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Property and Casualty News April 2025
Property and Casualty News
April 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
Kentucky authorized the temporary registration of unlicensed emergency adjusters in Daviess, Jefferson, and Oldham Counties following severe weather events. Insurance companies wishing to hire these unlicensed adjusters must submit a Form 8307 Request for Unlicensed Adjusters through the Department's eServices portal for approval. Notice Dated 3/19/25
AGENT / PRODUCER LICENSING AND APPOINTMENT
California issued a notice reminding insurance licensees and applicants that they must report background information changes within 30 days. The mandate applies to individuals and business entities and covers events such as convictions, license actions, and fiduciary breaches. Licensing Notice Dated 3/21/25
AUTOMOBILE INSURANCE
New York issued a circular letter informing insurers of amendments to Insurance Law § 3420(g) regarding supplemental spousal liability (SSL) insurance. Effective March 26, 2025, SSL insurance will be automatically included in motor vehicle policies if the first named insured lists a spouse, with the option to decline it through a written request. Insurers must notify insureds about SSL coverage and provide a new declination form. Circular Letter 2025-2
DISASTER / CATASTROPHIC EVENT
Missouri issued guidelines requiring insurers covering real or personal property to maintain updated catastrophe and disaster coordination contact information with the DOI. The designated contact will facilitate communication with the DOI during and after disasters, handle media inquiries, coordinate consumer outreach, and participate in industry meetings. Insurers are instructed to update their contact information via the UCAA process using Form 14. Bulletin 25-02
FRAUD / ANTI-FRAUD
Delaware reissued a bulletin clarifying insurers' obligation to report suspected insurance fraud. The published bulletin highlights the use of the NAIC’s Model Uniform Suspected Insurance Fraud Reporting Form, allows submission via email or mail, and clarifies options regarding referrals. Insurers are urged to provide accurate contact details. Domestic-Foreign Bulletin 15 (Reissued) (2)
Illinois issued a bulletin clarifying that insurers are not required to participate in regular fraud reporting programs, and such participation remains voluntary under Section 155.23 of the Illinois Insurance Code. The bulletin also encourages reporting workers' compensation and consumer fraud to the Department's designated units, while advising regulated entities to report criminal fraud to the appropriate law enforcement agency. Bulletin 2025-06
Kentucky amended its property and casualty insurance laws to strengthen definitions and penalties related to fraudulent insurance acts. The amendments introduce new terms, such as "criminal syndicate" and "Division," introduce greater penalties for fraud, and expand definitions to include a wider range of insurance policies and documents involved in fraudulent activities. SB 24
GUARANTY ASSOCIATION
Mississippi amended its insurance laws to include cybersecurity insurance under the Mississippi Insurance Guaranty Association statutes. The changes expand the definition of "covered claim" to include cybersecurity-related claims and establish a cap of $300,000 for all first- and third-party claims under a cybersecurity policy. Additionally, the maximum limit per claimant for property damage covered claims is changed to $400,000. SB 2894
HOLDING COMPANIES
Arkansas amended the Insurance Holding Company Regulatory Act to expand oversight and flexibility for domestic insurers and their subsidiaries. The updates define key regulatory terms, allow broader investment activities, introduce group capital and liquidity stress test reporting requirements, and enhance standards for affiliate transactions. SB 236
Idaho updated its insurance regulations to redefine key terms, including "enterprise risk," introduce requirements for insurers when filing annual group capital calculations and to set standards regarding compliance with the NAIC liquidity stress test framework. Additional provisions ensure fair transactions within holding company systems, emphasize confidentiality, and set criteria for exemptions from the annual group capital calculation for smaller insurers. HB 71
Illinois amended provisions related to prior notification of transactions within insurance holding company systems. Under the revised code, the director will disapprove transactions within 30 days of receiving a complete notice if specified standards are not met. The amendment updates the NAIC Accounting Practices and Procedures Manual and introduces new requirements for cost-sharing and management services agreements. 50 Ill. Adm. Code 654.30
North Dakota will increase various fees charged by the Department of Insurance. The renewal fee for the certificate of authority will rise from $100 to $150, the annual statement fee from $25 to $100, and the abstract fee from $30 to $50. Additionally, appointment fees for producers will increase from $10 to $25, while fees for life settlement brokers and providers, public adjusters, and life or health insurance administrators will also see increases. HB 1123
MISCELLANEOUS
Kentucky extended the insurance regulatory sandbox program through 2030 to provide additional time for development and testing of innovative insurance products and technologies within limited regulatory exemptions. Additionally, it established new statutes defining rights and requirements for netting agreements and financial contracts in the event of an insurer’s delinquency, along with updating procedures for the liquidation and rehabilitation of insurers. HB 184
Montana adopted the Pet Insurance Act, which requires insurers disclose exclusions for preexisting conditions, hereditary disorders, and other conditions before selling policies, and provides consumers the right to review and return policies within 15 days for a refund. It also outlines requirements for coverage exclusions, waiting periods, sales practices, and producer training. HB 78
PERSONAL LINES INSURANCE
Maine issued a bulletin addressing the use of aerial imagery by homeowners insurers. The bulletin highlights the importance of using aerial imagery carefully and transparently, advising insurers to provide homeowners with access to the imagery if it affects policy decisions, and ensure that the imagery is recent, clear, and used alongside other tools. Bulletin 483
