Resources
Newsroom
Newsletter
Property and Casualty News November 2025
Property and Casualty News
November 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 LICENSING AND APPOINTMENT
California eliminated the 20-hour pre-licensing coursework requirement for certain Department of Insurance license applicants, retaining only the 12-hour ethics course certification and allowing CDI to charge associated fees. AB 943
Oklahoma issued the 2025 Appointment Renewal Notification outlining procedures and deadlines for insurers to renew producer, limited lines, title, motor service club, and managing general agent appointments. Renewals must be completed electronically via NIPR between November 25 and December 31, 2025, with fees due by the December 31 deadline; failure to pay results in termination of all appointments. The bulletin goes on to provide detailed guidance on payment methods and transaction fees. 2025 Appointment Renewal Notification
CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE
Mississippi issued guidance implementing HB 1611, which requires property and casualty, automobile, and workers’ compensation insurers to provide at least 45 days’ notice before policy renewal, cancellation, reduction of coverage, or non-renewal for policies issued or renewed on or after July 1, 2026. The bulletin clarifies compliance deadlines, defines reductions in coverage, addresses transfers of workers’ compensation policies to affiliates, and outlines policyholder rights if notice is not properly provided. Insurers must update their systems and submit amended forms via SERFF by February 28, 2026. Bulletin 2025-5
CAPTIVES
Alabama clarified that the temporary moratorium on licensing or registration of captive insurance companies under Bulletins 2025-01 and 2025-05 does not apply to registration applications from foreign risk retention groups, which will continue to be processed as usual by the Department. Clarification to Bulletins 2025-01 and 2025-05
CLAIMS / CLAIMS ISSUES
Michigan released a bulletin addressing improper claims administration practices in the automobile insurance industry, emphasizing compliance with the Insurance Code to ensure prompt, fair, and equitable claim handling. The bulletin identifies abusive practices such as misrepresentations, delayed investigations, underpayment of claims, and improper handling of total-loss vehicles. DIFS will investigate complaints and may impose sanctions, including fines or suspension/revocation of an insurer’s certificate of authority. Bulletin 2025-25-INS
New Mexico amended its Unfair Claims Practices law, adding a new subsection to prohibit insurers from treating inquiries about damage or loss as claims when no payment is made, the policy does not cover the inquiry, and the inquiry involves no deceptive conduct. This applies to all property and homeowner’s insurers. Bulletin 2025-010
CREDIT INSURANCE
Massachusetts issued a bulletin updating deviated case rates for credit life and credit accident and health insurance sold through motor vehicle dealers. Effective for policies issued or renewed from January 1, 2026, through December 31, 2028, single life insurance is set at $0.70 per $1,000 of coverage per month, joint life at $1.12, and credit accident and health insurance rates vary by year of coverage, starting at $0.70 per $100 of indebtedness. Bulletin 2025-05
CYBERSECURITY
Delaware issued a warning to regulated entities about an active phishing campaign targeting insurance carriers, TPAs, and others, involving fraudulent emails impersonating the DOI. The bulletin advises recipients not to click links or download attachments, to verify sender addresses, and to follow organizational cybersecurity protocols. The DOI emphasizes vigilance, staff training, and proactive security measures to protect sensitive information. Universally Applicable Bulletin 10
DISCRIMINATION
Delaware issued guidance on House Substitute 1 for House Bill 55 which prohibits unfair discrimination in insurance based on military status. Insurers may not deny, cancel, exclude, or modify coverage solely due to an individual’s military status, applying to active-duty service members, reservists, veterans, and their dependents. Carriers must update operational materials, maintain documentation for any legally authorized distinctions, and ensure marketing, sales, and claims practices comply with the Act. Domestic-Foreign Insurers Bulletin 161
FILINGS: PROPERTY / CASUALTY
Massachusetts issued filing guidance for insurers on new disclosure requirements addressing “junk fees” and Negative Option Features in personal lines property and liability insurance. Starting March 2, 2026, policies with these features must include both the insurance application and a separate policyholder notice meeting disclosure requirement sent 30 to 5 days before automatic renewal or action deadlines. All related forms must be submitted via SERFF by November 28, 2025. Filing Guidance Notice 2025-T
FEDERAL GOVERNMENT SHUTDOWN RELIEF
Alabama encourages insurers to offer reasonable accommodations, such as payment plans or premium extensions, to policyholders affected by the federal government shutdown. The Department advises impacted federal employees to contact their insurers directly to discuss available options. Bulletin 2025-07
Arizona issued a bulletin urging insurers to provide at least 60 days of relief to policyholders affected by the federal government shutdown. Recommended measures include extending grace periods, delaying cancellations, waiving late fees, and offering flexible payment plans. The Department clarified that such actions will not violate the Unfair Trade Practices Act if applied fairly and consistently. Bulletin 2025-10 (INS)
California released a notice urging insurers and related entities to provide protective measures for policyholders affected by the federal government shutdown, particularly federal employees. The DOI requests grace periods for premium payments, postponement of cancellations or non-renewals, and extensions or waivers of claim and underwriting deadlines for at least 30 days or through the duration of the shutdown. Notice of October 23, 2025
