Resources
Newsroom
Newsletter
Property and Casualty News June 2025
Property and Casualty News
June 2025
Welcome to our latest newsletter! As a thought leader in the Insurance Industry for over 50 years we are always excited to share the latest sampling of insurance compliance related bulletins, regulations and legislative activity. Please feel free to share this newsletter with others that may be interested. Contact Us with any questions on the items in this newsletter or with any other compliance related matter we can assist you with. Enjoy!
AGENT / PRODUCER CONTINUING EDUCATION
Louisiana amended licensure and continuing education requirements for insurance producers, consultants, adjusters, and public adjusters by increasing mandatory continuing education hours focused on legislative updates and flood insurance, and raising the unlicensed claims adjustment threshold from $500 to $2,000. SB 40
AGENT / PRODUCER LICENSING AND APPOINTMENT
Maine has ended online-proctored insurance licensing exams due to security concerns, requiring all future exams to be taken in person at Pearson VUE testing centers starting immediately. Notice Dated 5/9/25
Missouri announced that insurance producer exams must be scheduled and taken at physical testing centers, ending the use of the OnVue online proctoring service for new appointments. Scheduled OnVue exams will be honored through May 18, 2025, after which all exams must be rescheduled in person. Bulletin 25-03
AUTOMOBILE INSURANCE
Louisiana enacted new legislation prohibiting unauthorized aliens from receiving general damages or past and future wages in automobile accident claims, except when covered under an uninsured or underinsured motorist policy naming them as insured. HB 436
North Carolina approved revised private passenger auto and motorcycle insurance rates effective October 1, 2025. The final settlement includes a +5.0% overall rate increase for private passenger autos and a -16.3% decrease for motorcycle liability. Updates also include changes to class factors, deductibles, and extended transportation rates. Circular Letter A-25-3
CAPTIVES
Arizona adopted new legislation allowing captive insurers to apply for a certificate of dormancy through the Department of Insurance and Financial Institutions (DIFI). The law revises definitions, licensing procedures, and corporate governance rules, including reducing capital requirements for protected cell captive insurers. HB 2193
Georgia expanded the insurance and reinsurance activities allowed for limited purpose subsidiaries and captive insurance companies, broadening their operational scope and updating definitions. The changes allow limited purpose subsidiaries to be owned by sponsors and reinsure beyond their organizing reinsurer, while captive insurers can now engage in any DOI-approved insurance or reinsurance business. HB 348
Montana caps annual premium taxes for captive insurance companies at $100,000, excluding protected cell captives and special purpose captives with LLC series, effective for tax years after December 31, 2025. SB 60
COMMERCIAL LINES INSURANCE
Arizona enacted new legislation specifying that landlords are not liable for injuries or damages caused by assistance or service animals allowed as reasonable accommodations, while affirming that this exemption does not limit the rights of individuals with disabilities under fair housing laws. The law goes on to provide definitions and clarify the types of animals covered. HB 2068
Arizona established a new framework for wildfire mitigation planning by electric utilities and power entities, defining exclusive legal remedies for wildfire-related claims. The law requires power entities to submit Wildfire Mitigation Plans, shields compliant entities from certain negligence claims, and prohibits punitive damages or inverse condemnation claims unless strict evidentiary standards are met. HB 2201
Colorado enacted legislation to regulate foreign third-party litigation financing in civil actions, requiring foreign funders to disclose their identity and financing agreements to the Attorney General and comply with strict limitations to ensure transparency and protect national security interests. The law prohibits foreign funders from influencing legal strategies, sharing sensitive information, or using domestic entities to provide financing. HB 1329
DISASTER / CATASTROPHIC EVENT
Maryland’s Insurance Commissioner activated emergency regulations requiring property, casualty, life, and health insurers to provide a 60-day grace period for premium payments and other reasonable accommodations to policyholders and businesses in Allegany and Garrett Counties following the May 15, 2025, weather-related State of Emergency. Bulletin 25-8
DISASTER PREPAREDNESS
New York issued a new circular letter establishing updated disaster preparedness and response requirements for property/casualty insurers. The letter mandates pre-disaster data reporting, annual disaster and business continuity plans, and coordination with state agencies during emergencies. Circular Letter 2025-3
FILINGS: PROPERTY / CASUALTY
Massachusetts issued guidance requiring all home insurance providers to disclose flood coverage exclusions in policies issued or renewed on or after January 1, 2026, inform policyholders that standard home insurance does not cover flood damage, and encourage consideration of separate flood insurance. Insurers must submit a separate disclosure for approval by September 1, 2025. PC Filing Guidance Notice 2025-R
HOLDING COMPANIES
Oklahoma updated definitions, registration, and reporting requirements for insurer holding company systems. Insurers must now submit group capital calculations and Liquidity Stress Test results. The changes also clarify registration procedures, materiality thresholds, and conditions under which proprietary information may be shared or disclosed. HB 1497
MISCELLANEOUS
Hawaii enacted the Pet Insurance Act, establishing comprehensive regulations for pet insurance policies, including mandatory disclosures about coverage limits, waiting periods, and exclusions, as well as a 30-day free look period for consumers. The law requires clear separation and disclosure of wellness programs from insurance and mandates specific training for insurance producers selling pet policies. HB 544
Michigan released an updated list of municipalities participating in the Fire Insurance Withholding Program, detailing the applicable program sections for each municipality and replacing prior lists. Insurers must receive at least 30 days’ notice before new municipalities implement the program. Notice Dated 6/1/25
PERSONAL LINES INSURANCE
Colorado amended its homeowners insurance laws to prohibit insurers from denying, canceling, refusing to renew, or increasing premiums based solely on the breed or breed mix of a dog kept at a residence. Insurers may still take such actions if a specific dog is known to be dangerous or has been officially declared dangerous, and the provision now applies to all residential structures occupied by owners or renters. HB 1207
