Property and Casualty News
August 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
Oregon adopted new rules to regulate the licensing, qualifications, and ethical conduct of public adjusters, excluding those handling auto insurance claims. The rules detail licensing procedures, continuing education, contract and fee requirements, standards of conduct, and mandatory recordkeeping. OAR 836-071-1100 +
ADVERTISING / SALES & MARKETING
Oregon enacted legislation effective January 1, 2026, expanding the definition of telephone solicitations and auto-dialers to include text messages, and restricting solicitations to between 8 a.m. and 8 p.m., no more than three times in 24 hours. The law also clarifies exemptions for established business relationships and certain entities. HB 3865
AGENT / PRODUCER LICENSING AND APPOINTMENT
Delaware requires all non-resident licensees to renew their licenses by February 28, 2027, with renewals accepted starting December 1, 2026, and fees paid online via NIPR. Renewal fees vary by license type, and continuing education is mandatory for certain adjusters, with reduced requirements for long-term licensees or those holding professional designations. Notice of Non-Resident License Renewal 2027
AUTOMOBILE INSURANCE
Colorado amended its rules governing disclosure requirements for private passenger automobile insurance policies. The changes allow insurers flexibility in formatting the required summary document and adding new disclosures to Appendix C. 3 CCR 702 Reg. 5-2-16
Massachusetts requires motor vehicle insurers to file annual information returns reporting payments to repair shops, starting with payments made on or after January 1, 2025, with returns due to the Commissioner of Revenue by March 31 annually. Insurers must also provide copies to the repair shops by January 31. This requirement is effective August 1, 2025. 830 CMR 62C.8.2
New Jersey is implementing phased increases to auto insurance minimum coverage limits under P.L.2022, c.87, with higher limits effective January 1, 2026. The Department of Banking and Insurance requires insurers to update rates, policy forms, and notify policyholders of new minimums by specified deadlines, exempting them from obtaining signed coverage selection forms for these increases. These changes apply to admitted and surplus lines insurers, self-insureds, and risk retention groups but exclude the basic auto policy under N.J.S.A. 39:6A3.1. Bulletin 25-06
North Carolina announced updates to the Personal Auto Manual, effective October 1, 2025, including revised inexperienced operator surcharge factors, new classification codes, and editorial changes to Rule 5 of the Safe Driver Insurance Plan. Circular Letter A-24-5
CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE
Louisiana issued a notice requiring property and casualty insurers issuing homeowners or private passenger auto policies to disclose the prior policy premium on renewal notices, with full compliance due by January 1, 2026. Advisory Letter 2025-03
Texas passed legislation effective January 1, 2026, clarifying that insurers are to provide written reasons for the declination, cancellation, or non-renewal of insurance policies. Insurers will be required to submit quarterly reports to the Department of Insurance summarizing such actions by ZIP code (except for workers’ comp which is reported statewide and not by zip codes). HB 2067
CAPTIVES
Connecticut announced expanded flexibility for captive insurers with the signing of Public Act No. 25-130. The legislation allows various captive types to convert into protected cells and enables sponsored captives to transfer cells and their assets, subject to DOI approval. Notice Dated 7/25/25
CLAIMS / CLAIMS ISSUES
North Carolina issued a bulletin directing insurers to adopt safeguards when using aerial imagery in underwriting and claims handling. The Department raised concerns about inaccurate or outdated images leading to improper non-renewals, and now requires insurers to use recent, reliable imagery, disclose reasons and evidence to policyholders, and allow disputes before action is taken. Bulletin 25-B-09
COMMERCIAL LINES INSURANCE
Michigan published the updated list of municipalities participating in the Fire Insurance Withholding Program, effective September 1, 2025. The program allows certain municipalities to escrow 25% of fire insurance settlements for covered property losses, with participation and coverage varying based on population thresholds. Insurers must receive at least 30 days’ notice before new municipalities apply the program. Notice Dated 8/1/25
CREDIT INSURANCE
Arizona issued an order establishing updated prima facie rates for credit property insurance effective February 1, 2026, while maintaining the 51.5% loss ratio standard set in 2013. Insurers may file for higher deviated rates using the Credibility Table in Exhibit B, following A.R.S. § 20-1621.05. The Order also requires annual experience reports from insurers by April 1. Order Dated 7/31/25
CYBERSECURITY
North Dakota updated its insurance data security and cybersecurity event reporting requirements under NDCC Chapter 26.1-02.2. All DOI licensees must maintain a written Information Security Program and report cybersecurity events impacting 250 or more consumers within three business days. HIPAA-covered entities may be exempt from some provisions but must still notify the DOI. Bulletin 2025-1
DISASTER / CATASTROPHIC EVENT
California is now enforcing a mandatory one-year moratorium on cancellations and non-renewals of residential property insurance policies following the June 18, 2025, state of emergency declaration for the Franklin Fire in Malibu. The bulletin applies to all insurers covering properties in specified ZIP Codes and requires reinstatement or renewal offers for policies canceled due to wildfire risk since the declaration date. Bulletin 2025-12
FILING REQUIREMENTS / PROCEDURES
Alabama consolidated several prior bulletins concerning the mandatory use of SERFF and providing filing fees. Bulletin 2025-04
Virginia’s Bureau of Insurance updated its June 2025 Property and Casualty Filing and Product Guidelines to clarify Excess Workers’ Compensation filings, mandate offers of water backup and diminution of value coverage and provide new guidance on Workers’ Compensation credits and rating plans. SCC Notice Dated 7/9/25
