Ѐщ͔͐Ϡ͏͏͏Ϡ͏͏͐ϙ- щ͔͑Ϡ͏͏͏Ϡ͏͏͏Ёϙ ͔͐Ϡ͏͏͏Ϡ͏͏͏ϙ ͏ϟ͏͏͑͑͘ϙ щ͔͑Ϡ͖͕͒ Ѐщ͔͑Ϡ͏͏͏Ϡ͏͏͐ϙ- щ͔͏Ϡ͏͏͏Ϡ͏͏͏Ёϙ ͔͑Ϡ͏͏͏Ϡ͏͏͏ϙ ͏ϟ͏͏͖͐͒ щ͖͔Ϡ͔͕͘ Ѐщ͔͏Ϡ͏͏͏Ϡ͏͏͐ϙ- щ͐͏͏Ϡ͏͏͏Ϡ͏͏͏Ёϙ ͔͏Ϡ͏͏͏Ϡ͏͏͏ϙ ͏ϟ͏͏͓͐͑ щ͐͏͘Ϡ͖͕͘ Ѐ@ŘôÍťôŘϙťēÍIJϙщ͐͏͏Ϡ͏͏͏Ϡ͏͏͏Ёϙ ͐͏͏Ϡ͏͏͏Ϡ͏͏͏ϙ ͏ϟ͏͏͐͐͑ щ͖͐͐Ϡ͕͗͘
(ƄÍıŕīôŜϙċĺŘϙĺīĖèĖôŜϙĖIJϙ(ƄèôŜŜϙĺċϙщ͐͏͏Ϡ͏͏͏
(ƄÍıŕīôϙ͐ϡ ϼ͐ϽϙĺīĖèƅϙĖŜϙщ͕͑͗Ϡ͔͏͏ ϼ͑ϽϙŪæťŘÍèťϙщ͐͏͏Ϡ͏͏͏ϙѱѱѳϙщ͕͑͗Ϡ͔͏͏ϙ-щ͐͏͏Ϡ͏͏͏ϙѱѱѳϙôŜŪīťϙѱϙщ͕͐͗Ϡ͔͏͏ ϼ͒ϽϙaŪīťĖŕīƅϙæƅϙ͏ϟ͏͏͓͖͓ѱѱѳϙщ͕͐͗Ϡ͔͏͏ϙƄϙ͏ϟ͏͏͓͖͓ϙѱѱѳϙôŜŪīťϙѱϙщ͖͘͘ ϼ͓Ͻϙîîϙщ͖͓͘ϙѱѱѳϙщ͖͘͘ϙѭϙщ͖͓͘ϙѱѱѳϙ>ĖIJÍīϙôŜŪīťϙѱϙщ͐Ϡ͔͓͗
(ƄÍıŕīôϙ͑ϡ ϼ͐ϽϙĺīĖèƅϙĖŜϙщ͓Ϡ͕͗͑Ϡ͕͏͏ ϼ͑ϽϙŪæťŘÍèťϙщ͐Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙщ͓Ϡ͕͗͑Ϡ͕͏͏ϙ-щ͐Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙôŜŪīťϙѱϙщ͒Ϡ͕͗͑Ϡ͕͏͏ ϼ͒ϽϙaŪīťĖŕīƅϙæƅϙ͏ϟ͏͏͒͘͏ϙѱѱѳϙщ͒Ϡ͕͗͑Ϡ͕͏͏ϙƄϙ͏ϟ͏͏͒͘͏ϙѱѱѳϙôŜŪīťϙѱϙщ͓͐Ϡ͓͑͘ ϼ͓Ͻϙîîϙщ͔Ϡ͏͐͗ϙѱѱѳϙщ͓͐Ϡ͓͑͘ϙѭϙщ͔Ϡ͏͐͗ϙѱѱѳϙ>ĖIJÍīϙôŜŪīťϙѱϙщ͐͘Ϡ͓͑͘
(ƄÍıŕīôϙ͒ϡ ϼ͐ϽϙĺīĖèƅϙĖŜϙщ͐͏Ϡ͘͏͑Ϡ͗͏͏ ϼ͑ϽϙŪæťŘÍèťϙщ͔Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙщ͐͏Ϡ͘͏͑Ϡ͗͏͏ϙ-щ͔Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙôŜŪīťϙѱϙщ͔Ϡ͘͏͑Ϡ͗͏͏ ϼ͒ϽϙaŪīťĖŕīƅϙæƅϙ͏ϟ͏͏͒͑͐ϙѱѱѳϙщ͔Ϡ͘͏͑Ϡ͗͏͏ϙƄϙ͏ϟ͏͏͒͑͐ϙѱѱѳϙôŜŪīťϙѱϙщ͐͗Ϡ͓͗͘ ϼ͓Ͻϙîîϙщ͑͏Ϡ͕͏͕ϙѱѱѳϙщ͐͗Ϡ͓͗͘ϙѭϙщ͑͏Ϡ͕͏͕ϙѱѱѳϙ>ĖIJÍīϙôŜŪīťϙѱϙщ͒͘Ϡ͔͔͓ 2025-9125