Colorado urges insurers to provide relief to policyholders affected by the federal government shutdown, particularly federal employees. Recommended measures include a 30-day grace period for premium payments, waiving late fees and penalties, offering flexible payment options, and clearly communicating available support to prevent coverage lapses or cancellations. Bulletin B-6.05
Connecticut released a bulletin directing insurers to provide at least a 60-day grace period or flexible payment options for federal employees affected by the ongoing government shutdown. The bulletin applies to life, health, auto, property, casualty, and other insurance lines, aiming to prevent cancellations or penalties for nonpayment of premiums while maintaining policy terms. Bulletin IC-46
Delaware released a bulletin guiding insurers to provide relief for federal employees affected by the government shutdown. Carriers are encouraged to offer at least a 60-day premium payment grace period, suspend late fees and penalties, refrain from cancellations or non-renewals due to nonpayment, accept proof of federal employee status, and provide extensions for property repairs. These accommodations should remain in effect during the shutdown and for 30 days afterward. Domestic-Foreign Insurers Bulletin 160
Illinois requests property and casualty insurers protect federal employees affected by the government shutdown. Insurers are asked to place a moratorium on cancellations or non-renewals for unpaid premiums for at least 30 days or through the shutdown, with an additional 30-day extension if compensation remains unpaid. The bulletin also requests extending repair deadlines by at least 30 days for consumers unable to complete repairs within policy timeframes. Bulletin 2025-17
Maine issued a bulletin urging licensed insurers to provide relief to policyholders affected by the federal government shutdown, including federal employees and those dependent on federal funding. Carriers are encouraged to offer a minimum 60-day grace period for premium payments or flexible payment options to prevent cancellations or penalties, while maintaining policy terms. Bulletin 488
Oregon asks insurers to assist policyholders affected by the federal government shutdown by offering at least a 30-day grace period for premium payments, refraining from cancellations or non-renewals, waiving or providing flexible options for late fees, and extending deadlines for claims or other communications. Insurers are also encouraged to proactively communicate available assistance and ensure customer service and producers are prepared to support impacted individuals. Bulletin DFR 2025-8
MISCELLANEOUS
Colorado adopted rules requiring insurers to respond to requests for commercial or personal automobile policy information and certified copies of homeowner insurance policies within 30 calendar days of receipt. Insurers must provide copies of the requested policies, retain records of requests and responses for the current year plus two prior years, and, if the Commissioner is the registered agent, provide an electronic mailing address to facilitate submissions. 3 CCR 702 Reg. 5-1-27
Tennessee advises insurers to use aerial imagery responsibly in property and homeowners insurance, ensuring it is recent, accurate, and supplemented by physical inspections. Homeowners must be notified, allowed to review or dispute imagery, and given time for repairs before adverse actions. Relying solely on outdated or unclear imagery for claims or policy decisions is considered an unfair practice, and noncompliance may result in penalties. Bulletin 25-03
PERSONAL LINES INSURANCE
California requires insurers effective 1/1/26, after a total dwelling loss due to a declared state of emergency, to offer 60% of personal property coverage limits (up to $350,000) without an itemized claim and extends the proof-of-loss deadline to 100 days. The bill also enacts the Insurance and Climate Risk Market Intelligence Act, requiring large admitted insurers to annually report reinsurance and catastrophe model data to the Department of Insurance. SB 495
Colorado issued a bulletin to clarify that auto insurance deductibles are the policyholder’s contractual responsibility and to prohibit insurers from participating in or condoning arrangements where repair shops waive deductibles. Insurers must ensure producers and representatives do not promote deductible waivers, communicate this obligation to policyholders, and investigate or report any instances of deductible waivers that may constitute fraud or violate state law. Bulletin B-5.54
PHARMACY BENEFIT MANAGERS
California has enacted reforms governing pharmacy benefit managers (PBMs) and prescription drug cost-sharing. The bill establishes fiduciary duties for PBMs, prohibits spread pricing, mandates passthrough pricing and full rebate disclosure, and bans discriminatory practices against nonaffiliated pharmacies. It also bars insurers from charging enrollees cost-sharing amounts exceeding what the plan actually pays for prescription drugs and requires contracts and oversight measures to ensure compliance. SB 41
New Mexico updated its licensing and compliance procedures for Pharmacy Benefit Managers (PBMs) under the Pharmacy Benefits Manager Act. PBM license applications must now be submitted through the Company Licensing Bureau, with renewal and annual report fees required by March 1 each year, while compliance reporting is completed via SERFF. The bulletin details required documents, reporting deadlines, and confidentiality procedures, emphasizing that noncompliance may result in penalties. Bulletin 2025-011
PROPERTY INSURANCE