Ohio amended the Fair Plan Underwriting Association's plan of operation to enhance coverage and operational procedures. The changes increase coverage limits to $2 million for real and personal property, introduce a $10,000 maximum for residential crime insurance, and update definitions. The amendments also refine property inspection processes, eliminate regulatory restrictions, remove gender-specific language, and adjust the maximum liability limits for various coverages. Rule 3901-1-18
PHARMACY BENEFIT MANAGERS
Arkansas enacted the Pharmacy and Pharmacist Timely Reconciliation and Payment of Pharmacist Services Act to regulate pharmacy benefits managers and streamline pharmacy claims processing. The law mandates timely payment for clean claims, imposes penalties for delays, and extends audit protections to the Arkansas Medicaid Program. HB 1620
Florida reminds all pharmacy benefit managers of their obligation to comply with the biennial examination process under the Prescription Drug Reform Act (SB 1550). The Department of Insurance warns that failure to submit required claims data and policies by the established deadlines may result in penalties. OIR Notice Dated 3/24/25
REPORTS - DATA CALLS & OTHER REPORTS
New York issued a data call for all insurers providing medical malpractice insurance on a direct basis. Insurers must complete a survey to determine their obligation to participate in the New York Medical Malpractice Insurance Plan by April 30, 2025. Medical Malpractice Insurance Data Call 2025
New York issued its annual data call regarding private passenger automobile insurance. The data call requires insurers to submit details on underwriting practices, difficult-to-insure vehicles, available discounts, and rate/rule manuals. Insurers must submit the information in specified formats by the given deadline, with possible penalties resulting if any inaccurate data is submitted. Private Passenger Auto Insurance Data Call - 2025
SURPLUS LINES
Connecticut published an updated list of all licensed insurance companies, approved/accredited reinsurers, and surplus lines insurers authorized in the state. Connecticut directs users to the State Based System Lookup Tool for more detailed company information. Notice Dated 3/31/25
New Jersey published an updated list of eligible foreign and domestic surplus line insurers in the state, along with an updated list of eligible alien surplus line insurers from the NAIC Quarterly Listing of Alien Insurers. Notice Dated 3/11/25
Pennsylvania published a new export list, identifying specific insurance coverages deemed generally unavailable in the authorized market. This allows these coverages to be placed in the surplus lines market without requiring a diligent search among admitted insurers in Pennsylvania. The new list, effective immediately, supersedes the previous one published on July 15, 2023. Notice Dated 4/5/25
TRADE PRACTICES
Massachusetts adopted new rules to address unfair and deceptive practices in marketing, solicitation, and sale of products, including those with trial offers or negative option features. The regulation mandates clear disclosure of total prices, including all fees, and requires specific cancellation instructions for trial offers, applying to all acts or practices in Massachusetts. 940 CMR 38.01
WORKERS' COMPENSATION
Alaska published a bulletin establishing new electronic filing guidelines to improve document processing. The bulletin mandates all submissions be in consolidated PDF format and prohibits the use of third-party file-sharing services. Alaska directs filings be submitted via email or its ZendTo service, and warns that noncompliance may result in rejections. Bulletin WC 25-
Colorado updated Rule 11 and DIME-related forms to streamline independent medical examination procedures in workers' compensation cases. The revised forms include changes to applications, notifications, and terminations, with the WC199 now issued as a standalone form. Notice Dated 4/1/25
Idaho amended its workers' compensation law to extend personal liability for failing to secure compensation to members of limited liability companies. The revised law, under section 72-319, now holds LLC members, along with corporate officers and employees, criminally liable for knowingly avoiding workers' compensation obligations. HB 64
Idaho amended its workers’ compensation law to relocate the definition of “member of an employer’s family” to Section 72-102, renumber all following definitions, and correct all code references. HB 65
Idaho increased the maximum allowable burial expenses from $6,000 to $10,000. Under the updated section 72-436, employers must cover funeral, burial, cremation, and transportation costs up to $10,000 if the injury results in death within four years, with payment directed to the person entitled to compensation or the deceased employee’s personal representative. HB 67
Iowa issued a notice regarding a new $8M assessment imposed on insurers and self-insured employers to address insufficient funds in the Second Injury Fund. Both insurers and self-insured employers are required to comply with the assessment due by May 30, 2025. Notices were emailed on March 28, 2025. Notice Dated 3/28/25
Maine amended 39-A Sec. 403 of its Workers' Compensation Act to eliminate the ability of an employer member of a group self-insurer to form workers' compensation fronting company arrangements. SP 67
Oregon introduced a quarterly review process to assess vocational assistance benefits for workers. This review focuses on claims closed after 2018, ensuring compliance regarding workers' eligibility for vocational assistance. Insurers and self-insured employers must accurately evaluate eligibility and respond promptly to WCD requests to avoid penalties. Notice Dated 4/7/25
Texas issued a bulletin clarifying that all insurance companies involved in workers' compensation and employers' liability insurance within the state are to file rates, and all supporting documentation, based on updated loss costs. These filings must be submitted by June 1, 2025, for policies starting on or after July 1, 2025. New entrants must submit filings at least 30 days before their first policy effective date. Bulletin B-0002-25
Newsletter
Life and Health News December 2024
Life and Health News
December 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!