(ƄÍıŕīôϙ͓ϡ ϼ͐Ͻ ĺīĖèƅϙĖŜϙщ͖͐Ϡ͔͑͘Ϡ͐͏͏ ϼ͑Ͻ ŪæťŘÍèťϙщ͔͐Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙщ͖͐Ϡ͔͑͘Ϡ͐͏͏ϙ-щ͔͐Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙôŜŪīťϙѱϙщ͑Ϡ͔͑͘Ϡ͐͏͏ ϼ͒Ͻ aŪīťĖŕīƅϙæƅϙ͏ϟ͏͏͑͑͘ѱѱѳϙщ͑Ϡ͔͑͘Ϡ͐͏͏ϙƄϙ͏ϟ͏͏͑͑͘ϙѱѱѳϙôŜŪīťϙѱϙщ͔Ϡ͔͕͑ ϼ͓Ͻ îîϙщ͔͑Ϡ͖͕͒ϙѱѱѳϙщ͔Ϡ͔͕͑ϙѭϙщ͔͑Ϡ͖͕͒ϙѱѱѳϙ>ĖIJÍīϙôŜŪīťϙѱϙщ͔͖Ϡ͑͘͘
(ƄÍıŕīôϙ͔ϡ ϼ͐Ͻ ĺīĖèƅϙĖŜϙщ͒͘Ϡ͔͒͐Ϡ͗͏͏ ϼ͑Ͻ ŪæťŘÍèťϙщ͔͑Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙщ͒͘Ϡ͔͒͐Ϡ͗͏͏ϙ- щ͔͑Ϡ͏͏͏Ϡ͏ϙ͏͏ϙѱѱѳϙôŜŪīťϙѱϙщ͓͐Ϡ͔͒͐Ϡ͗͏͏ ϼ͒Ͻ aŪīťĖŕīƅϙæƅϙ͏ϟ͏͏͖͐͒ϙѱѱѳϙщ͓͐Ϡ͔͒͐Ϡ͗͏͏ϙƄϙ͏ϟ͏͏͖͐͒ϙѱѱѳϙôŜŪīťϙѱϙщ͐͘Ϡ͕͕͑ ϼ͓Ͻ îîϙщ͖͔Ϡ͔͕͘ϙѱѱѳϙщ͐͘Ϡ͕͕͑ϙѭϙщ͖͔Ϡ͔͕͘ϙѱѱѳϙ>ĖIJÍīϙôŜŪīťϙѱϙщ͔͘Ϡ͔͑͗
(ƄÍıŕīôϙ͕ϡ ϼ͐Ͻ ĺīĖèƅϙĖŜϙщ͖͔Ϡ͒͏͏Ϡ͑͏͏ ϼ͑Ͻ ŪæťŘÍèťϙщ͔͏Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙщ͖͔Ϡ͒͏͏Ϡ͑͏͏ϙ-щ͔͏Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙôŜŪīťϙѱϙщ͔͑Ϡ͒͏͏Ϡ͑͏͏ ϼ͒Ͻ aŪīťĖŕīƅϙæƅϙ͏ϟ͏͏͓͐͑ϙѱѱѳϙщ͔͑Ϡ͒͏͏Ϡ͑͏͏ϙƄϙ͏ϟ͏͏͓͐͑ϙѱѱѳϙôŜŪīťϙѱϙщ͒͐Ϡ͖͒͑ ϼ͓Ͻ îîϙщ͐͏͘Ϡ͖͕͘ϙѱѱѳϙщ͒͐Ϡ͖͒͑ϙѭϙщ͐͏͘Ϡ͖͕͘ϙѱѱѳϙ>ĖIJÍīϙôŜŪīťϙѱϙщ͓͐͐Ϡ͕͐͗
(ƄÍıŕīôϙ͖ϡ ϼ͐Ͻ ĺīĖèƅϙĖŜϙщ͔͐͐Ϡ͔͑͏Ϡ͒͏͏ ϼ͑Ͻ ŪæťŘÍèťϙщ͐͏͏Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙщ͔͐͐Ϡ͔͑͏Ϡ͒͏͏ϙ- щ͐͏͏Ϡ͏͏͏Ϡ͏͏͏ϙѱѱѳϙôŜŪīťϙщ͔͐Ϡ͔͑͏Ϡ͒͏͏ ϼ͒Ͻ aŪīťĖŕīƅϙæƅϙ͏ϟ͏͏͐͐͑ϙѱѱѳϙщ͔͐Ϡ͔͑͏Ϡ͒͏͏ϙƄϙ͏ϟ͏͏͐͐͑ѱѱѳôŜŪīťϙѱϙщ͔͖Ϡ͓͏͏ ϼ͓Ͻ îîϙщ͖͐͐Ϡ͕͗͘ϙѱѱѳϙщ͔͖Ϡ͓͏͏ϙѭϙщ͖͐͐Ϡ͕͗͘ϙѱѱѳϙ>ĖIJÍīϙôŜŪīťϙѱϙщ͑͑͘Ϡ͕͑͘ EXHIBIT B 6/20/2025 12:00 AM Velva L. Price District Clerk Travis County Cause No. D-1-GN-25-001663 D-1-GN-25-001663 Rosa Oneal