California amended its Civil Code Section to expand the unenforceability of restrictive covenants that limit residential use, extending protections to developments redeveloping commercial properties for housing under state or local housing laws. The bill also applies these provisions to restrictions in reciprocal easement agreements and requires county officials to verify eligibility and record modification documents for qualifying affordable housing developments. AB 1050
California extended existing wildfire-related non-renewal protections to commercial property insurance policies. Under new Insurance Code Section 675.55, insurers are prohibited from canceling or refusing to renew commercial property insurance for one year after a declared state of emergency if the property is within or adjacent to the fire perimeter, except under specified conditions such as willful misconduct or material risk changes. SB 547
Virginia clarified that labor and other nontangible costs (e.g., taxes, fees, overhead, profit) cannot be depreciated when calculating actual cash value (ACV) for property insurance claims. Only physical property may be depreciated, and improper depreciation of labor or intangibles constitutes an unfair claims settlement practice. This guidance applies to all insurers writing fire, homeowners, or dwelling property insurance in Virginia. Administrative Letter 2025-06
REPORTS - DATA CALLS & OTHER REPORTS
Texas published a bulletin requiring licensed property and casualty insurers (excluding farm mutuals and surplus lines) to submit 2025 annual experience and workers’ compensation deductible data by February 6, 2026. The data supports TDI’s annual report to state leadership and the public and must be retained until February 6, 2027. Forms and instructions are provided by TDI. Bulletin B-0016-25
SURPLUS LINES
Alabama adopted the SLIP+ for States platform for reporting and payment of surplus line policy data and taxes, replacing the NAIC’s OPTins platform. Surplus line brokers and non-admitted carriers must use SLIP+ for States for policies effective on or after January 1, 2026, with a 6% surplus line tax and a 0.175% transaction fee applied to each transaction. The bulletin also outlines quarterly and annual reporting and payment procedures, with annual tax remittances due by March 1 each year. Bulletin 2025-06
Connecticut issued a bulletin to revise and clarify surplus lines placement requirements for Property & Casualty licensees, superseding Bulletins SL-3 and SL-5. The bulletin updates the diligent effort requirement for brokers, electronic tax filings through OPTins, and guidance for flood insurance and exempt commercial purchasers. Bulletin SL-6
Delaware reminds licensed Surplus Lines Brokers of their responsibility to collect and remit annual premium taxes on surplus lines policies, as required under 18 Del. C. Section 1925. The published bulletin details mandatory electronic filing forms through OPTins, due dates, submission requirements, and the use of individual Delaware license numbers, emphasizing that brokers, not producers, are solely responsible for compliance. Surplus Lines Bulletin 22
TITLE INSURANCE / AGENTS
FinCEN renewed its Geographic Targeting Orders (GTOs), now requiring title insurance companies to identify the natural persons behind shell companies in non-financed residential real estate purchases. The orders apply to specified counties in major metropolitan areas across 14 states and D.C., with a $300,000 purchase threshold ($50,000 in Baltimore), and aim to prevent illicit activity in the real estate market. Compliance resources and guidance are available on FinCEN’s website. FinCEN Notice Dated 10/9/25
WORKERS' COMPENSATION
Arizona approved a 6.7% reduction in Workers’ Compensation rates effective January 1, 2026, marking the 12th consecutive year of decreases. The reduction, based on NCCI’s annual rate filing, reflects declining claims frequency and utilization. Notice Dated 11/3/25
California expanded worker safety protections in the artificial stone fabrication industry by classifying silicosis and silica-related lung cancer as “serious injuries or illnesses” under the Labor Code. The amendments also update the definition of “serious physical harm” to include these conditions, strengthening penalties and oversight for workplace safety violations involving silica exposure. SB 20
California updated the inpatient hospital section of the Official Medical Fee Schedule (OMFS) to align with recent Medicare payment system changes. The revised fee schedule takes effect December 1, 2025, with additional details are available on the Division of Workers’ Compensation website. DWC Release 2025-110
Newsletter
Life and Health News August 2024
Life and Health News
August 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
Maryland updated its Health Benefit Exchange regulations to address changes to the re-enrollment process, to ensure carrier awareness and to define the key term "provider network." COMAR 14.35.01.02+
AGENT / PRODUCER LICENSING AND APPOINTMENT
Maryland published a bulletin notifying companies and producer license applicants of HB 0265/SB 0336 which removes the education and experience requirements for producers required to pass a licensing examination. Beginning 10/01/24, applicants are no longer required to complete an approved program of study before taking the examination. Bulletin 24-19
ARTIFICIAL INTELLIGENCE
New York published expectations of all insurers using Artificial Intelligence Systems and External Consumer Data and Information Sources in insurance underwriting and pricing. Insurance Circular Letter 2024-7
Virginia's Burau of Insurance issued expectations as to how insurers will govern and manage the risks of Artificial Intelligence Systems. Administrative Letter 2024-01
CAPITAL AND SURPLUS REQUIREMENTS
Maryland issued a bulletin notifying companies of the annual group capital calculation reporting requirement. Bulletin 24-17
CONFIDENTIALITY / PRIVACY
Rhode Island created the Data Transparency and Privacy Protection Act to protect personal data of customers and allow customers to opt out of the collection of personally identifiable information. HB 7787 / SB 2500