ACTUARIAL
New York issued guidelines for insurance companies regarding the submission of the Actuarial Opinion and Memorandum (AOM) and Risk-Based Capital Checklist due by March 1, 2025. Actuarial Opinion Checklist dated November 20, 2024
AGENT / PRODUCER LICENSING AND APPOINTMENT
Kansas Department of Insurance set the following application fees for insurance professionals: $15 for resident agents and $50 for nonresident agents for calendar year 2025. Notice of Application Fee Amounts
Ohio updated regulations governing agent pre-licensing and continuing education, including requirements for CE courses, providers, and violations. Rule 3901-5-01
Pennsylvania removed the pre-examination education requirements for insurance producer licensing and replaced them with new continuing education mandates. Insurance producers will be required to complete three credits in ethics for most licensees. The law takes effect on April 29, 2025. SB 1241
Wisconsin announced that all company appointments for resident and nonresident agents must be processed electronically through the National Insurance Producer Registry (NIPR) for the 2025 renewal period. The renewal period begins on January 5, 2025, and ends on March 15, 2025. Companies must pay renewal invoices electronically by March 15, and failure to do so will result in termination of agent appointments. Bulletin dated November 14, 2024
ANNUITIES / ANNUITY CONTRACTS
Nevada amended a regulation on annuity suitability. NAC 686A.526
ARTIFICIAL INTELLIGENCE
Iowa issued guidance for insurers regarding the use of Artificial Intelligence (AI) systems, emphasizing compliance with insurance laws, including those against unfair trade practices and discrimination. Insurers must establish an AI Systems (AIS) Program for responsible AI use, ensure the prevention of errors and bias, and be prepared to provide documentation if the use of AI is investigated or examined by the DOI. Bulletin 24-04
Oklahoma's Insurance Commissioner reminded insurers that decisions or actions supported by advanced technologies, including Artificial Intelligence (AI), must comply with all relevant insurance laws and regulations, ensuring fairness and preventing discrimination. Insurers must establish an AI Systems Program (AIS Program) with governance and risk management protocols, among other requirements. Bulletin 2024-11
CAPTIVES
Ohio amended regulations governing captive insurance companies, focusing on modifications to applications, capital and surplus requirements, and financial condition reporting. Rule 3901-11-01
CYBERSECURITY
New York's Department of Financial Services issued a cybersecurity advisory highlighting deceptive practices used by North Korean IT workers, such as fake identities and VPNs, to infiltrate U.S. companies for cyber espionage and illicit financial gain. Carriers are urged to remain on heightened vigilance regarding background checks, identity verification, and technical measures to monitor suspicious activity. Industry Letter dated November 1, 2024
DISCRIMINATION
Delaware updated the definition of “sexual orientation” in its state code to include asexuality and pansexuality alongside heterosexuality, homosexuality, and bisexuality. It also revises the Delaware Insurance Code to prohibit unfair discrimination in the insurance industry based on sexual orientation, including the newly added categories. HB 275
DRUG / PRESCRIPTION COVERAGE
Texas requires issuers of health benefit plans to provide prescription drug information to enrollees or prescribing providers through a standard application programming interface (API) in real time, if requested. Issuers with fewer than 10,000 enrollees can apply for a 12-month extension. Bulletin B-0018-24
ESSENTIAL HEALTH BENEFITS
Alaska announced updates to the Essential Health Benefits benchmark plan, effective January 1, 2026, expanding coverage to include hearing aids, massage therapy, nutritional counseling, chiropractic care, and treatment for TMJ disorders. Notice Dated November 15, 2024
EXCEPTED BENEFITS
New Mexico extended the effective date for compliance with the regulation adopted under the Short-Term Health Plan and Excepted Benefit Act from January 1, 2025, to July 1, 2025. Bulletin 2024-24
FEE SCHEDULES
Hawaii published its comprehensive schedule of fees, taxes, and deposits for insurers, covering areas such as admission fees, service charges, and premium taxes across various insurance classes. Notice dated November 1, 2024
HEALTH INSURANCE / HEALTH RATES
Delaware now requires all group, blanket, and individual health insurance policies to cover prostate cancer screenings for men at risk, including those aged 50 (average risk), 45 (high risk), and 40 (higher risk). Delaware also expanded the definition of "prostate screening" to include methods such as the digital rectal exam and PSA test, while repealing the previous mandate for PSA tests for men aged 50 and older. HB 302
Delaware now requires insurers to provide coverage for speech therapy to treat children diagnosed with certain speech-language disorders, including conditions like expressive language disorder and phonological disorder. The coverage requirements apply to individual, group, and blanket policies issued or renewed after December 31, 2024. HB 273
New Jersey passed two laws requiring medical insurance carriers to cover hearing aids and cochlear implants, and to provide cost sharing caps for diabetes treatment, epinephrine auto-injector devices and prescription asthma inhalers. Bulletin 24-16
Oregon mandated that health insurance policies cover an updated list of prosthetic and orthotic devices. OAR 836-052-1000
HOLDING COMPANIES
Colorado readopted amendments to the "Holding Company System Regulation" to strengthen procedural and reporting requirements for insurance holding company systems. This includes new provisions for the group capital calculation which outlines the criteria for exemption from filing the annual group calculation. 3 CCR 702-3-4
New Mexico promulgated amendments to regulations under the Insurance Holding Company Law. The amendments update definitions, revise provisions related to transactions requiring prior notice, outline new notification requirements and transparency measures for cost-sharing and management services agreements, among other changes. 13.2.2.1 NMAC
INTERNAL AND EXTERNAL REVIEW