TEXAS LAND TITLE ASSOCIATION, § IN THE DISTRICT COURT OF Plaintiff, § § v. § § TEXAS DEPARTMENT OF § TRAVIS COUNTY, TEXAS INSURANCE and CASSIE BROWN, § IN HER CAPACITY AS § COMMISSIONER OF THE TEXAS § DEPARTMENT OF INSURANCE, § Defendants. § 345TH JUDICIAL DISTRICT
NOTICE OF APPEAL TO THE FIFTEENTH COURT OF APPEALS
COME NOW Defendants, the Texas Department of Insurance and Cassie
Brown, in her capacity as Commissioner of the Texas Department of Insurance
(collectively “TDI”), through their counsel the Office of the Attorney General, and file
this, their Notice of Appeal:
1. This is an appeal of two judgments issued by Judge Daniella DeSeta
Lyttle, in the 261st Judicial District Court, Travis County, Texas, Cause Number
D-1-GN-25-001663, styled Texas Land Title Association v. Texas Department of
Insurance and Cassie Brown, in her capacity as Commissioner of the Texas
Department of Insurance. It is, on the issues under Texas Civil Practices and
Remedies Code section 51.014(a)(4) and (8), an accelerated interlocutory appeal.
2. The judgments appealed are the trial court’s Order Granting Plaintiff’s
First Amended Application for Temporary Injunction, signed and filed May 30, 2025,
[Attachment A] and the trial court’s Order Overruling Texas Department of Insurance and Cassie Brown’s First Amended Plea to the Jurisdiction, also signed
and filed May 30, 2025 [Attachment B].