CYBERSECURITY
Rhode Island passed a law requiring carriers to establish an information security program. HB 7281 / SB 2802
DISASTER / CATASTROPHIC EVENT
Iowa published a bulletin providing a summary of its expectations when a disaster has been declared. General expectations are outlined including, among other items, a grace period for cancellation, and claim reporting and resolution. Bulletin 24-03
DISCLOSURE REQUIREMENTS
California adopted a bill requiring any solicitation for a consumer financial product or service to include a certain disclosure, on the front of the envelope, in no less than 16 point bold type. SB 1096
ELECTRONIC TRANSACTIONS
Pennsylvania passed a law allowing an insurer to electronically deliver insurance notices or documents to a covered person under a health benefit plan, vision or dental plan. Certain disclosures are required to be given to the covered person. In addition, a health insurer cannot restrict the method of payment to a participating health care provider so that the exclusive payment method is a credit card payment. HB 1664
FILING REQUIREMENTS / PROCEDURES
Alabama has published a bulletin concerning filing requirements for federal disclosures for insurers that issue short-term, limited duration insurance and hospital indemnity and fixed indemnity policies. Bulletin 2024-02
New York's Insurance Department issued Filing Guidance for submitting wellness programs in connection with life insurance. Filing Guidance of July 16, 2024
Texas issued guidance to insurers that issue short-term limited duration policies and hospital indemnity and other fixed indemnity policies regarding filing requirements for new consumer disclosures. Bulletin B-0013-24
Utah's Insurance Commissioner issued a bulletin providing guidance regarding amended federal rules issued on March 28, 2024, revising the requirements for short-term limited duration insurance and fixed indemnity excepted benefits coverage. Bulletin 2024-8
FRAUD / ANTI-FRAUD
Florida adopted regulations updating its Anti-fraud Award Program. Changes are intended to align with statutory penalties. FAC 69D-1.001-004
HEALTH CARE EXCHANGE / MARKETPLACE
New Mexico's Insurance Superintendent informs all health care insurers, HMOs, and cooperatives providing individual and group health insurance in the individual and small group markets to submit their policies for compliance review with the Delivery of Necessary Diabetic Resources law pursuant to HB 53. Bulletin 2024-14
HEALTH INSURANCE - COMPREHENSIVE
Colorado published a bulletin providing guidance to insurers issuing health benefit plans in the individual and small group market. The department clarifies that its position is that companies are required to provide coverage for abortion services. B-4.139
Illinois has enacted a bill that gives additional authority to the insurance director in regulating large group health plans. The insurance department will now have the authority to accept or reject large group health insurance rate filings and apply state provider network adequacy rules to those large groups. HB 5395
New Hampshire amended its Terminal Patients Right to Try Act to by revising eligibility criteria and definitions, replacing the term biological products with biologics, and changing the name to Right to Try Act. HB 1300
New Hampshire passed a law that has the same requirements and prohibitions that exist under the Federal No Surprises Act. SB 173
New Hampshire passed the Lead Poisoning Prevention and Treatment Act of 2024 which requires the cost of blood lead testing to not be subject to a co-payment, deductible or coinsurance. Benefits provided shall include any follow-up blood lead testing that is necessary to complete the preventive screening when the initial blood lead testing indicates an elevated blood lead level or is inconclusive. SB 399
New Mexico's Insurance Superintendent advised all health care insurers and pharmacy benefit managers to submit health insurance policies for compliance review of SB 273, Parity for Coverage of Mental Health and Substance Use Disorder. Bulletin 2024-13
Pennsylvania passed a law requiring health insurers to include biomarker testing as a covered benefit under health insurance for the diagnosis, treatment, and management of a covered person's disease or condition. HB 1754
HOLDING COMPANIES
Delaware published a revised bulletin clarifying the Department's interpretation of the term "admitted assets" for purposes of triggering reporting requirements within a holding company system. The department is clarifying "admitted assets" include only those admitted assets in the insurer's general account. Bulletin No. 6 Rev. 7-9-2024
LONG-TERM CARE INSURANCE
Alabama enacted the Long-Term Care Insurance Policy Minimum Standards Act, which sets standards for long term care policies, administration and disclosures. Ch 482-1-091
MANAGED CARE PLANS / HMOS
Mississippi adopted amendments to its Managed Care Plan Network Adequacy Regulation, designed to ensure adequate access to managed care. Changes include authorizing the commissioner to request information and data from carriers and to maintain confidentiality of data as gathered. 19-3-14.01
MISCELLANEOUS
New Mexico's Superintendent of Insurance announced its Fraud Fee collection has been delayed due to automating the fee payment system. The fee will not be collected until September 1, 2024. Insurers are instructed to check the Department's website on that day for further instructions. Notice dated July 24, 2024
MISCELLANEOUS HEALTH / ACCIDENT
Arkansas issued a bulletin clarifying that the state's Medicaid plan, ARHOME, is supplemental to and not a replacement for payments from other sources. 10-2024
Colorado published an announcement that the state has extended the deadline to enroll for health insurance through Connect for Health Colorado. Individuals who are no longer eligible for Health First Colorado (Colorado Medicaid) due to the end of the Covid 19 Public Health Emergency now have until November 30 to complete enrollment. News Release 7-24-2024