Colorado amended its homeowners’ insurance laws to clarify that insurers are to provide policyholders with a copy of their insurance policy, including the declaration page and endorsements, within three business days of a request. Insurers must also provide a certified copy within 30 calendar days of receiving a written request. HB 1322
Colorado now allows FAIR Plan member insurers to recoup startup fees through a transparent premium surcharge on property insurance policies over two years, subject to DOI approval and consumer protections. Insurers must disclose surcharges clearly, maintain records, and refund any excess collected beyond statutory limits. 3 CCR 702-5
Colorado strengthened tenant protections for individuals using housing subsidies by now prohibiting landlords from unreasonably delaying or refusing to cooperate with rental assistance applications. The law mandates a minimum of $5,000 in damages for proven discrimination based on subsidy use and requires courts to consider subsidy losses when awarding actual damages. HB 1240
Maryland now prohibits insurers from denying residential condominium insurance policies solely due to a coverage lapse caused by the insurer’s market withdrawal, provided the lapse is no longer than 90 days and required documentation is submitted. The law applies to new policies issued on or after January 1, 2026, and amends unfair underwriting practices under Title 27. HB 1148
Michigan reminds personal lines homeowners and dwelling insurers that any underwriting, rating, claims, or adverse decisions based on aerial imagery must comply with insurance laws ensuring accuracy, current property conditions, and consumer protections. Insurers must allow policyholders to review and dispute imagery findings before cancellations or nonrenewals, avoid using cosmetic roof issues as a basis for such actions, and conduct physical inspections when needed. Additionally, insurers must file underwriting rules with the DOI, provide annual notices informing consumers of their rights, and follow specific cancellation and nonrenewal procedures. Bulletin 2025-12-INS
Montana now requires admitted insurers using wildfire risk scores for rating residential property to disclose, upon request, details including the property's current wildfire risk score, score range, creator, creation date, and key adverse factors. This information must be provided within 30 days to insureds, producers, or applicants. HB 533
PROPERTY INSURANCE
Colorado enacted legislation requiring insurers that use wildfire or catastrophe risk models in underwriting homeowner and residential property insurance to submit detailed model information to the Commissioner and account for both property-specific and community-level wildfire mitigation efforts. Insurers must offer discounts for verified mitigation actions if such factors are not included in their models, provide clear public information on discounts and appeals, and issue annual notices to policyholders explaining wildfire risk scores and their impact. HB 1182
SURPLUS LINES
Alabama revised its regulations for nonresident surplus line brokers by requiring license applicants to submit a commissioner-specified form, pay the fee outlined in Section 27-4-2, and adhere to a license expiration date of December 31 in the year of issuance. SB 97
THIRD PARTY ADMINISTRATORS
Indiana issued a bulletin informing insurers, TPAs, and PBMs of new annual ownership reporting requirements starting July 1, 2025, under Public Law 239-2025. Reports must include detailed ownership information but exclude Social Security numbers, with penalties for late filings. Bulletin 278
WORKERS' COMPENSATION
Alabama’s Workers’ Compensation Division announced that, effective July 1, 2025, the maximum weekly workers' compensation benefit will be $1,172 and the minimum will be $322, based on the 2024 State Average Weekly Wage of $1,172.15 as determined on May 15, 2025. WC Notice Dated 5/20/25
California’s Workers' Compensation Insurance Rating Bureau (WCIRB) announced that the Department of Insurance approved all proposed amendments in its regulatory filing, with changes to the Uniform Statistical Reporting Plan, Miscellaneous Regulations, and Experience Rating Plan taking effect September 1, 2025. The amendments followed a public hearing and are summarized in a new WCIRB online reference guide, with full updates to be published on the WCIRB website. WCIRB Bulletin 2025-09
California’s Workers' Compensation Insurance Rating Bureau announced it will relocate its office from Oakland to San Francisco’s Financial District. The Bureau has published its new mailing address, will begin accepting mail at the new location immediately, with phone numbers remaining unchanged. WCIRB Bulletin 2025-08
Colorado amended its workers’ compensation laws to strengthen oversight of medical treatment authorization and improve injured workers’ access to care. Employers and insurers must now follow the Division of Workers' Compensation's utilization standards when responding to treatment requests, or risk mandatory payment for services deemed authorized. The law also revises the process for selecting treating physicians, expands employee rights to designate or change doctors, and introduces new disclosure and notification requirements. HB 1300
Delaware’s Compensation Rating Bureau updated its indemnity data call requirements by adding six new data fields to improve reporting accuracy. These changes apply starting with Q4 2025 data, and require mandatory testing by December 31, 2025. Updated manuals and resources are available on the DCRB website. DCRB Circular No. 1053
Montana updated its pharmacy laws and insurance regulations to restrict workers’ compensation prescription drug payments to in-state mail order pharmacies, allowing up to a 90-day supply, and require out-of-state mail order pharmacies to be properly registered in Montana. HB 794
Nebraska announced that the burial benefit under the Workers’ Compensation Act will increase to $11,900 effective July 1, 2025, as part of the Court’s annual benefit rate adjustment. WC Notice Dated 5/13/25
New Jersey’s Property-Liability Insurance Guaranty Association announced a 1% Workers’ Compensation Security Fund (WCSF) assessment for 2025, based on each carrier’s 2024 net direct written premium. Notices for the 2025 WCSF assessment will be issued on July 1, 2025. Payment is due by August 15, 2025. NJPLIGA Bulletin 2025-005
Newsletter
Life and Health News October 2024
Life and Health News
October 2024
Welcome to our latest newsletter! As a thought leader in the Insurance Industry for over 50 years we are always excited to share the latest sampling of insurance compliance related bulletins, regulations, and legislative activity. Please feel free to share this newsletter with others that may be interested. Contact Us with any questions on the items in this newsletter or with any other compliance related matter we can assist you with. Enjoy!