3. The parties filing this appeal are Defendants, Texas Department of
Insurance and Cassie Brown, in her capacity as Commissioner of the Texas
Department of Insurance. The other party is Plaintiff Texas Land Title Association.
4. This appeal is taken to the Fifteenth Court of Appeals, Austin, Texas.
See Tex. Gov’t Code § 22.220(a) and (d) (providing that the Fifteenth Court of Appeals
has exclusive intermediate jurisdiction over a matter brought against a state
commission or against an employee of an agency in the executive branch arising out
of that employee's official conduct). This appeal does not meet any of the exceptions
found in Texas Government Code section 22.220(d)(1)(A)-(O).
5. On May 30, 2025, Judge Lyttle signed the Order Granting Plaintiff’s
First Amended Application for Temporary Injunction, granting a Temporary
Injunction in favor of the Plaintiffs and issuing other rulings including, but not
limited to, granting Plaintiff’s Petition for Review and remanding the matter to the
Department for reconsideration and further proceedings. [See Attachment A]. Also
on May 30, 2025, Judge Lyttle signed the Order Overruling Texas Department of
Insurance and Cassie Brown’s First Amended Plea to the Jurisdiction. [See
Attachment B].
6. The Texas Department of Insurance and Commissioner Cassie Brown,
through their counsel, the Attorney General, desire to appeal under Rules 25.1, 26.1,
26.1(b), 27.1(a), 28.1, and 29 of the Texas Rules of Appellate Procedure and under
TDI & CASSIE BROWN’S NOTICE OF APPEAL Cause No. D-1-GN-25-001663; Texas Land Title Association v. TDI, et al. Page 2 of 5 Texas Civil Practices and Remedies Code 51.014(a)(4) and (8) both the Temporary
Injunction and other rulings in the trial court’s May 30, 2025, Order Granting
Plaintiff’s First Amended Application for Temporary Injunction and the trial court’s
May 30, 2025, Order Overruling Texas Department of Insurance and Cassie Brown’s
First Amended Plea to the Jurisdiction.
7. A copy of this Notice of Appeal has been served on all parties of record.
Respectfully Submitted,
KEN PAXTON Attorney General of Texas
BRENT WEBSTER First Assistant Attorney General
RALPH MOLINA Deputy First Assistant Attorney General
AUSTIN KINGHORN Deputy Attorney General for Civil Litigation
ERNEST C. GARCIA Chief, Administrative Law Division
TDI & CASSIE BROWN’S NOTICE OF APPEAL Cause No. D-1-GN-25-001663; Texas Land Title Association v. TDI, et al. Page 3 of 5 /s/ James Z. Brazell JAMES Z. BRAZELL State Bar No. 02930100 Assistant Attorney General ROSALIND HUNT State Bar No. 24067108 Assistant Attorney General Administrative Law Division OFFICE OF THE ATTORNEY GENERAL OF TEXAS P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 Telephone: (512) 475-3204 Facsimile: (512) 320-0167 James.Brazell@oag.texas.gov
ATTORNEYS FOR DEFENDANTS TEXAS DEPARTMENT OF INSURANCE AND CASSIE BROWN, IN HER CAPACITY AS COMMISSIONER OF THE TEXAS DEPARTMENT OF INSURANCE
TDI & CASSIE BROWN’S NOTICE OF APPEAL Cause No. D-1-GN-25-001663; Texas Land Title Association v. TDI, et al. Page 4 of 5 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing Notice of Appeal has been served on June 19, 2025, in compliance with Texas Rule of Civil Procedure 21a to the following party:
RAY C. CHESTER State Bar No. 04189065 ANDREW M. EDGE State Bar No. 24071446 MCGINNIS LOCHRIDGE LLP 1111 W. 6th Street, Bldg. B, Suite 400 Austin, Texas 78703 Telephone: (512) 495-6000 Facsimile: (512) 495-6093 rchester@mcginnislaw.com aedge@mcginnislaw.com
ATTORNEYS FOR PLAINTIFF TEXAS LAND TITLE ASSOCIATION