Illinois enacted amendments to its Insurance Code including updates to required billing practices, notifications and utilization review. HB 2472
OMNIBUS LEGISLATION
North Carolina passed an omnibus bill that amends laws pertaining to insurance producers, electronic communications under a health benefit plan, and captive insurance. SB 319
PHARMACY BENEFIT MANAGERS
Oklahoma adopted a rule dealing with Pharmacy Benefit Management procedures, contract requirements, Maximum Allowable Cost lists, network access standards, and appeals, among other items. Rule 75:45-3-1+
REPORTS - DATA CALLS & OTHER REPORTS
New Jersey, in connection with 29 other states and territories, requested eligible insurers to file the Climate Risk Survey Disclosure Survey for 2023. California will collect the information from insurers and coordinate for the participating states. Insurers with direct written premium of more than $100M nationwide in 2023 must respond. Bulletin 24-09
Rhode Island added the Dental Insurance Loss Ratio Reporting and Study Act requiring dental insurers to file an actuarial memorandum disclosing its incurred claims and earned premiums with the Insurance Commissioner. The reporting deadline is March 1, 2025, for reporting years 2023 and 2024. SB 2873 / HB 7944
SUITABILITY
Missouri adopted the updated NAIC Suitability in Annuity Transactions Model. The updated rule requires producers to act in the best interest of the consumer when recommending an annuity. 20 CSR-400-5.900
TRADE PRACTICES
Pennsylvania passed a law allowing the offering of certain gifts valued at $125 or less by an insurer or producer to be in compliance with the trade practices law. SB 1092
Newsletter
Property and Casualty News October 2025
Property and Casualty News
October 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
South Dakota repealed producer licensing rule 20:06:18:09, which previously limited licensees to receiving no more than half of their required continuing education credits from courses sponsored by a single insurance company within any two-year period. 20:06:18:09
ARTIFICIAL INTELLIGENCE
California enacted the Transparency in Frontier Artificial Intelligence Act, establishing mandatory transparency, incident reporting, and whistleblower protections for large frontier AI developers to mitigate catastrophic risks while supporting innovation. The law requires developers to implement risk frameworks, report critical safety incidents, and protect employees who disclose violations, with enforcement authority and civil penalties up to $1 million per violation. SB 53
AUTOMOBILE INSURANCE
California lowered its uninsured and underinsured motorist coverage requirements for transportation network companies (TNCs) from $1 million to $60,000 per person and $300,000 per incident while a passenger is in the vehicle. The bill makes TNCs solely responsible for maintaining this coverage and requires that any resulting insurance cost savings be reinvested to support the economic welfare of drivers and riders. SB 371
Delaware established new regulations for non-consensual towing of motor vehicles weighing 5,000 pounds or less from private and public parking areas. The new provisions set strict pre-towing requirements, cap towing and storage fees, regulate storage facility standards, and provide legal remedies for improper towing. HB 67
Missouri issued a bulletin directing auto insurers to register with the new Missouri Insurance Verification System (MOIVS), as part of the state’s Uninsured Motorist Program. Insurers must begin system testing by January 15, 2026, with transition to full production by March 16, 2026. Bulletin 25-09
CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE
California issued a bulletin enforcing a mandatory one-year moratorium on cancellations and non-renewals of residential property insurance policies in areas affected by the TCU September Complex Fire. Insurers are prohibited from dropping coverage due to wildfire risk for properties in specified ZIP Codes and must reinstate or renew any policies canceled since the declaration. The moratorium applies to homeowners’, condo, mobile home, and renters’ policies. Bulletin 2025-13
CLAIMS / CLAIMS ISSUES
Michigan released a bulletin warning auto insurers against improper claims practices, including delayed investigations, underpayments, and pressuring claimants into title transfers without fair settlements. The Department of Insurance and Financial Services (DIFS) reminds insurers they must comply with prompt, fair claims handling or face regulatory penalties. Bulletin 2025-19-INS
Wisconsin reminds property and casualty insurers to process storm-related claims promptly following the August 2025 floods in Southeast Wisconsin. Insurers must affirm or deny claims within 30 days, enabling consumers to meet FEMA’s November 12 disaster aid deadline. Bulletin Dated 10/7/25
COMMERCIAL LINES INSURANCE
California strengthened its oil spill prevention by requiring facilities that could impact state waters to obtain a certificate of financial responsibility. The adopted bill mandates public disclosure of certificate applications and directs the Office of Spill Prevention and Response to conduct a public review process every 10 years, starting in 2027, to update financial assurance requirements for oil spill response. SB 237
Michigan published an updated list of municipalities participating in the Fire Insurance Withholding Program. The list identifies each municipality's participation type and replaces previous versions. Insurers must be notified at least 30 days in advance of any new municipal participation. Notice Dated 10/1/25
CREDIT INSURANCE
Illinois now requires credit insurance refunds under the Consumer Installment Loan Act to be calculated strictly per the Department of Insurance’s rule 50 Ill. Adm. Code 1053.10, replacing the previous broader refund method standard. 38 Ill. Adm. Code 110.170
