‘Filed Rate Doctrine’ Bars Force-Placed Insurance Action, Conn. Federal Judge Rules

HARTFORD, Conn. — A Connecticut federal judge has dismissed claims that a mortgage loan servicer and an insurer violated the Racketeer Influenced and Corrupt Organizations Act by charging borrowers inflated rates for force-placed insurance, finding they are barred by the “filed rate doctrine” because the rates were approved by state insurance regulators.

In a March 19 order, Judge Janet C. Hall of the U.S. District Court for the District of Connecticut explained that under the doctrine, “a rate filed with and approved by a regulatory agency is unassailable in judicial proceedings brought by ratepayers.”

In July 2010, Robert Lewis obtained …