New Mexico amended grievance procedures for health care insurers. Changes include expanding the internal panel review period from 5 to 15 days and exempting "limited scope dental" and "limited scope vision" from some grievance procedures. Additionally, the timeline for reviewing administrative grievances by the Superintendent has been extended from 45 to 60 days. 13.10.17.2 NMAC
MISCELLANEOUS HEALTH / ACCIDENT
Colorado amended regulations to strengthen continuity of care requirements for ACA-compliant health plans, excluding short-term policies, ensuring that enrollees maintain access to necessary medical services when providers leave a network or when transitioning between plans. These amendments clarify carrier responsibilities, including notification requirements for network changes and provisions for continuing care with out-of-network providers during active treatment or transitions. 3 CCR 702-4-2-56
Colorado's Department of Labor and Employment updated regulations to ensure private plans for family and medical leave provide benefits and protections equivalent to the state plan. The amendments streamline procedures for approval, maintenance, and compliance of private plans, including the introduction of annual fees, clearer application requirements, and penalties for non-compliance. 7 CCR 1107-5
New Jersey's Insurance Commissioner advised carriers they must update their policies to comply with the federal final rules on Mental Health Parity and Addiction Equity Act and state regulations. Carriers must also file a new state annual report demonstrating compliance by March 1 each year. Bulletin 24-14
PHARMACY BENEFIT MANAGERS
Idaho issued guidance requiring all health insurers that undertake Pharmacy Benefit Manager (PBM) activities to officially register as PBMs. This guidance goes on to outline the compliance obligations for PBMs, effective January 1, 2025. Bulletin 24-05
New Hampshire published guidance on reporting receipt of pharmaceutical rebates by insurers and pharmacy benefits managers. Bulletin INS 24-067 AB
New York promulgated new regulations and amended existing regulations for pharmacy benefit managers (PBMs). 11 NYCRR 450.7+
UTILIZATION REVIEW - HEALTH CARE
Wyoming established requirements for prior authorization processes in health insurance, in line with the "Ensuring Transparency in Prior Authorization Act." These requirements mandate that health insurers and contracted utilization review entities submit and publicly post regular reports on prior authorization statistics, retain compliance records for five years, and file an annual report with the insurance commissioner. Regulation Chapter 72
Newsletter
Property and Casualty News March 2025
Property and Casualty News
March 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
Delaware issued bulletins addressing the roles of insurance adjusters and contractors in property damage claims, focusing on the prohibition of soliciting business during loss-producing events. The bulletins, updated in response to Senate Bill 80, restrict the assignability of insurance policies and prevent contractors from bypassing public adjuster licensing requirements. The Department encourages insurers to educate policyholders on the distinct roles of adjusters and contractors. Domestic-Foreign Bulletin 101 (2nd Rev)
AGENT / PRODUCER LICENSING AND APPOINTMENT
Arkansas issued a bulletin outlining the process for 2025 company appointment renewals for producers. Insurance companies must file annual renewal appointments for producers by May 24, 2025, and terminate any appointments they do not wish to renew. Appointments will remain in effect during active military duty, and companies must complete renewals via NIPR between June 1 and June 30, 2025, or contact the DOI if unable to renew electronically. Bulletin 3-2025
California announced its partnership with Secure Screening Solutions Inc., operating as Capital Live Scan (CLS), to provide Live Scan fingerprinting for California resident insurance license applicants. Applicants must now schedule fingerprinting through CLS's online system, with a fee of $74 covering the DOJ and FBI processing costs. Non-resident applicants must use an FBI fingerprint card through Accurate Biometrics for processing. Notice Dated 2/13/25
New Mexico announced a new online procedure for reporting name changes. All name changes for individuals and business entities must now be submitted through www.NIPR.com, with a $50 penalty imposed on licensees who report name changes more than 30 days after the legal change. The process eliminates the need for supporting documentation, though the OSI may request it. Notice regarding Licensees Name Change
AUTOMOBILE INSURANCE
Louisiana now requires property and casualty insurers to offer a 25% premium discount on automobile liability insurance for active-duty military personnel, military reservists, and Louisiana National Guard members. The discount, as mandated by Act 173 of the 2024 Legislative Session, is available to eligible individuals who submit the "Louisiana Application Form for Military Discount" with verification documents. Insurers may also extend the discount to veterans and retired military members, and may receive tax credits for doing so. Bulletin 2023-04 (Revised and Reissued)
Michigan issued a bulletin, superseding Bulletin 2023-11-INS, to release a revised version of the Michigan Selection of Personal Injury Protection (PIP) Medical Coverage Form and to reissue the Choice of Bodily Injury Liability Form (BI Form). The updated PIP form clarifies coverage options, and applies to both individual and commercial policies, requiring approval for new or revised forms by June 1, 2025. Insurers must also offer PIP medical limits choices and provide consumers with options to opt out based on their qualified health coverage. Bulletin 2025-07-INS
CAPTIVES
Alabama announced a temporary moratorium on the licensing or registration of new captive insurers and risk retention groups. During this time, the Department of Insurance will not accept or process new applications. Captive insurance companies, risk retention groups, and captive managers are advised not to submit any filings or payments. This moratorium may last up to six months, with potential extensions or reductions based on future updates. Bulletin 2025-01
CLAIMS / CLAIMS ISSUES