AGENT / PRODUCER COMPENSATION
North Carolina issued a notice to insurers in the state that offer Medicare Supplement Insurance policies and certificates to resolve misunderstandings about mandated restrictions on agent compensation. Notice 08/26/24
AGENT / PRODUCER CONTINUING EDUCATION
California published a notice announcing a new 2025 annuity four-hour training course. The new course is required for producers to continue recommending annuities, prior to each license renewal. Notice Dated 09/19/24
New Jersey provided new rules and amendments effective September 16, 2024, to strengthen oversight and continuing education prerequisites for broker-dealers and investment adviser representatives. NJAC 13:47A-1.9
Utah has amended provisions in R590-142, the Continuing Education Rule. The changes notify insurance licensees about how the Insurance Department sets fees. R590-142-4
CONFIDENTIALITY / PRIVACY
Alabama made updates to the procedures to be followed when a third party requests the release of medical information. The changes were made to coincide with current Medicaid policy. 560-X-20-.05
DENTAL INSURANCE
Colorado amended its filing requirements for dental products. Changes include the requirement to file an annual dental loss ratio filing. The provision also provides dental coverage filing requirements for new and existing products. Regulation 4-2-11 s 5
DEPARTMENT OF INSURANCE
Florida updated its disciplinary guidelines for violations of Florida laws or rules. A copy of the guidelines may be obtained from the department or through its website. The updated guidelines provide a list of mitigating factors and considerations. 69W-1000.001
FILING REQUIREMENTS / PROCEDURES
Alabama updated its minimum filing fees including a minimum fee of $50 per filing for each long-term care policyholder letter. Bulletin 2024-04
FRAUD / ANTI-FRAUD
New Mexico has announced the launch of a new electronic submission process for the Insurance Fraud Act Assessment Filing to ease compliance for regulated entities. Electronic Filing Fraud Assessment Notice
HEALTH CARE EXCHANGE / MARKETPLACE
Rhode Island issued a bulletin for the purpose of issuing state-specific requirements for carrier notices of renewal and discontinuance in the Rhode Island Individual and Small Group Markets. Bulletin 2024-2
HEALTH INSURANCE - COMPREHENSIVE
Oregon has updated the services that health plans are required to cover during a comprehensive well-woman visit to include the thirteen well-woman preventive services identified by the United States Health Resources and Services Administration (HRSA) as of December 2022. It aligns with the guidelines set forth by the Women's Preventive Services Initiative (WPSI) and requires carriers to adhere to current practice and form filing requirements. OAR 836-053-0435
HOLDING COMPANIES
Louisiana amended its regulations to add additional language permitting electronic filing and to provide clarification as to the exemption with respect to the group capital calculation. LAC 37:XIII.128-131
LIMITED BENEFIT CONTRACTS
Colorado published a bulletin providing guidance on Short-Term Limited Duration Insurance including filing requirements for new or revised plans, effective 09/01/24. Carriers must submit rate and form filings in accordance with Colorado regulations. The bulletin also provides a policyholder notice. Bulletin B-4.142
Michigan published a bulletin notifying carriers about new federal requirements for short term limited duration insurance. Changes include new limitations on duration and contract disclosure. All rates and forms are to be submitted via SERFF. Bulletin 2024-23-INS
MENTAL HEALTH PARITY
Colorado adopted a regulation to establish the requirements, process, and form to be utilized by health benefit plans for step therapy utilization and exceptions for enrollees with serious mental illnesses. 3 CCR 702 Reg R-2-100 s 1
MISCELLANEOUS
Arkansas published a bulletin to establish a procedure for the handling of independent reviews of provider healthcare services prior authorization exemption rescissions and prescription drug prior authorization continuation disallowances. Bulletin 16-2024
Missouri's Department of Commerce and Insurance issued Bulletin 24-06 to inform regulated entities about new provisions from Senate Bill 1359. The new law allows entities at least 30 days to respond to requests for records or materials from the Department. Bulletin 24-06
New Mexico enacted new regulations, effective September 10, 2024, that will permanently establish standards for compliance with the Health Care Consolidation Oversight Act. 13.2.12 NMAC
Oklahoma Health Care Authority (OHCA) has made emergency changes necessary to maintain compliance with federal and state regulations which forbid third party insurers from denying a Medicaid member’s claim solely on the basis that prior authorization was not received for services covered under the state plan or a waiver. 317:30-3-24
OMNIBUS LEGISLATION
Alaska enacted SB 134 to address insurance data security. It sets certain standards for handling a cybersecurity breach and providing notification. SB134 also requires state-regulated private insurance plans which include breast diagnostic imaging to provide this coverage without cost sharing. SB 134
PHARMACY BENEFIT MANAGERS
Utah has revised the licensing requirements for pharmacy benefit managers by altering the fee payment process. R590-282-3
PUBLIC RECORDS
Colorado published a bulletin updating public records procedures. The bulletin outlines when and how records may be requested as well as the fees for doing so. Bulletin B-1.6
RATEMAKING
New Jersey amended provisions concerning minimum loss ratios for certain health benefit plans. SB 2875
REPORTS - DATA CALLS & OTHER REPORTS
Maryland published a bulletin, notifying companies of changes to the process and format for carrier reporting of adverse decisions and grievances. Bulletin 24-21
TAX CREDITS