/s/ James Z. Brazell JAMES Z. BRAZELL Assistant Attorney General
TDI & CASSIE BROWN’S NOTICE OF APPEAL Cause No. D-1-GN-25-001663; Texas Land Title Association v. TDI, et al. Page 5 of 5 Attachment A 05/30/2025 04:28:34 PM Velva L. Price District Clerk Travis County D-1-GN-25-001663 CAUSE NO. D-1-GN-25-001663
TEXAS LAND TITLE ASSOCIATION, § IN THE DISTRICT COURT OF § Plaintiff, § § v. § § TEXAS DEPARTMENT OF INSURANCE § TRAVIS COUNTY, TEXAS AND CASSIE BROWN, IN HER § CAPACITY AS COMMISSIONER OF THE § TEXAS DEPARTMENT OF INSURANCE, § § Defendants. § 345TH JUDICIAL DISTRICT
ORDER GRANTING PLAINTIFF’S FIRST AMENDED APPLICATION FOR TEMPORARY INJUNCTION
On May 27-28, 2025, the Court heard Plaintiff’s Original Petition and Application for
Temporary Injunction filed on March 6, 2025, and as amended on May 28, 2025, solely to include
a verification as provided in Plaintiff’s First Amended Original Petition and Application for
The Court FINDS that Defendants waived the insufficiency of verification to support
Plaintiff’s original application for injunctive relief, by Defendants’ failure to timely object thereto
before the Court heard evidence pertaining to the requested injunctive relief. Russell v. City of
Dallas, No. 05-13-00061-CV, 2014 Tex. App. LEXIS 5339, at * 9–10 (Tex. App.—Dallas 2014,
pet. denied, cert. denied 574 U.S. 1048 (2014)).
After considering the evidence and arguments of counsel, the Court FINDS Defendants did
not strictly comply with the rulemaking requirements of Texas Insurance Code section 2703.202,
subdivision (c), in connection with the issuance of Commissioner’s February 6, 2025 order number
2025-9125 (Commissioner’s Order 2025-9125).
ORDER GRANTING PLAINTIFF’S FIRST AMENDED APPLICATION Page 1 of 3 FOR TEMPORARY INJUNCTION Cause No. D-1-GN-25-001663 The Court FURTHER FINDS that Commissioner’s Order 2025-9125 dictates a new set of
basic premium rates as set forth in the “Exhibit A” attached to that order, which will take effect on
July 1, 2025, and its application to Plaintiff interferes with or impairs, or threatens to interfere with
or impair, a legal right or privilege of the plaintiff.
IT IS THEREFORE ORDERED that Plaintiff’s Petition for Review of Commissioner’s
Order 2025-9125 is GRANTED.
IT IS FURTHER ORDERED that this matter is hereby REMANDED to the Texas
Department of Insurance for reconsideration of Commissioner’s Order 2025-9125, and for further
proceedings as may be necessary before that agency, to include but is not limited to additional
income and expenses data used to fix premium rates for the year of 2023 and beyond, which were
incomplete or previously unavailable and as recognized by the Commissioner’s Order in her
Findings of Fact 12(d) and its attendant footnote 2.
The Court FURTHER FINDS that Plaintiff is without adequate remedies at law, absent a
temporary injunction of Commissioner’s Order 2025-9125 at this time.
IT IS THEREFORE ORDERED that Plaintiff’s First Amended Application for Temporary
Injunction is GRANTED.
IT IS ORDERED that Defendants are hereby ENJOINED from enforcing Commissioner’s
Order 2025-9125, and that order is hereby STAYED, pending final disposition of this matter. This
injunction is binding only upon the parties to the action, their officers, agents, servants, employees,
and attorneys, and upon those persons in active concert or participation with them who receive
actual notice of the order by personal service or otherwise.
IT IS FURTHER ORDERED that this cause is hereby set for trial on the merits to
commence on December 1, 2025, and as the Court may further order.