Delaware’s Department of Insurance issued guidance to clarify the roles of insurance adjusters and contractors in property damage claims. The bulletin addresses issues with licensees soliciting business during loss-producing events, as prohibited by law, and includes updated information about Senate Bill 80, which restricts policy assignability and contractor activities. The Department also urges insurers to educate policyholders on the distinctions between adjusters and contractors. Agents Bulletin 28 (2nd Rev)
CREDIT FOR REINSURANCE
New Jersey issued a bulletin updating the accreditation status of reinsurers, ensuring insurers, agents, and brokers are informed about approved reinsurers, including those domiciled in other jurisdictions. All insurers domiciled, licensed or eligible to write surplus lines insurance in New Jersey will be allowed to take full credit for reinsurance ceded to the listed reinsurer until September 1, 2025. Notice Dated 2/18/25
DISASTER / CATASTROPHIC EVENT
California issued a notice reminding admitted and non-admitted residential property insurance companies of their obligation to provide Additional Living Expenses (ALE) coverage for consumers affected by the Southern California wildfires. The notice emphasizes that ALE coverage must be extended to policyholders whose residences are deemed uninhabitable due to fire damage, as required by SB 872 (2020), until the homes are habitable again. Insurers are instructed to assess habitability and comply with statutory timeframes and policy limits for ALE coverage. Notice Dated 2/14/25
California’s Department of Insurance (DOI) announced a mandatory moratorium on the cancellation and non-renewal of residential property insurance policies in areas affected by wildfires following a state of emergency declaration. Insurers cannot cancel or refuse to renew policies due to wildfire risk in specified ZIP Codes for one year and must offer to rescind any prior notices of cancellation or non-renewal. The DOI may expand the moratorium to additional ZIP Codes impacted by wildfires through future bulletins. Bulletin 2025-6
DISCRIMINATION
Alabama will implement changes to its laws effective October 1, 2025, to clarify and standardize definitions related to sex discrimination and equality. The amendments to the Code of Alabama 1975 establish clear definitions of sex-based terms, mandate equal protection against sex discrimination for both males and females, and require entities collecting vital statistics to identify individuals as either male or female. SB 79
FEE SCHEDULES
Michigan issued a bulletin announcing a 13.12% Fee Schedule Consumer Price Index (CPI) Adjustment for amounts payable under MCL 500.3157(7) or MCL 500.3157(8) for dates of service from July 2, 2025, through July 1, 2026. This adjustment includes a 10.16% increase from Bulletin 2024-08-INS, along with an additional 2.69% adjustment for the current year. The bulletin supersedes Bulletin 2024-08-INS and includes a table outlining fee schedule adjustments for recent periods. Bulletin 2025-05-INS
MISCELLANEOUS PROPERTY / CASUALTY
Michigan issued an updated list of municipalities participating in the Fire Insurance Withholding Program, effective April 1, 2025. This list outlines the specific sections of the program under which each municipality is involved and replaces previous editions. Insurers must be given at least 30 days' notice before new municipalities begin applying the program's provisions. Notice Dated 2/28/25
PREMIUM TAX
Florida adopted new regulation outlining how insurers must report premium tax discounts on policies issued between October 1, 2024, and September 30, 2025. The rule mandates that insurers clearly list the discounts on the declarations page and refers to a form for reporting this information to the Department of Insurance. It applies to policies under the premium tax statutes 624.509 and 624.515, specifying various discounts. FAC Rule 69O-171.013
Wisconsin has adopted the OPT/ns system, developed by the NAIC, for insurers to submit and pay Wisconsin premium taxes, fire department dues, and fees. Starting April 15, 2025, insurers must use this system for all premium tax payments, with tax forms available exclusively through OPT/ns for the 2025 filing year. Bulletin Dated 2/27/25
PROPERTY INSURANCE
California published updated guidance for FAIR Plan member insurers on the procedure to request prior approval for recouping FAIR Plan assessments from policyholders under Proposition 103. Following the January 2025 wildfires and a $1 billion assessment on insurers, the DOI allows insurers to recover up to 50% of assessment amounts, with higher recoupment for assessments exceeding $1 billion. Insurers must submit rule-change applications with detailed documentation to the DOI within six months for approval. Bulletin 2025-4
Florida directs insurers to provide additional data to the Office of Insurance Regulation (OIR) regarding property damage claims from the 2024 Hurricane Season, particularly for wind and water damage. This initiative aims to address concerns over concurrent causation claims, especially those involving flood-related damages under the National Flood Insurance Program. OIR Notice Dated 2/20/25
New Hampshire issued a bulletin addressing the use of aerial imagery in underwriting decisions for property and casualty insurance. The bulletin clarifies that insurers cannot refuse to write or renew policies based solely on cosmetic issues, such as roof discoloration, unless there is clear evidence of property degradation or damage. Insurers must conduct a physical inspection to verify any concerns raised by aerial imagery, especially if the property owner disputes the findings. Bulletin INS 25-016-AB
REPORTS - DATA CALLS & OTHER REPORTS
North Carolina issued a bulletin informing property and casualty insurers about the annual reporting requirements for homeowners insurance covering residential real property with up to four housing units. Insurers must report data, including consent-to-rate information, for policies such as HO-2, HO-3, HO-5, HO-7, and HO-8, with the deadline for submission set for March 27, 2025. Detailed instructions and forms are available on the Department's website. Bulletin 25-B-02
SURPLUS LINES