The Nevada Tax Commission has approved a regulation that repeals certain tax credits for insurers that were eliminated in 2021. This includes provisions related to credits for insurers with home offices in the state and requirements for quarterly tax reporting. Essentially, insurers can no longer claim these credits, simplifying the tax framework but potentially increasing their tax liabilities. NAC 680B.150
Newsletter
Property and Casualty News May 2025
Property and Casualty News
May 2025
Welcome to our latest newsletter! As a thought leader in the Insurance Industry for over 50 years we are always excited to share the latest sampling of insurance compliance related bulletins, regulations and legislative activity. Please feel free to share this newsletter with others that may be interested. Contact Us with any questions on the items in this newsletter or with any other compliance related matter we can assist you with. Enjoy!
ADJUSTERS
Mississippi established fiduciary requirements for public adjusters handling funds on behalf of insureds, mandating that all funds be deposited into separate fiduciary trust accounts and disbursed within 30 days of invoice approval. The bill expands the definition of public adjusters, sets licensing criteria including a $50,000 bond requirement, and introduces stricter rules for compensation, including limits on fees and contract terms. HB 1174
AUTOMOBILE INSURANCE
Michigan issued a bulletin to update no-fault automobile insurers and health care providers on payment and billing requirements. The bulletin clarifies that the amended MCL 500.3157 fee schedule does not apply to treatment for injuries from accidents occurring before June 11, 2019, and reaffirms that such claims are subject to the prior “reasonableness” standard. Bulletin 2025-11-INS
New Hampshire issued a bulletin regarding virtual vehicle claims adjustments, clarifying insurers' obligations under the Unfair Claims Settlement Practices law. The bulletin emphasizes that while virtual claims can streamline the process, insurers must offer in-person inspections if requested by consumers and cannot deny such requests. Unreasonable delays in providing in-person inspections may violate the law. Bulletin INS 25-031-AB
Rhode Island issued an alert to remind auto insurers and the repair industry stakeholders about the legal prohibitions against steering. The alert emphasizes that insurers cannot require or suggest a specific repair facility for insureds and must inform consumers of their right to freely choose their repair shop. Noncompliance may result in penalties. Industry Alert 2025-2
Virginia issued an administrative letter to motor vehicle insurers, outlining the requirements for issuing private passenger automobile policies, particularly concerning premium increases and point assignments after accidents or motor vehicle convictions. The letter provides guidance on how insurers must apply these increases, consolidates prior guidance, and withdraws several administrative letters. Administrative Letter 2025-01
COMMERCIAL LINES INSURANCE
Arizona adopted the Uniform Special Deposits Act which governs how beneficiaries receive payments from special deposits following a triggering event. The law defines the roles and responsibilities of banks, clarifies that no fiduciary duty exists in special deposit relationships, restricts how account agreements can be amended or interpreted, and limits banks’ liability to direct damages for noncompliance. SB 1206
CONFIDENTIALITY / PRIVACY
Rhode Island released a bulletin outlining the implementation of the state's new insurance data security statute which applies to both foreign and domestic insurers. The bulletin clarifies the requirements under Rhode Island's 2024 Public Laws Chapters 354 and 355, emphasizing the need for insurers to protect consumer data and detailing compliance expectations, including submitting annual statements by April 15 annually. Bulletin 2025-1
CYBERSECURITY
Arkansas enacted the Children and Teens' Online Privacy Protection Act to regulate how online operators collect, use, and disclose personal information from users aged 16 and under. The law requires consent, clear notice, and data security while banning targeted advertising to children and teens. It protects user privacy without mandating age verification or data collection. HB 1717
DISCLOSURE REQUIREMENTS
Louisiana implemented Act 611, requiring all authorized property and casualty insurers to disclose available discounts for homeowners’ and private passenger motor vehicle insurance policies. Insurers must clearly present these discount opportunities and provide them electronically or in writing with each new policy and renewal. Bulletin 2025-02
HOLDING COMPANIES
New Mexico updated its insurance holding company law to require group capital calculation reports and liquidity stress tests. The updates include amendments to definitions and filings under the Insurance Code, a modified examination timeline for Health Maintenance Organizations, and the enactment of new provisions for group capital calculations and liquidity stress tests. HB 398
MISCELLANEOUS
Arkansas enacted a new law to ensure local access to prescription medications by regulating how pharmaceutical manufacturers distribute drugs within the state. The legislation prohibits manufacturers from restricting access to out-of-state networks beyond three months without ensuring availability through local pharmacies and requires a wholesale distributor permit in good standing. All manufacturers must meet a September 1, 2026, compliance deadline. HB 1531
Florida adopted the Pet Insurance Act to regulate the sale of pet insurance and ensure that wellness programs are marketed separately with clear, distinct costs and terms. The law prohibits deceptive advertising, requires transparency on policy exclusions and coverage, and holds insurers accountable for training agents and properly handling claims. HB 655
