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Meanwhile, leading insurance lobby the Property Casualty Insurers Association of America (PCI) said in state Senate testimony that Granholm’s proposal is out of step with the 20 states that have adopted a variation of the model law developed by the National Conference of Insurance Legislators (NCOIL). PCI lobbyist Michael Harrold said “the NCOIL model provides many consumer protections while preserving an important and fair rating tool.” He said Michigan should do the same, while criticizing the OFIS for failing to tell consumers that most of them will see rate increases if credit scoring is banned. Harrold said “there is a dramatic difference between the base rate in any territory and the average premium in that territory.” He said most Michigan consumers would be worse off under a ban. Harrold cited House Bill 5803, a variation of the NCOIL model, as a “sensible alternative.”