West Virginia released a notice providing a report on the 237 surplus lines insurance companies operating in the state. The report covers both foreign and alien insurers across all lines of business and includes key details about each company, such as name, domicile type, and various identification numbers, including FEIN and NAIC Company Code. Notice Dated 2/13/25
TAX CREDITS
Nebraska amended its regulations to expand the accessibility of the Nebraska Affordable Housing Tax Credit and the Nebraska Childcare Tax Credit. The amendments include allowing insurance companies to receive tax credits under the Child Care Tax Credit Act, clarifying eligibility for affordable housing tax credits, and adjusting the process for allocating, transferring, or selling these credits. LB 182
THIRD PARTY ADMINISTRATORS
Puerto Rico adopted a new rule to regulate third-party administrators (TPAs) in Puerto Rico. This rule standardizes the registration and licensing process for TPAs involved in life, annuities, health insurance, and stop-loss coverage, and mandates that TPAs must submit a detailed application, pay a $2,500 licensing fee, and comply with various operational and reporting requirements. Rule CXI s 1
TITLE INSURANCE / AGENTS
California reminds title insurers, underwritten title companies, and controlled escrow companies of their obligation to comply with title insurance filing requirements under the California Insurance Code. These entities must file their schedules of rates and policy forms with the DOI, ensuring the rates are fair, not discriminatory, and not used before their effective date. Bulletin 2025-5
UNCLAIMED PROPERTY
Arkansas will now allow for the direct payment or delivery of unclaimed property to apparent owners. This amendment to Section 18-28-215 removes the need for formal claims, and enables the administrator to directly transfer property under certain conditions, including the individual being named in a report, the administrator's reasonable belief of entitlement, and the property's value not exceeding $5,000. SB 14
WORKERS' COMPENSATION
Alaska's Department of Labor and Workforce Development issued a bulletin updating travel allowances for medical treatment under the Alaska Workers' Compensation Act. The bulletin establishes a mileage reimbursement rate of $0.700 per mile for private vehicle use within Alaska, and outlines lodging and per diem reimbursements based on the Alaska Department of Administration's rate tables. It also introduces a shift to using the Division's 'What’s New' email system for future updates regarding travel allowances. Bulletin WC 25-01
Alaska's Workers' Compensation Division will implement several rule changes concerning reemployment benefits and the stay-at-work program. These updates include new requirements for document service and procedures for employers opting out of stay-at-work plans. It will also introduce timelines for plan approvals, modifications to the rehabilitation specialist's responsibilities, and adjustments to reemployment benefit eligibility criteria and notification deadlines. Memorandum regarding 8 AAC 45.040+
California's Division of Workers' Compensation (DWC) announced that all mandatory settlement conferences, status conferences, lien conferences, and priority conferences will be held through the CourtCall Video Platform. To assist participants, DWC has created a dedicated webpage with virtual courtroom links, training videos, and written guides. DWC Notice Dated 2/27/25
California's Workers' Compensation Insurance Rating Bureau (WCIRB) announced its participation in the 2025 NAIC and FIO Terrorism Risk Insurance Data Calls. The WCIRB will submit California workers' compensation terrorism exposure data, including policy counts, payroll, and terrorism premiums, to the NAIC to help assess insurance coverage and financial exposure related to terrorism risk. Insurers must also register for the FIO data call and provide additional specific data elements not covered by the WCIRB. WCIRB Bulletin 2025-02
California's Workers' Compensation Insurance Rating Bureau (WCIRB) updated its Policyholder Notice PN 04 99 01 J to inform insured employers about their rights regarding rating and dividend information, and the procedures for disputing and appealing insurer and WCIRB actions. The notice now includes WCIRB’s updated address and clearer instructions for the insurer’s office designated to receive complaints. Effective June 2025, insurers must provide this notice with each policy and include the necessary contact information for disputes and the policyholder ombudsman. WCIRB Bulletin 2025-04
Delaware's Compensation Rating Bureau (DCRB) announced the implementation of its Late Reported Policy Timeliness Initiative as part of the 2025 Policy Data Quality Assurance Program (PDQAP), effective July 1, 2025. The initiative requires insurers to submit policy data within 30 days of the policy’s effective date and introduces fines for late submissions. DCRB will provide automated notifications and a Late Policies Report to assist insurers. DCRB Circular 1048
Massachusetts released a bulletin updating the Residual Market Share for the Workers' Compensation Assigned Risk Pool. The bulletin reports that the estimated ultimate residual market share for the year ending December 31, 2024, is 12.3%, showing a consistent decline from previous years, such as 14.0% in November 2021. It also compares these estimates to those based on Annual Statement Data. WCRIBMA Special Bulletin
Nevada's Division of Industrial Relations (DIR) issued a memorandum outlining updates to its audit and medical units' practices regarding fines for non-compliance with industrial insurance and occupational disease regulations, effective June 28, 2024. The updated structure introduces a graduated fine schedule for insurers and Third Party Administrators (TPAs) who fail to comply with filing requirements. Memo Dated 2/11/25
New Jersey's Compensation Rating and Inspection Bureau announced that it is expanding the Indemnity Data Call (WCIND) to improve analysis, research, and industry consistency by incorporating new data elements in line with the Workers Compensation Insurance Organizations' (WCIO) electronic data specifications. These updates will take effect with Fourth Quarter 2025 data, due by March 31, 2026, and will be included in the updated Indemnity Data Call Reporting Guidebook. Circular Letter 2082
Newsletter
Property and Casualty News July 2025
Property and Casualty News
July 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!