Georgia established a regulatory framework for litigation financing by requiring registration with the Department of Banking and Finance, prohibiting certain practices, and mandating written contracts with specific consumer protections. The law bars unregistered financiers from operating, imposes penalties for violations, and allows discovery of large litigation funding agreements in civil cases. SB 69
Michigan updated the list of municipalities participating in the Fire Insurance Withholding Program, which allows certain municipalities to escrow 25% of fire insurance settlements for losses to real property. This updated list supersedes all prior editions and includes effective dates for new municipalities, which require at least 30 days' notice before applying withholding provisions. Fire Insurance Withholding Program List Edition 179
PERSONAL LINES INSURANCE
Oklahoma announced a $150 assessment for all property and casualty insurers (licensed for both property and casualty in the state) to fund the Oklahoma Market Assistance Program (OK-MAP), which helps consumers find homeowners’ insurance. The assessment is due by September 1, 2025, and nonpayment may result in fines or revocation of an insurer’s certificate of authority. Bulletin 2025-02
West Virginia issued a bulletin advising insurers on the use of aerial imagery in homeowners insurance. It mandates insurers ensure aerial imagery is current, clear, and used alongside other tools in decision-making, and requires that consumers have access to the imagery if it influences policy nonrenewal. The bulletin also highlights the need for transparent communication, allowing homeowners to review and contest the imagery used in coverage decisions. Bulletin 2025-02
PHARMACY BENEFIT MANAGERS
Alabama strengthened its regulation of pharmacy benefits managers (PBMs) by establishing new prohibitions and enabling civil actions for parties harmed by PBM violations. The bill mandates minimum reimbursements for independent pharmacies, requires PBMs to pass 100% of manufacturer rebates to clients, and prohibits practices like spread pricing and steering. SB 252
Arkansas amended the Pharmacy Benefits Manager Licensure Act to strengthen regulation of PBMs and healthcare payors. The legislation defines key terms like “carve-out network” and “ghost network,” prohibits unfair practices such as restricting pharmacy choice or misrepresenting provider availability and bans PBMs from imposing unapproved accreditation standards. SB 104
PREMIUM TAX
Delaware issued a bulletin implementing new premium allocation requirements for property and casualty insurers under HB 371. The bulletin mandates the use of a Geographic Information System (GIS) for precise geographic premium reporting starting with the 2023 premium tax report. It also warns insurers against relying solely on ZIP codes for determining risk location and defines "City of Wilmington" using specific ZIP codes. Domestic-Foreign Insurers Bulletin 151
REPORTS - DATA CALLS & OTHER REPORTS
Idaho issued a mandatory data call requiring property and casualty insurers writing homeowners and dwelling fire insurance in the state to submit detailed policy and claims data from 2018 to 2024. The data will support analysis of wildfire-related risk, affordability, and market dynamics. Insurers meeting specific premium thresholds must submit reports by May 20, 2025, using the state’s official reporting template. Bulletin 25-02
Washington informs all property and casualty insurers that they must complete and submit a Special Liability Report Form for the 2024 calendar year. Insurers must submit the form via e-mail to the specified address, ensuring it follows the official layout and avoids including it with other filings such as the Annual Statement or premium tax filing. Special Liability Report Instructions 2024
SERVICE CONTRACTS / WARRANTY INSURANCE
Arizona issued a Policy Statement to guide insurers on complying with service contract regulations. The Department emphasizes that entities offering service contracts must obtain a service company permit and provide a transition period until at least January 1, 2027. Arizona also invites stakeholders to a May 2025 meeting to discuss compliance. Substantive Policy Statement 2025-03 (INS)
SURPLUS LINES
New Jersey's Department of Insurance published updated lists of eligible foreign, domestic, and alien surplus line insurers, including changes such as additions, deletions, name updates, and redomiciled insurers. These updates reflect the latest information from the NAIC Quarterly Listing of Alien Insurers. Notice Dated 4/14/25
TITLE INSURANCE / AGENTS
U.S. Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) for title insurance companies to enhance transparency in residential real estate transactions. The GTO mandates reporting for transactions involving the purchase of residential properties by legal entities with no external financing, requiring title insurance companies to report qualifying transactions to FinCEN within 30 days. The order applies to specific purchase price thresholds and types of payments and requires title insurance companies to retain records for five years. FinCEN Notice Dated 4/14/25
Utah reminds individual and agency title insurance producers to keep their licensing files up to date with the most current information. The Department provides an analysis of relevant sections of the Insurance Code and Insurance Regulation, emphasizing requirements for title insurance agents to maintain accurate business and residence addresses, keep records, and properly reinstate inactive licenses. Bulletin 2025-4
TRADE PRACTICES
New Mexico amended its insurance laws to define treating an insured's inquiry about damage or loss as a claim—when it is not covered by the policy and no payment is made—as an unfair and deceptive practice if performed frequently enough to indicate a general business practice. SB 221
TRAVEL INSURANCE
New Mexico enacted the Travel Insurance Act, creating a regulatory framework for the sale, administration, and provision of travel insurance products. The Act prohibits unfair practices, establishes licensing requirements for travel insurance producers, regulates marketing practices, and outlines eligibility and underwriting standards for travel protection plans. SB 168