ORDER GRANTING PLAINTIFF’S FIRST AMENDED APPLICATION Page 2 of 3 FOR TEMPORARY INJUNCTION Cause No. D-1-GN-25-001663 IT IS FURTHER ORDERED that this Order not be effective unless and until Plaintiff
executes and files with the Clerk a bond, in conformity with the law, payable to Defendants in the
amount of $2,500.
SIGNED on May 30, 2025,
_____________________________ DANIELLA DESETA LYTTLE Judge Presiding, 261st District Court
ORDER GRANTING PLAINTIFF’S FIRST AMENDED APPLICATION Page 3 of 3 FOR TEMPORARY INJUNCTION Cause No. D-1-GN-25-001663 Attachment B 05/30/2025 04:27:51 PM Velva L. Price District Clerk Travis County D-1-GN-25-001663 CAUSE NO. D-1-GN-25-001663
TEXAS LAND TITLE ASSOCIATION, § IN THE DISTRICT COURT OF § Plaintiff, § § v. § § TEXAS DEPARTMENT OF INSURANCE § TRAVIS COUNTY, TEXAS AND CASSIE BROWN, IN HER § CAPACITY AS COMMISSIONER OF THE § TEXAS DEPARTMENT OF INSURANCE, § § Defendants. § 345TH JUDICIAL DISTRICT
ORDER OVERRULING TEXAS DEPARTMENT OF INSURANCE AND CASSIE BROWN’S FIRST AMENDED PLEA TO THE JURISDICTION
On May 27-28, 2025, the Court heard Texas Department of Insurance and Cassie Brown’s
First Amended Plea to the Jurisdiction filed on May 20, 2025 (Plea).
After considering the evidence and arguments of counsel, the Court FINDS that it has
subject-matter jurisdiction under Texas Insurance Code section 36.201 and Texas Government
Code section 2001.038, subdivision (a), to conduct judicial review of the Commissioner’s actions
as alleged in Plaintiff’s Original Petition and Application for Temporary Injunction filed on March
6, 2025, and as amended on May 28, 2025. The Court therefore FINDS that Defendants’ sovereign
immunity has been statutorily waived.
IT IS THEREFORE ORDERED that the Plea is OVERRULED.
_____________________________ DANIELLA DESETA LYTTLE Judge Presiding, 261st District Court Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Meridith Fischer on behalf of James Brazell Bar No. 2930100 meridith.fischer@oag.texas.gov Envelope ID: 102206362 Filing Code Description: Notice of Appeal Filing Description: NOTICE OF APPEAL TO THE FIFTEENTH COURT OF APPEALS Status as of 6/20/2025 8:35 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Andrew MEdge aedge@mcginnislaw.com 6/19/2025 1:30:49 PM SENT
Ray Chester rchester@mcginnislaw.com 6/19/2025 1:30:49 PM SENT
Kim McBride kmcbride@mcginnislaw.com 6/19/2025 1:30:49 PM SENT
Associated Case Party: TEXAS DEPARTMENT OF INSURANCE
Rosalind Hunt rosalind.hunt@oag.texas.gov 6/19/2025 1:30:49 PM SENT
Jennifer Foster Jennifer.Foster@oag.texas.gov 6/19/2025 1:30:49 PM SENT
James Z.Brazell james.brazell@oag.texas.gov 6/19/2025 1:30:49 PM SENT
Meridith Fischer Meridith.Fischer@oag.texas.gov 6/19/2025 1:30:49 PM SENT EXHIBIT C Travis County District Court enjoins the change to title insurance basic premium rates Texas Department of Insurance sent this bulletin at 06/12/2025 10:12 AM CDT
View as webpage
The Travis County District Court has issued a temporary injunction order enjoining the enforcement of Commissioner Order No. 2025-9125. Because of the court's action, the change to title insurance basic premium rates under Order 2025-9125 will not go into effect on July 1. Title insurance companies and agents should continue to use the current rates contained in the Title Insurance Basic Manual until further notice. EXHIBIT D 05/30/2025 04:28:34 PM Velva L. Price District Clerk Travis County D-1-GN-25-001663 CAUSE NO. D-1-GN-25-001663