GUARANTY ASSOCIATION
New Jersey has authorized insurers to impose a surcharge of up to 0.3% of net direct written premiums on applicable policies issued or renewed on or after October 1, 2025, to recoup the PLIGA assessment due September 15, 2025. This applies to most lines of insurance except life, health, workers' comp, title, and other excluded lines. Insurers must stop surcharges once the assessment is fully recouped and properly account for any excess funds. Order A25-02
MISCELLANEOUS
Louisiana adopted new regulations establishing an Insurance Regulatory Sandbox Program to allow insurers to test innovative products and services with temporary waivers from certain laws. The regulation sets application, reporting, and disclosure requirements, limits participation, and includes provisions for waiver denial, revocation, and confidentiality. LAC 37 XIII.20501
PERSONAL LINES INSURANCE
New York enacted the Third Amendment to Insurance Regulation 159 to standardize hurricane deductibles for homeowners' and dwelling fire policies. The regulation clarifies when deductibles apply, mandates prominent disclosures in policy documents, and limits deductibles to wind losses occurring around a hurricane’s landfall in New York. It also sets new definitions, notice requirements, and minimum standards for applying hurricane deductibles based on proximity to the coastline or by county. 11 NYCRR 74.0
PREMIUM ISSUES
Delaware issued guidance clarifying that property and casualty insurers must include operating expenses in filed rates and policy premiums, prohibiting separate fees such as policy, inspection, or administrative charges. The bulletin permits only certain fees—like installment or late payment fees—if they are actuarially justified and meet specific conditions. Forms and Rates Bulletin 41
REGULATORY REPORTING REQUIREMENTS
New Hampshire mandates insurance companies to notify the Insurance Department before discontinuing certain lines of business. Fire and casualty insurers must provide 120 days’ notice to the department and agents before ceasing a line. SB 121
REPORTS - DATA CALLS & OTHER REPORTS
Florida issued a memorandum requiring authorized personal and commercial residential property insurers to annually submit detailed claims data by March 1, 2026, under Rule 69O-171.011, F.A.C. Insurers must provide comprehensive information on closed claims to help monitor litigation and claims trends and ensure consumer protection. Informational Memorandum OIR-B1-2222
SURPLUS LINES
Alaska updated its list of eligible surplus lines insurers, introducing revised classifications and clarifying eligibility under the NRRA. The bulletin distinguishes between “White Listed” foreign insurers and “Listing Approved” alien insurers, while removing alien insurers from the traditional white list. Bulletin B 25-06
Illinois amended its Insurance Code to revise the definition of "home state" for surplus line insurance under 215 ILCS 5/445. For groups of non-affiliated insureds on a single contract, "home state" is now determined by the principal place of business or residence of an insured, or, if all insured risk lies outside that state, by the state receiving the largest share of taxable premium for the contract. SB 1289
Puerto Rico issued a Circular Letter notifying surplus lines insurance brokers of the official name change of Discover Specialty Insurance Company to Travelers Specialty Insurance Company. Circular Letter CC-2025-2046-AF
WORKERS' COMPENSATION
Arizona announced the launch of a revised Notice of Claims Status (Form 104). The updated form includes new claimant identification fields, expanded work status options, and stricter submission requirements, with mandatory use beginning October 21, 2025. The ICA encourages electronic submissions and requires prior approval for any form modifications. Notice Dated 7/28/25
Connecticut announced the publication of the 2025 Official Practitioner Fee Schedule for all medical services rendered on or after that date under the Workers' Compensation Act. The updated schedule includes rule clarifications and incorporates the 2025 CPT codes. Memorandum 2025-03
Delaware launched WorkComp360, a new cloud-native analytics platform from the Delaware Compensation Rating Bureau (DCRB). Designed for executives, underwriters, actuaries, and regulators, the platform replaces static reports with dynamic tools like injury visualizations and customizable benchmarking. Members can access WorkComp360 via www.dcrb.com. DCRB Circular 1059
Illinois issued clarification that all workers’ compensation rate filings, including “consent to rate” policies for high-risk or unusual businesses, must be filed for approval at least 30 days before use, per Article XXIX and Public Act 100-11181. The bulletin emphasizes that rates cannot be excessive or unfairly discriminatory, and premium increases over 5% require advance notice. Company Bulletin 2025-15
Indiana’s Compensation Rating Bureau adopted updates to the NCCI Basic Manual for Workers Compensation and Employers Liability Insurance to revise classifications for hazardous material remediation services involving asbestos, mold, and lead paint, and to clarify classification of construction employees performing janitorial-type work under Code 5059. Circular 2025-07
Minnesota’s Workers' Compensation Insurers Association (MWCIA) announced updates to the NCCI Medical and Indemnity Data Call reporting requirements for workers' compensation insurers. Changes to the Medical Data Call began with Q4 2024 data (due Q1 2025), while new elements for the Indemnity Data Call apply starting with Q4 2025 data (due Q1 2026). WC Circular Letter 25-1861
Nevada’s Division of Industrial Relations, Workers’ Compensation Section, requires all workers’ compensation insurers, including private carriers and self-insured employers, to submit the Fiscal Year 2025 Claims Activity Report or a Statement of Inactivity via the CARDS portal by September 1, 2025. The report must consolidate data from all TPAs, cover the period July 1, 2024, to June 30, 2025. Notice Dated 7/15/25