WORKERS' COMPENSATION
Arizona updated its workers' compensation laws by increasing the dependent allowance for total disability from $25 to $100 per month. It broadens the definition of "interested party" to include third-party administrators, clarifies how service of notice can be made, and expands fee schedule regulations. SB 1551
Arkansas amended its Workers' Compensation Law by revising the definition of “employee” and replacing the traditional twenty-factor test with the federal Empower Independent Contractors Act criteria for determining employment status. SB 598
Delaware's Compensation Rating Bureau (DCRB) published the Policy Timeliness Compliance Guide to assist insurers in meeting new workers' compensation policy reporting requirements under Phase 1 of the 2025 Policy Data Quality Assurance Program (PDQAP), effective July 1, 2025. The guide outlines how to use the Policy Data Manager (PDM) system to monitor reporting timeliness, avoid fines ranging from $50 to $2,000 for late submissions, and manage policy notifications. Insurers must review the guide, confirm PDM access, and update Policy Contacts ahead of the compliance deadline. DCRB Circular 1050
Ohio amended regulations under the Health Partnership Program, including updates to the 2025 Professional Provider Medical Services Fee Schedule, outpatient medication formularies, and payment rules for hospital and ambulatory surgical center services. The amendments revise fee schedules, adjust medication coverage, and update payment factors for services provided to injured workers. Rule 4123-6-08
Oklahoma's Workers' Compensation Commission announced updates to CC-Form 3. The revised form will include new fields for indicating the need for a courtroom interpreter, the claimant's attorney's email address, and clearer language to distinguish between initial and additional benefits claims. Notice Dated 4/25/25
West Virginia adopted a bill to simplify insurance and workers' compensation regulations by removing certain reporting requirements, including those related to PTSD claims for first responders and flood insurance notifications. It also updates provisions for state agency workers' compensation programs and eliminates outdated sections. SB 856
Newsletter
Life and Health News November 2024
Life and Health News
November 2024
Welcome to our latest newsletter! As a thought leader in the Insurance Industry for over 50 years we are always excited to share the latest sampling of insurance compliance related bulletins, regulations, and legislative activity. Please feel free to share this newsletter with others that may be interested. Contact Us with any questions on the items in this newsletter or with any other compliance related matter we can assist you with. Enjoy!
AFFORDABLE CARE ACT
Federal Department of Health and Human Services, Centers for Medicare and Medicaid Services and the Center for Consumer Information and Insurance Oversight released the 2026 Draft Letter to issuers of Qualified Health Plans (QHPs) and Stand-Alone dental plans (SADPs) in the Federally-Facilitated Exchanges, or the Federally-Facilitated Small Business Health Options Programs (FF-SHOPs) and state-based exchanges on the federal platform. The letter focuses on updates for the 2026 plan year. 2026 Draft Letter dated October 4, 2024
AGENT / PRODUCER CONTINUING EDUCATION
California’s Department of Insurance approved a new 2025 Annuity Eight-Hour Training Course for all life agents, both resident and non-resident. This course is part of the continuing education requirements for California life agents. Effective January 1, 2025, life agents licensed on or after this date must complete the training before soliciting annuity business. Those already holding a lifeline of authority before January 1, 2025, must complete the course by their license's next expiration date, but no later than July 1, 2025. Licensing Notice Dated October 11, 2024
AGENT / PRODUCER TERMINATION
New Mexico’s Insurance Superintendent issued guidelines for the Annual Appointment Renewal Invoices for 2025 for those carriers with New Mexico agent appointments. Letter dated October 2, 2024
Oklahoma’s Insurance Department reminds all carriers to submit any changes to Producer Licensing Appointment contact emails within 20 days of the change. The process and deadline dates for the Producer Appointment Renewal are outlined, with the first deadline being November 15, 2024, when all producer terminations must be entered into NIPR. 2024 Appointment Renewal Notification
ANNUITIES / ANNUITY CONTRACTS
Louisiana's Department of Insurance amended regulations related to annuity sales, requiring producers to act in the best interest of consumers and establish supervisory systems. LAC 37 XIII.11701
Missouri's Department of Commerce and Insurance amended the Suitability in Annuity Transactions rule (20 CSR 400-5.900). The amendments adopt a “Best Interests” standard, requiring producers to prioritize consumers' interests over their own when recommending annuity products. BULLETIN 24-07
ARTIFICIAL INTELLIGENCE
California law mandates that health plans and insurers using Artificial Intelligence (AI) for utilization review and management must adhere to specific guidelines, effective January 1, 2025. These tools must be informed by individual patient medical histories and clinical circumstances, rather than relying solely on group data. It cannot replace healthcare provider decision making. SB 1120
California passed the "Artificial Intelligence Training Data Transparency" law. It requires developers of generative artificial intelligence systems to disclose specific information about the datasets used for training, including sources, data characteristics, and modifications made to the data. Developers must post this documentation on their websites by January 1, 2026. AB 2013
California passed a law requiring autodialing devices to inform consumers when a prerecorded message utilizes an artificial voice. This is effective January 1, 2025. AB 2905