South Carolina set 2026 credit property insurance rates. The rates are based on loan amounts, with notable premiums like 0.45% for Automobile Fire and Theft and 5.81% for Household Goods – Single Interest. Insurers must submit required reports and notify the Department by December 1, 2025, if using these rates or lower. Order 2025-005
CYBERSECURITY
California amended its Civil Code to require businesses to disclose data breaches within 30 calendar days of discovery, with limited allowances for law enforcement delays or system restoration efforts. The amendment also updates reporting requirements, mandating that businesses notify the Attorney General within 15 days if a breach affects more than 500 California residents. SB 446
California issued a notice reinforcing mandatory reporting requirements for data breaches involving personal information of California residents, applying to all entities engaged in the insurance business. The notice emphasizes compliance with the Insurance Information and Privacy Protection Act requiring timely notification of breaches, including those involving affiliates or vendors, and submission of breach notices to both the Attorney General and the DOI. Notice Dated 9/30/25
New York DFS warns regulated entities about active cyberattacks exploiting zero-day vulnerabilities in Cisco ASA and Firepower devices, urging immediate remediation per CISA guidance. Entities must identify affected devices, apply updates promptly, disconnect unsupported hardware by set deadlines, and report incidents to DFS if compromised. Industry Letter Dated 9/26/25
DISCRIMINATION
Texas issued a bulletin implementing SB 1238, which prohibits insurers from discriminating against widowed individuals in coverage, options, or rates compared to married individuals. This applies to all policies delivered, issued, or renewed on or after September 1, 2025. Bulletin B-0014-25
FILING REQUIREMENTS / PROCEDURES
Michigan reminds reciprocal insurance exchanges of their continuous filing obligations under MCL 500.7210. Companies with outdated filings must submit updated information via SERFF by October 31, 2025, including required contracts and agreements. Bulletin 2025-21-INS
MISCELLANEOUS PROPERTY / CASUALTY
Kansas' Attorney General clarified that the Public Adjusters Licensing Act applies only to commercial lines insurance contracts and does not regulate or prohibit public adjusting for residential insurance claims. While unlicensed individuals may assist with residential claims, they must still comply with consumer protection laws and avoid unauthorized legal practice. The Act’s scope remains limited to licensing public adjusters for commercial insurance claims. Attorney General Opinion 2025-22
Washington urges property and casualty insurers to provide a minimum 30-day grace period for federal employees affected by the ongoing government shutdown. Insurers are encouraged to waive late fees, avoid cancellations, and clearly communicate flexible payment options. The bulletin emphasizes protecting coverage for the approximately 80,000 impacted federal workers in the state. Notice Dated 10/6/25
PHARMACY BENEFIT MANAGERS
Iowa issued a bulletin to guide implementation of SF 383 that regulates Pharmacy Benefit Managers (PBMs) in prescription drug practices. The law mandates NADAC-based reimbursements, pass-through pricing, rebate transparency, and prohibits discriminatory or deceptive practices. PBMs must also comply with new appeal processes and cost-sharing rules. Bulletin 25-06
Massachusetts now requires all Pharmacy Benefit Managers (PBMs) to be licensed by the Division of Insurance starting January 1, 2026. The initial one-year license costs $8,334, and future three-year licenses will cost $25,000. Bulletin 2025-04
North Carolina adopted new PBM regulations establishing licensing, fees, financial responsibility, claims processing, and operational standards to strengthen oversight and compliance. Key rules include application requirements, financial reporting, solvency criteria, claims handling protocols, and administrative governance for PBMs. 11 NCAC 24 .0101
PROPERTY INSURANCE
California reminds property and casualty insurers of their obligations under the "efficient proximate cause" doctrine, which requires coverage for damages like mudslides or flooding if caused by a wildfire, a covered peril. Insurers must not deny such claims without a thorough investigation and must comply with established legal standards when handling post-wildfire damage claims. Notice Dated 9/19/25
REPORTS - DATA CALLS & OTHER REPORTS
North Carolina’s Property and Casualty Division requires insurers offering nonfleet private passenger motor vehicle physical damage and certain homeowners insurance policies under Consent to Rate provisions to submit semi-annual reports by November 20, 2025. Bulletin 25-B-13
SURPLUS LINES
Connecticut published an updated list identifying all licensed insurance companies, approved/accredited reinsurers, and surplus lines insurers operating in the state. The list includes each company's name, type, domicile and state, NAIC code, and NAIC group number. Interested parties are advised to use the State Based System Lookup Tool for more detailed information. Notice Dated 9/30/25
Georgia launched a new Compliance Review Program for surplus lines brokers to verify adherence to filing and tax remittance requirements. The program includes routine, random, or issue-triggered reviews, and emphasizes education, error reduction, and market integrity. Brokers will receive advance notice, must provide key records, and are expected to respond to findings within 14 days. Bulletin 25-EX-3
THIRD PARTY ADMINISTRATORS
Nevada requires third-party administrators (TPAs) to have written agreements with insurers that comply with specific statutory provisions, prohibiting subcontracting of workers’ compensation administration to a second TPA. TPAs must also provide insured parties with insurer-approved written notice detailing the relationships between the insurer, TPA, and insured. Bulletin 25-001