TEXAS LAND TITLE ASSOCIATION, § IN THE DISTRICT COURT OF § Plaintiff, § § v. § § TEXAS DEPARTMENT OF INSURANCE § TRAVIS COUNTY, TEXAS AND CASSIE BROWN, IN HER § CAPACITY AS COMMISSIONER OF THE § TEXAS DEPARTMENT OF INSURANCE, § § Defendants. § 345TH JUDICIAL DISTRICT
ORDER GRANTING PLAINTIFF’S FIRST AMENDED APPLICATION FOR TEMPORARY INJUNCTION
On May 27-28, 2025, the Court heard Plaintiff’s Original Petition and Application for
Temporary Injunction filed on March 6, 2025, and as amended on May 28, 2025, solely to include
a verification as provided in Plaintiff’s First Amended Original Petition and Application for
The Court FINDS that Defendants waived the insufficiency of verification to support
Plaintiff’s original application for injunctive relief, by Defendants’ failure to timely object thereto
before the Court heard evidence pertaining to the requested injunctive relief. Russell v. City of
Dallas, No. 05-13-00061-CV, 2014 Tex. App. LEXIS 5339, at * 9–10 (Tex. App.—Dallas 2014,
After considering the evidence and arguments of counsel, the Court FINDS Defendants did
not strictly comply with the rulemaking requirements of Texas Insurance Code section 2703.202,
subdivision (c), in connection with the issuance of Commissioner’s February 6, 2025 order number
ORDER GRANTING PLAINTIFF’S FIRST AMENDED APPLICATION Page 1 of 3 FOR TEMPORARY INJUNCTION Cause No. D-1-GN-25-001663 The Court FURTHER FINDS that Commissioner’s Order 2025-9125 dictates a new set of
basic premium rates as set forth in the “Exhibit A” attached to that order, which will take effect on
July 1, 2025, and its application to Plaintiff interferes with or impairs, or threatens to interfere with
IT IS THEREFORE ORDERED that Plaintiff’s Petition for Review of Commissioner’s
IT IS FURTHER ORDERED that this matter is hereby REMANDED to the Texas
Department of Insurance for reconsideration of Commissioner’s Order 2025-9125, and for further
proceedings as may be necessary before that agency, to include but is not limited to additional
income and expenses data used to fix premium rates for the year of 2023 and beyond, which were
incomplete or previously unavailable and as recognized by the Commissioner’s Order in her
The Court FURTHER FINDS that Plaintiff is without adequate remedies at law, absent a
temporary injunction of Commissioner’s Order 2025-9125 at this time.
IT IS THEREFORE ORDERED that Plaintiff’s First Amended Application for Temporary
IT IS ORDERED that Defendants are hereby ENJOINED from enforcing Commissioner’s
Order 2025-9125, and that order is hereby STAYED, pending final disposition of this matter. This
injunction is binding only upon the parties to the action, their officers, agents, servants, employees,
and attorneys, and upon those persons in active concert or participation with them who receive
IT IS FURTHER ORDERED that this cause is hereby set for trial on the merits to
commence on December 1, 2025, and as the Court may further order.
ORDER GRANTING PLAINTIFF’S FIRST AMENDED APPLICATION Page 2 of 3 FOR TEMPORARY INJUNCTION Cause No. D-1-GN-25-001663 IT IS FURTHER ORDERED that this Order not be effective unless and until Plaintiff
executes and files with the Clerk a bond, in conformity with the law, payable to Defendants in the
_____________________________ DANIELLA DESETA LYTTLE Judge Presiding, 261st District Court
ORDER GRANTING PLAINTIFF’S FIRST AMENDED APPLICATION Page 3 of 3 FOR TEMPORARY INJUNCTION Cause No. D-1-GN-25-001663