63 N.Y.2d 446 (1984)
When a statute requires regulations to be ‘in accordance with’ other regulations, it does not mandate strict conformity but rather requires reasonable consistency and harmony, allowing for the exercise of agency expertise in interpreting and implementing the law.
Summary
This case concerns a challenge to regulations promulgated by the New York Superintendent of Insurance for determining excess profits on motor vehicle insurance policies. The plaintiffs argued that the regulations, which used aggregate industry data, were inconsistent with a statute requiring them to be ‘in accordance with’ regulations that used individual carrier data. The court reversed the Appellate Division’s decision, holding that ‘in accordance with’ does not require strict conformity and that the Superintendent’s interpretation was reasonable given the statute’s purpose. The court emphasized the Superintendent’s broad power to interpret and implement insurance law, deferring to their expertise.
Facts
The New York Public Interest Research Group (NYPIRG) and several of its members challenged regulations (11 NYCRR part 166) issued by the Superintendent of Insurance regarding the determination of excess profits under Insurance Law § 2329. NYPIRG contended that these regulations, which used aggregate industry data to determine excess profits, were inconsistent with Insurance Law § 2323 and its corresponding regulations (11 NYCRR part 165), which required a company-by-company, line-by-line determination of profitability. The challenged regulations were intended to give policyholders the benefit of a reduction in automobile accidents.
Procedural History
The Department of Insurance moved to dismiss the complaint. Special Term granted the motion, holding the regulations valid. The Appellate Division reversed, declaring the regulations invalid because they were not ‘in accordance with’ the regulations under Insurance Law § 2323. The Department of Insurance appealed to the New York Court of Appeals.
Issue(s)
Whether the regulation promulgated by the Superintendent of Insurance, which utilizes aggregate industry data to determine excess profit for motor vehicle insurance policies, is inconsistent with Insurance Law § 2329 requiring it to be ‘in accordance with’ regulations issued under Insurance Law § 2323 that mandate a company-by-company, line-by-line determination.
Holding
No, because the phrase ‘in accordance with’ does not require strict conformity, and the Superintendent’s interpretation is reasonable given the statute’s purpose and the Superintendent’s expertise in insurance matters.
Court’s Reasoning
The Court of Appeals held that the Superintendent of Insurance has broad power to interpret insurance law, and their regulations should be upheld unless inconsistent with a specific statutory provision. The court reasoned that ‘in accordance with’ does not require identicality but only reasonable correspondence or harmony. The court noted that the purpose of § 2323 is to ensure competitive insurance rates, while § 2329 aims to return excess profits to policyholders due to factors affecting the entire industry. The court stated, “the Superintendent of Insurance could rationally construe the uniformity requirement [of section 2329] as prohibiting inconsistent results, rather than mandating identical formulas”. The court also addressed ambiguity in the statute, noting it could be interpreted as requiring either profit or net worth to be computed under Part 165. The court deferred to the Superintendent’s expertise in interpreting the statute to require the computation of net worth attributable to motor vehicle insurance under Part 165. The Court found that the legislative history was not dispositive. Ultimately, the court deferred to the Superintendent’s reasonable interpretation, emphasizing that the regulations should be read as requiring a refund per policy rather than per line of coverage.