WORKERS' COMPENSATION
Arkansas released updated workers’ compensation rates for 2026, setting the maximum weekly benefit at $953.00 for Total Disability and $715.00 for Permanent Partial Disability, based on 85% of the state’s Average Weekly Wage. Notice 2000-1 Updated 10/1/25
California’s Division of Workers' Compensation updated the Official Medical Fee Schedule for physician and non-physician practitioner services. The update incorporates the CMS Medicare National Physician Fee Schedule Relative Value File (RVU25D) and revised procedure edits. DWC Release 2025-91
Colorado amended the Medical Fee Schedule to align reimbursement rates and procedures with Medicare and Medicaid standards, updating billing codes and documentation requirements. The amendments also update related exhibits and introduce new standards for prior authorization, provider procedures, and administrative processes. 7 CCR 1191-3
Connecticut’s Workers' Compensation Commission announced that specific forms and documents may now be submitted electronically through the enhanced GovQA System. While electronic submission is optional, this update aims to streamline processes for insurers, claimants, attorneys, and other stakeholders. The new system allows secure online submission of various claim-related and administrative forms, though parties must still provide physical copies to other involved parties where required. Memorandum 2025-09
Connecticut's Workers' Compensation Commission published an updated Authorization for Release of Medical Records form that complies with HIPAA and the state’s Reproductive Rights Shield Law. While use of the revised form is optional, the WCC encourages stakeholders to review and utilize it as needed in workers’ compensation cases. The form is available on the WCC website. Memorandum 2025-07
Idaho’s Industrial Commission released the 2026 workers’ compensation survivor death benefits, based on the state’s Average Weekly Wage of $1,135.00. The update includes historical data since 2017 and clarifies that certain family members—such as parents, siblings, grandparents, and grandchildren—may qualify for benefits if they were financially dependent on the deceased worker. WC Survivor Death Benefits 2026
Indiana approved the 2026 Advisory Rate Filing, which reduces advisory loss costs by 6.1% and both advisory and assigned risk rates by 5.8%, effective January 1, 2026. These changes reflect continued declines in lost time claim frequency and average claim costs across the state. Rate impacts vary by classification within five industry groups. Circular 2025-08
Kentucky set the 2026 discount rate for lump-sum workers’ compensation settlements at 3.75% for weekly payments over $40 and 4.25% for payments of $40 or less. These rates are based on the 10-year U.S. Treasury Note rate as of August 1, 2025. The updated rates apply to all lump-sum settlements finalized in 2026. Order Dated 9/29/25
Massachusetts updated its Indemnity Data Call requirements, adding six new data fields that workers’ compensation insurers must report starting with Q4 2025 data, due by the end of Q1 2026. Circular Letter 2448
Nevada has adopted the Official Disability Guidelines (ODG) Drug Formulary for its workers' compensation system, with full implementation by July 1, 2027. The formulary applies to non-emergency outpatient services and allows appeals for denied non-formulary drugs, aiming to improve efficiency, outcomes, and timely care for injured workers. Notice Dated 9/17/25
Virginia's Workers' Compensation Commission will begin enforcing civil penalties starting January 1, 2026, for insurers that fail to submit Form 26A by the January 31 deadline, as required by Va. Code § 65.2-902(a). Late filings will incur a minimum $500 fine. WC News Dated 10/2/25 (2)
Newsletter
Life and Health News September 2024
Life and Health News
September 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 LICENSING AND APPOINTMENT
California published notice of a new two-hour variable life/annuity course. Effective 01/01/25, the state will require life producers to complete the two-hour course before each license renewal. Licensing Notice Dated 07/31/24
ARTIFICIAL INTELLIGENCE
Arkansas published a bulletin intended to notify insurers doing business in the state of its expectation that companies comply with all laws and regulations when utilizing artificial intelligence. This includes laws dealing with unfair trade practices and unfair discrimination. Bulletin 13-2024
Michigan issued a bulletin to all insurers doing business in the state explaining its expectations that companies comply with applicable laws and regulations when utilizing artificial intelligence. Bulletin 2024-20-INS
West Virginia's Insurance Commissioner reminds insurers that use Artificial Intelligence (AI) Systems to comply with pertinent laws and develop a specific written program for the responsible use of an AI program. Bulletin 2024-06
CLAIMS / CLAIMS ISSUES
Washington's Division of Child Support (DCS) amended its rule requiring insurers to report claim information to the DCS and withhold payments if directed to do so. This rule change complies with SB 5842. Rule WSR 24-16-134
CREDIT INSURANCE
South Carolina's Department of Insurance published notice of tentative Credit Accident and Health Insurance rates to be used in 2025. Carriers who feel aggrieved may request a public hearing with respect to these rates. Bulletin 2024-09
DISASTER / CATASTROPHIC EVENT
North Carolina's Insurance Commissioner reminds health benefit plans that during a state of emergency declared as a result of Tropical Storm Debby, insureds are authorized to obtain extra prescriptions. Bulletin 24-B-08
DISCLOSURE REQUIREMENTS
California approved a bill that will require a health care service plan or health insurer to provide written or electronic notice of the benefit of behavioral health and wellness screening for children and adolescents ages 8-18. The notice is required beginning 01/01/25. AB 2556