ARTIFICIAL INTELLIGENCE
Maine now requires clear disclosures when an AI chatbot is used in consumer transactions to prevent consumers from being misled into thinking they are interacting with a human. Violations are considered breaches of the Maine Unfair Trade Practices Act. HP 1154
CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE
Louisiana adopted rules allowing insurers to nonrenew or cancel up to 5% of homeowners policies in effect for at least three years as of August 1, 2024, without prior approval. Insurers must submit a detailed plan to the Department of Insurance, with any plan exceeding the 5% threshold statewide or in a single parish requiring the commissioner’s approval. LAC 37:XIII.20201
Montana issued an advisory reminding property and casualty insurers that they cannot refuse coverage in areas without a substantially increased wildfire risk to prevent unfair discrimination. Insurers must base decisions on actual wildfire threats, and unjustified refusals or cancellations will be investigated. Memo Dated 7/2/25
CAPTIVES
Louisiana amended and reenacted Subpart S of Title 22 to modernize the regulation of captive insurance companies under the newly named "CHOICES Law". Key updates include expanded definitions, revised capital and surplus requirements, clarified regulatory oversight, new provisions for redomestication and dormancy, and detailed rules on affiliated reinsurance and branch captive companies. HB 635
COMMERCIAL LINES INSURANCE
Florida amended the My Safe Florida Condominium Pilot Program under Section 215.55871, narrowing eligibility to specific condominium structures and imposing stricter conditions for participation. Condominium associations may now apply for hurricane mitigation inspections or grants only if certain criteria are met, and grant funds may be used solely for approved water intrusion mitigation improvements identified in a final inspection. HB 393
Florida enacted amendments to statutes governing condominium and cooperative associations. Changes include updated property insurance requirements based on replacement cost or windstorm loss models and clarified rules on reserve funding and hurricane protection costs. HB 913
CONFIDENTIALITY / PRIVACY
Oklahoma issued a bulletin addressing updates to the insurance Data Security Act which sets comprehensive data security and cybersecurity event reporting requirements for licensed entities under Title 36. The Act, aligned with NAIC standards, mandates annual information security program reports, cybersecurity event notifications within three business days, and submission of Data Security Attestation forms, while outlining exemptions, compliance deadlines, and record retention rules. Bulletin 2024-10 (Revised)
DISASTER / CATASTROPHIC EVENT
Hawaii Department of Insurance reactivated the Hawaii Hurricane Relief Fund (HHRF) to provide excess hurricane property insurance coverage for Condominium and Townhouse Associations of Apartment Owners (AOAOs) amid ongoing market instability. Eligible AOAOs denied coverage by at least two insurers and with buildings valued over $10 million can apply for excess coverage above $10 million. Memorandum 2025-2A
Hawaii urges all insurers covering residential and commercial properties in affected areas of the August 2023 Maui wildfires to voluntarily extend or be flexible with timeframes for policyholders to complete repairs or replacements. Memorandum 2025-1A
New Mexico issued an Emergency Order following the governor’s declaration of a state of emergency in Grant County due to the Trout Fire. The order requires health, property, casualty, and automobile insurers to provide 90-day premium grace periods, waive deductibles and fees, postpone cancellations, extend claims reporting deadlines, and offer payment plans. Emergency Order Dated 6/17/25
FRAUD / ANTI-FRAUD
Louisiana passed a bill amending R.S. 22:1923 to strengthen anti-fraud provisions by expanding the definition of a fraudulent insurance act to include knowingly altering repair estimates—original, revised, or supplemental—without proper documentation or notification to the estimate issuer. SB 34
MISCELLANEOUS
Alabama issued guidance on the use of aerial imagery in property insurance decisions, emphasizing that it must be used carefully and not as the sole basis for actions like non-renewals or claims decisions. Insurers are urged to ensure imagery is recent, accurate, and supported by clear communication with policyholders, including notice, evidence sharing, and time for response or repairs. Bulletin 2025-03
Arkansas adopted new rules to provide automatic and expedited licensure for military service members, veterans, and their spouses. Additional provisions include license extensions, exemptions from continuing education, and recognition of military training and credentials toward licensure requirements. Regulation 20 Section 1
Maryland issued a bulletin guiding property and casualty insurers on the proper use of satellite or aerial imagery in cancellations, nonrenewals, and claim settlements, emphasizing that only clear, accurate, and current images can justify such actions. Insurers must provide insureds with reasons and an opportunity to respond, and unclear or outdated images cannot support adverse decisions without further investigation. Bulletin 25-10
Michigan released an updated list of municipalities participating in the Fire Insurance Withholding Program, effective August 1, 2025. The program allows certain municipalities to escrow 25% of fire insurance settlements for property losses, with participation and applicable perils varying based on municipality and county population. Notice Dated 7/1/25
New Jersey issued a bulletin requiring licensed insurers with over $100 million in direct written premiums nationwide to complete the NAIC Climate Risk Disclosure Survey for the 2024 reporting year, aligned with the TCFD framework. Responses are due by August 29, 2025, and may be submitted via a web application or as self-contained documents. Bulletin 25-05
PERSONAL LINES INSURANCE
Hawaii increased the required notice period that property insurers must give policyholders before canceling residential property insurance policies, including cancellations for nonpayment. The notice period increased from at least 10 days to at least 20 days. SB 752
