In Greene v. Safeco Ins. Co. (1983) 140 Cal. App. 3d 535, the plaintiff was insured by the defendant insurer under a term automobile policy. After the plaintiff was involved in an automobile accident and disputes arose over the handling of the claim, the insurer notified the plaintiff in writing that it would not renew her policy when it expired. The plaintiff sued, alleging that defendant's failure to renew her policy constituted a breach of the implied covenant of good faith and fair dealing. The appellate court began by noting that nonrenewal of automobile policies is regulated by statute in California. (Ins. Code, 660-670.) "Under former section 663, 'An insurer shall offer renewal of a policy, contingent upon payment of premium as stated in the offer, to an insured unless the insurer mails or delivers to the named insured, at the address shown in the policy, at least 20 days advance notice of nonrenewal. Such notice shall contain or be accompanied by a statement that upon written request by the named insured, made not later than one month following the expiration of the policy period, or delivered to the insurer, the insurer will notify the insured in writing, within 20 days of his request, the reason or reasons for such nonrenewal . . . .'It is plaintiff's contention that the provision requiring an insurer upon request to give the reason for a nonrenewal would be meaningless if it can be arbitrary and unreasonable under the facts of a given situation, therefore, she can challenge the insurer's good faith in this instance. Plaintiff's argument would be plausible if it were not for section 667, which provides: 'There shall be no liability on the part of, and no cause of action of any nature shall arise against . . . any insurer . . . for any statement made . . . in any written notice of cancellation or nonrenewal, or in any other communication, oral or written, specifying the reasons for cancellation or nonrenewal of an automobile insurance policy. . . .'" (Greene, supra, 140 Cal. App. 3d 535, 537-538.) The court continued: "At first blush one might question why the statute requires the insurer to state its reasons for not renewing a policy if any reason, good or bad, cannot be challenged by the insured. There is, however, an explanation. An insurer has no legal duty to renew a policy of automobile insurance once a term has expired. The law is stated in 13A Appleman, Insurance Law and Practice (1976) section 7642, pages 409-410: 'Both property and liability policies are considered to be term policies. Accordingly in the absence of any statutory provisions to the contrary, the insurer may refuse to renew them for any reason whatsoever, or for no reason at all.' (Italics added.) Sections 663 and 667 have kept this basic legal concept intact, but apparently to enlighten a puzzled insured when a nonrenewal notice is received, the requirement was added that the insurer must give the insured a reason upon request. Section 667 simply maintains the historic right of an insurer to not renew a policy, after appropriate notice, for any reason it chooses without subjecting it to a lawsuit for the reasons stated." (Greene, supra, 140 Cal. App. 3d 535, 538.)