CLAIMS / CLAIMS ISSUES
California passed a law that modified the reimbursement process for healthcare claims effective January 1, 2026. Key changes include transitioning from working days to calendar days for claim reimbursements, with a 15% annual interest rate on late payments for uncontested claims. Health care service plans must also reimburse claims within 30 calendar days and provide written notifications for contested claims, detailing the reasons for denial or contest. AB 3275
CONFIDENTIALITY / PRIVACY
California amended its Consumer Privacy Act of 2018 to require businesses that receive consumer personal information as part of a merger, or other transaction, to comply with a consumer's opt-out request made to the original business. AB 1824
New Mexico's Superintendent of Insurance released a new process for requesting confidentiality of forms filed with the Life and Health Division. Bulletin 2024-18
Oklahoma passed the Insurance Data Security Act in SB 543. It applies to licensees of the Insurance Department that have $5M or more in gross annual revenue that do not have a security program in place pursuant to HIPAA or the Gramm-Leach-Bliley Act. Bulletin 2024-10
CREDIT INSURANCE
South Carolina's Insurance Department approved 2025 credit accident and health insurance rates. Each insurer must notify the Insurance Department by December 1 each year of its intention to use rates no higher than those promulgated. Orders 2024-04 and 2024-06
CYBERSECURITY
Alaska now requires insurers and large broker firms to implement risk assessment and notification protocols for cybersecurity, while exempting smaller brokerage firms. The bill establishes strong data security measures for licensees and producers and requires them to maintain a comprehensive written information security program. The Department requires them to be notified of any significant cybersecurity incident within three business days after it occurs. SB 134
New York's Department of Financial Services alerted all regulated entities to take immediate action to thwart a cybersecurity threat currently being used to gain unauthorized access to information systems and targeting help desks and call centers. Industry Letter dated September 27, 2024
New York's Department of Financial Services issued guidance for regulated entities regarding cybersecurity risks associated with Artificial Intelligence (AI). The Department recommends a series of controls and measures to reduce risk, such as conducting AI-related threat risk assessments and Multi-Factor Authentication which will become mandatory for all authorized users by November 2025. Industry Letter dated September 27, 2024
DISCLOSURE REQUIREMENTS
California amended the Consumers Legal Remedies Act and mandates clearer disclosures in financial product solicitations. AB 3281
DISCRIMINATION
Delaware amended its Insurance Code to prohibit genetics-based discrimination in health insurance, clarifying that "insurance" refers specifically to health insurance and does not cover disability or long-term care insurance. Additionally, a new section addresses genetics-based discrimination in life insurance and annuities. HB 286
EXCEPTED BENEFITS
Michigan's Department of Insurance and Financial Services outlined new federal requirements for Short-Term Limited Duration Insurance (STLDI) and fixed indemnity excepted benefits coverage, replacing Bulletin 2018-20-INS. Bulletin 2024-23-INS
FILING REQUIREMENTS / PROCEDURES
Alabama's Insurance Department issued a new bulletin that revised older Bulletin 2021-06. The older bulletin included a "per filing" fee for various submissions. Specifically, a $50 fee will now apply for each Long-Term Care policyholder letter filing. Bulletin 2024-04
Colorado amended Regulation 4-2-11, specifically focusing on section 5 regarding general rate and dental loss ratio filing requirements. The amendments clarify procedures for rate filing submissions across various insurance types, including dental, long-term care, and Medicare supplement insurance. 3 CCR 702-4
Oregon's Division of Financial Regulation provided updated guidance and expectations to insurers who write Short Term Disability policies in light of the recent implementation of the Paid Leave Oregon program. Insurers must submit updated plan documents as described in the bulletin. Bulletin 2024-8
FRAUD / ANTI-FRAUD
Missouri's Secretary of State issued an emergency rule addressing fraudulent practices by investment advisers and their representatives. The primary aim is to clarify definitions of fraud in connection with securities transactions, specifying that certain behaviors by investment advisers will be deemed fraudulent under the Missouri Securities Act. Emergency Rule 15 CSR 30-51.174
HEALTH INSURANCE / HEALTH RATES
Arkansas's Department of Insurance provided guidelines for healthcare providers regarding the appeals process under the "Gold Card" laws. Providers have 12 months to appeal rescissions of exemptions, with specified documentation needed for eligibility. The bulletin also covers the assignment of an independent review organization, deadlines for reviews, and procedures for appealing disallowances of prescription drug prior authorizations. Bulletin 16-2024
California passed a law requiring health insurance policies starting July 1, 2025, to cover emergency and follow-up care for rape or sexual assault victims without cost-sharing for the first nine months after treatment begins. Additionally, for high deductible health plans, the no cost-sharing benefit applies only after the deductible is met. AB 2843
California passed a law requiring health insurance policies to cover Pediatric Autoimmune Neuropsychiatric Disorder Associated with Streptococcal Infections (PANDAS) and Pediatric Acute-onset Neuropsychiatric Syndrome (PANS). Coverage cannot impose higher cost-sharing requirements than other benefits and cannot be denied or delayed based on prior treatment or different diagnostic names. AB 2105