EXCEPTED BENEFITS
Montana's Insurance Commissioner provided guidance regarding the disclosures and filing requirements for Hospital Indemnity and other independent and non-coordinated fixed-indemnity policies. Advisory Memorandum dated August 2, 2024
Virginia issued guidance to remind carriers of anticipated loss ratio standards for Excepted Benefits policies. Carriers are expected to immediately evaluate their open and closed blocks of business to determine whether corrective action must be taken. The Bureau will be sending a questionnaire to certain insurers that have written excepted benefits policies in Virginia. Guidance Document dated August 19, 2024
FILING REQUIREMENTS / PROCEDURES
Colorado published an amended bulletin reminding carriers of the requirements of SB 23189 regarding coverage for abortion services in the individual and small group market. Carriers are reminded to update all affected forms and actuarial memoranda. Bulletin B.4.139
Florida adopted a regulation requiring an attestation of compliance with Section 655.0323(1) and (2) FS. The regulation includes a form for completion of the attestation, available on the office's website and is due by July 1 each year. FAC Rule 69U-100.323
GUARANTY ASSOCIATION
New Jersey's Acting Commissioner notified all insurers of increased limits on coverage amounts provided by the New Jersey Life and Health Insurance Guaranty Association and a revised disclaimer notice to be given to policyholders. Bulletin 24-13
HEALTH INSURANCE - COMPREHENSIVE
Illinois approved a bill requiring that a group or individual accident and health plan, or managed care plan, after 01/01/26, must provide coverage for a medically necessary colonoscopy. HB 2385
Oklahoma's Insurance Commissioner informs health benefit plans of the new requirement to enable the public to report inaccurate information in a provider directory. The plan must verify or update the information within two days of receipt of a public report. Beginning March 1, 2025, and each March 1 thereafter, an insurer of a health benefit plan must file an annual provider directory audit report with the Insurance Department. Bulletin 2024-07
Oregon updated a rule to specify 13 well-woman preventive services to be covered during a comprehensive well-woman visit without cost sharing. The preventive services are identified by the U.S. Health Resources and Services Administration as of December 2022. OAR 836-053-0435
LIFE INSURANCE / LIFE CONTRACTS
Arkansas published a bulletin clarifying its position on repatriation of remains coverage. It has determined that a life insurance carrier has sufficient authority to issue this coverage in a standalone life insurance policy or as an endorsement to a life insurance policy. A separate certificate of authority for travel insurance is not required. Bulletin 11-2024
Idaho published a bulletin announcing the rate of interest payable on cash surrender benefits, effective 07/01/24. The minimum rate of interest on deferred payment is now 10.125%. Bulletin 24-04
MARKET CONDUCT EXAMINATIONS
Illinois enacted SB 1479, making numerous changes to its market conduct examination laws, including the manner in which a market conduct examination may be initiated and conducted. Other conditions include the penalties for failure to respond and provisions for corrective action. SB 1479
MISCELLANEOUS
Illinois amended the Automatic Contract Renewal Act. Any contract that includes a free trial or promotional period that lasts 15 days or longer, and includes an automatic renewal, must provide notification to the consumer at least three days before the cancellation deadline and send notice in a manner with which the consumer is familiar. SB 2764
Ohio passed a law that revised coverage for dental and vision insurance regarding provider contracts, appeal process and terminations. This law also addresses misrepresentation about policy terms and benefits and requires more detailed information to be provided on out-of- pocket expenses and business interests in suppliers of vision and dental care materials. SB 40
Virginia issued guidance to carriers writing Short-Term Limited-Duration Insurance. Forms must be filed and approved by Bureau of Insurance and contain notices and disclosures that comply with Virginia law and Federal rules. Guidance Document dated August 2024
OMNIBUS LEGISLATION
Ohio passed a law allowing pet insurance to be sold and delivered in the state. It covers pre-existing exclusions and licensing of agents, among other items. This is part of an omnibus bill. SB 175
Ohio passed an omnibus law requiring a statutory agent appointment to include the address of the agent's ordinary residence or usual place of business in Ohio. This bill also addresses fraudulent business filings, deceptive mailings and other items. SB 98
PHARMACY BENEFIT MANAGERS
New Hampshire passed a bill revising the reporting requirements for Pharmacy Benefit Managers and insurance companies. SB 555-FN
West Virginia addresses the applicability of the West Virginia Pharmacy Audit and Integrity Act to prescription drug discount plans and pharmacy coupon cards. Bulletin 2024-5
SUITABILITY
Louisiana published a bulletin announcing that it has adopted the "best interest" standard for annuity recommendations. Notice Dated 7-30-2024
Missouri adopted the most recent NAIC Suitability in Annuity Transactions Model, requiring a best interest standard in an annuity recommendation. 20 CSR 400-5.900
TRAVEL INSURANCE
Colorado published a bulletin providing guidance on travel insurance filing requirements, updated as a result of the passage of HB 24-1060. The bulletin provides, among other things, guidance on submitting filings that combine property casualty and accident and health coverages and provides a link for additional resources. Bulletin B-5.49
- Category
- All
- Article
- Download
- Year
- 2026
- Archive
- All Dates