Louisiana amended Sections 22:1508–1510 to enhance consumer protections regarding the use of credit information in personal insurance underwriting. Insurers must now disclose credit use at application, provide clear reasons for adverse actions, and submit credit scoring models for regulatory review. SB 61
Oregon adopted a new bill requiring insurers that renew qualified homeowner and personal insurance policies to disclose up to four significant factors contributing to any premium increase, such as driving record, claims history, or changes in base rates, and to inform insureds of their right to request an explanation. Insurers must respond to written requests within 20 days, while certain policies and proprietary information are exempt. HB 2563
PROPERTY INSURANCE
Oklahoma issued a special notice to property and casualty insurers, clarifying that all building codes must be considered strictly enforced for additional coverage purposes under ordinance or law exclusions. Insurers should provide additional coverage for increased costs related to building code requirements regardless of whether the local authorities actively enforce the codes. Special Notice Dated 6/26/25
RATEMAKING
California reminds property and casualty insurers that under Proposition 103, all rates must receive prior approval, including those for large commercial risks. Continued use of unapproved rating arrangements may result in enforcement actions and substantial penalties. Bulletin 2025-11
Connecticut extended the sunset date for its personal risk insurance “flex rating” law from July 1, 2025, to July 1, 2030. This law allows property and casualty insurers to file new personal risk insurance rates—such as for home, auto, or umbrella policies—and use them immediately without prior approval under specific conditions. HB 6897
REGULATORY REPORTING REQUIREMENTS
Louisiana now requires insurers authorized to write auto or property insurance to notify the Department of Insurance within 10 days of deciding to cease, pause, or resume issuing new policies in any region. The notice must include details such as the effective date, affected lines, impacted areas, and the reason for the change. SB 137
REINSURANCE
Connecticut published the updated list of licensed insurance companies, approved/accredited reinsurers, and surplus lines insurers in Connecticut as of June 30, 2025. The list includes details such as company name, domicile, and group number. Notice Dated 6/30/25
REPORTS - DATA CALLS & OTHER REPORTS
Indiana issued a bulletin requiring insurers, TPAs, and PBMs to annually report detailed ownership information, such as identities and business details of anyone holding 5% or greater ownership or control, under Public Law 239-2025 (HEA 1666). Non-compliance may result in daily fines of $1,000 and disciplinary actions, with a grace period for the first reporting cycle. Bulletin 279
Louisiana issued advance guidance for the 2025 hurricane season, requiring property and casualty insurers (including private flood and surplus lines) to prepare for mandatory claims data submissions after a named storm or hurricane. Separate directives will follow each storm, specifying reporting schedules and formats. Group filings are permitted for holding companies (excluding surplus lines), which must report individually. Bulletin 2025-04
TRADE PRACTICES
Louisiana reminds insurers, producers, and adjusters that Assignment of Benefits (AOB) agreements under residential or commercial property insurance policies are prohibited. Any such agreements are null, void, and unenforceable. The prohibition includes post-loss benefit transfers to contractors, public adjusters, or mitigation providers, but excludes assignments to mortgagees, federally insured institutions, or liability coverage. Violations may be deemed unfair or deceptive trade practices and are subject to enforcement and penalties. Advisory Letter 2025-02
WORKERS' COMPENSATION
California's Division of Workers' Compensation launched a new website featuring a live Pharmaceutical Fee Calculator to support the new Pharmacy Fee Schedule. The tool allows the public to calculate fees based on the updated schedule and includes additional information and a link for access. DWC Release 2025-59
Delaware's Compensation Rating Bureau (DCRB) will begin enforcing Phase 1 of its Policy Data Quality Assurance Program (PDQAP) which includes imposing financial penalties on commercial property and casualty insurers for late submission of policy data. Policies reported 36 days or more after the effective date will be fined on a tiered scale. DCRB Circular 1058
Iowa's Workers’ Compensation Division released its annual bulletin updating mileage reimbursement to $0.70 per mile and revising weekly workers’ compensation benefits for Temporary Total Disability, Healing Period, Permanent Partial and Total Disability, and Death benefits effective July 1, 2025, through June 30, 2026, based on a Statewide Average Weekly Wage of $1,174.98. Notice Dated 6/18/25
Kansas Department of Labor – Workers’ Compensation Division has published updated maximum weekly and total compensation amounts for injuries occurring between July 1, 2025, and June 30, 2026. These limits apply to benefits including Permanent Total, Temporary Total, and Permanent Partial Disability (excluding TTDI), as well as death, funeral, unauthorized, and authorized medical expenses. WC Notice of Maximum Benefit
Missouri's Division of Workers' Compensation updated the State Average Weekly Wage to $1,219.85 for July 1, 2025–June 30, 2026, setting maximum weekly benefit rates for workers’ compensation, including $1,280.84 for Temporary Total Disability, Permanent Total Disability, and Death benefits. Notice Dated 7/1/25
New Hampshire's Department of Labor published the state’s average weekly wage (SAWW) effective July 1, 2025, which is $1,539.13. DOL Notice of June 2025
New Jersey’s Compensation Rating and Inspection Bureau announced that carriers are no longer required to submit physical Notice of Election (NOE) forms for Large Risk Large Deductible Program and Retrospective Rating plans, but must retain internal documentation for audits and regulatory purposes. The Bureau will no longer acknowledge NOE submissions via its web portal, and carriers may continue using the existing form until system updates are complete. Circular 2501
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