Colorado's Division of Insurance issued updated guidance on Short-Term Limited Duration Insurance (STLDI) following new federal regulations. STLDI plans can now have an initial term of up to 3 months, with a maximum total coverage period of 4 months if renewed. Specific filing requirements are covered, and new or revised plans must include clear disclaimers, as well as questions about prior nonrenewable short-term coverage. Bulletin B-4.142
MENTAL HEALTH PARITY
California passed a law requiring insurers to include maternal mental health programs that provide at least one screening during pregnancy and one additional screening within the first six weeks postpartum. Further screenings may also be required. AB 1936
MISCELLANEOUS
Arkansas’s Department of Insurance issued a bulletin outlining its service of process requirements. Bulletin 15-2024
Federal Department of Health and Human Services issued a final rule to modify HIPAA privacy standards for reproductive health care. Starting December 23, 2024, all covered entities and business associates must secure a valid attestation for disclosure of certain PHI related to reproductive health care. HIPAA privacy notices should be updated by February 16, 2026. 45 CFR Parts 160 and 164
Federal Final Rule on Mental Health Parity and Addiction Equity Act (MHPAEA) requires health plans to provide mental health and substance use disorder benefits that are comparable to those for medical and surgical services. The rule was released by the Departments of Labor, Health and Human Services and Treasury and published in the Federal Register on September 23, 2024. 89 FR 77586
Federal Internal Revenue Service released its adjustments of certain benefit plan limits for 2025. Contribution limit for health FSAs increases to $3,300, an increase of $100 with a carryover limit of $660. Contribution limit for Health Savings Account for Self Only increased $150 to $4,300 and for Family increased $250 to $8,550. Rev. Proc. 2024-25, Rev. Proc 2024-40
Federal Internal Revenue Service issued guidance that allows amounts paid for condoms to be paid or reimbursed under a health Flexible Spending Account (FSA), Health Reimbursement Arrangement (HRA) and a Health Savings Account. Preventative care benefits provided before a HDHP deductible is met are expanded to include over-the-counter oral contraceptives, including emergency contraceptives, and male condoms. IRS Notice 2024-71, IRS Notice 2024-75
Indiana's Department of Insurance announced the withdrawal of Bulletin 245 concerning Association Health Plans (AHP) on October 15, 2024. This decision followed the U.S. Department of Labor's rescission of the 2018 AHP Rule, which had expanded the definition of "employer" under ERISA to include sole proprietors and small group employers, simplifying the establishment of AHPs. Bulletin 276
Wisconsin's Insurance Commissioner advised carriers, agents and other licensees that the Insurance Department is moving to a new location on November 4, 2024. The Department expects licensees to update the street address anywhere the previous street address appeared on their websites or on policy forms, policyholder notices, and other documents as required by some state statutes or administrative codes.
The new address: Office of the Commissioner of Insurance, 101 E. Wilson St., Madison, WI 53703
PHARMACY BENEFIT MANAGERS
Alaska amended its pharmacy benefit law. This bill implements new requirements for pharmacy benefit managers, such as registering with Alaska's insurance division, disclosing conflicts of interest, and passing on any negotiated discounts with drug manufacturers. HB 226
Arkansas's Insurance Commissioner issued an emergency rule to ensure fair pharmacy reimbursements under the Pharmacy Benefits Manager Licensure Act. Health benefit plans must include a reasonable dispensing cost to maintain network adequacy, and these costs must be uniformly applied across all pharmacies. Health insurers must submit reports detailing their dispensing cost calculations by November 30, 2024, for the 2025 plan year, with future reports due by March 1 for subsequent years. Emergency Rule 128
Delaware passed a law that prohibits discrimination against 340B drugs and covered entities by manufacturers and pharmacy benefits managers. Violations of these provisions are classified as unfair practices in the insurance business. HB 383
REGULATORY REPORTING REQUIREMENTS
Colorado's Division of Insurance announced the quantitative testing reporting requirement referenced in Regulation 10-1-1 is not applicable for the current reporting period due to the absence of an established regulation for such testing. Consequently, the annual report due on December 1, 2024, does not need to include a description of this quantitative testing. However, future reports will be required to include details of the quantitative testing conducted. Bulletin No. B-10.004
REINSURANCE
West Virginia's Insurance Department issued a list of companies that are accredited reinsurers and trusteed reinsurers. Notice dated September 30, 2024
REPORTS - ANNUAL / QUARTERLY STATEMENT
Florida updated insurance regulations regarding reporting requirements. Under section 624.424, certified public accountants preparing annual and quarterly reports for insurance companies are required to complete four hours of insurance-related continuing education every two years. This new regulation adds the continuing ed requirement of four hours of insurance related continuing education every two years to the qualifications for a CPA preparing the annual report and annual audited financial reports. FAC Rule 69O-137.002
REPORTS - DATA CALLS & OTHER REPORTS
New Mexico significantly changed its Surprise Billing Data Call Template. Plan Year 2023 information and data should be filed by December 1, 2024. Plan Years 2019 and 2022 data must be filed by January 6, 2025. Data collection for Plan Years 2021 and 2022 will be announced in the future. Bulletin 2024-20
- Category
- All
- Article
- Download
- Year
- 2026
- Archive
- All Dates