Property and Casualty News
February 2026
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
Illinois warns that public adjusters may not use third-party lead generators unless those parties and their employees are licensed as Illinois public adjusters. Using unlicensed third parties can void contracts, prevent payment collection, and expose adjusters to license suspension, revocation, or criminal liability. Public adjusters are required to verify licenses and maintain records of all third parties involved in contract solicitation. Bulletin 2026-02
AGENT / PRODUCER LICENSING AND APPOINTMENT
Illinois updated its pre-licensing and continuing education rules for insurance producers, limited insurance representatives, and business entities to align with the NAIC Continuing Education Reciprocity (CER) Agreement. The changes clarify definitions, establish submission and review procedures for CER-based and Illinois-specific courses, update provider and applicant responsibilities, and revise pre-licensing and continuing education course requirements. 50 Ill. Adm. Code 3119.20+
AGENT / PRODUCER TERMINATION
Maryland published a bulletin outlining procedures for insurers to notify the Administration when a producer’s appointment is terminated “for cause.” Notifications and supporting documentation may be submitted either via the Administration’s online form or by email. Bulletin 26-3
AUTOMOBILE INSURANCE
Hawaii now prohibits motor vehicle insurers from using ZIP code–based rating factors, citing unfair discrimination and lack of actuarial support, and requires insurers to refile rates eliminating such factors by June 30, 2026. County-based factors remain permissible if actuarially justified, with changes effective for new and renewal policies beginning October 1, 2026. Memorandum 2026-2PC
CAPTIVES
Utah amended its rules for captive insurance companies, moving the Statement of Actuarial Opinion filing deadline to June 30 to align with the annual audit and clarifying that the Statement of Economic Benefit to the State must be included in the annual report. Both the audit and actuarial opinion are now formally part of the annual financial condition report. R590-238-4
Vermont issued guidance for captive insurers on credit for reinsurance, clarifying statutory and regulatory requirements for recognizing reinsurance recoverables and managing risk with qualified reinsurers. Captives must ensure reinsurance agreements are secure, supported by adequate collateral, and approved by the Department for structural changes or affiliated reinsurers, while annual reporting and documentation requirements remain mandatory. The bulletin also discontinues the Captive Division’s authorized reinsurer list, directing insurers to publicly available resources to verify reinsurer eligibility. Notice Dated 1/28/26
COMPLAINTS
Delaware published a revised bulletin requiring admitted and approved insurers to provide and maintain direct telephone numbers and email addresses for all regulatory contacts to improve communication during consumer complaint investigations. The bulletin expands the requirement to all UCAA Form 14 contacts and mandates timely updates through SBS or the DOI. Domestic-Foreign Insurers Bulletin 98 (Revised)
DISASTER PREPAREDNESS
Maryland released a bulletin requiring insurers and other authorized entities to review and update disaster and catastrophe contact information by April 15, 2026, via the designated online portal. Entities must ensure primary or backup contacts are available for emergencies and provide details on disaster response, continuity, and severe event plans. Bulletin 26-1
Missouri updated its catastrophe and disaster coordination contact requirements for property insurers, ensuring timely communication with the Department during disaster events. Insurers must update contacts via UCAA Form 14 only if changes occur, with no filing fee required. Bulletin 26-02
GUARANTY ASSOCIATION
Michigan updated the insured net worth limit and covered claim cap under the Michigan Property and Casualty Guaranty Association Act for 2026. The net worth limit is set at $39,920,000 and the covered claim cap at $7,980,000, based on CPI adjustments, and must be applied by insurers when evaluating claims. Bulletin 2026-04-INS
HOLDING COMPANIES
Arkansas updated its insurance holding company regulations to revise prior-notice transaction rules, strengthen requirements governing insurer records, affiliate agreements, and receivership cooperation. The amendments also adopt a new group capital calculation rule that allows exemptions or limited filings under specified conditions while preserving regulatory discretion. 23 CAR s 9-118
MISCELLANEOUS
Illinois updated its administrative code to allow insurance companies to issue checks signed with the company name instead of a corporate officer’s or employee’s name, enhancing internal security measures and helping protect personnel from potential threats. 50 Ill. Adm. Code 904.30
Maryland clarified that the USPS Intelligent Mail Barcode qualifies as a valid “first-class tracking method” under the Insurance Article, providing evidence of mail acceptance and compliant supporting certified, first-class, standard, and periodical mail. Bulletin 26-2
Michigan published an updated list of municipalities participating in the Fire Insurance Withholding Program, effective March 1, 2026, specifying the program section under which each municipality participates. The program allows municipalities to escrow 25% of fire insurance settlements for covered property losses, with eligibility and covered perils varying by population and county size, and maximum escrow amounts adjusted annually by CPI. Notice Dated 2/1/26
Montana issued an advisory memorandum on the Montana Pet Insurance Act, effective October 1, 2025, providing guidance on marketing practices and the mandatory 15-day free look period. The memorandum clarifies that non-marketing communications about wellness programs are permitted and confirms that insurers may offer longer free look periods without violating the Act. Advisory Memorandum Dated 1/14/26
REGULATORY REPORTING REQUIREMENTS
Illinois updated its filing instructions for annual insurance supplier diversity reports. The released bulletin applies to insurers and accredited reinsurers meeting the $50 million asset threshold. It outlines requirements for submission, reporting, formatting, and deadlines. Bulletin 2026-03
Missouri reminds insurers of their annual statistical reporting obligations across all lines, including property, casualty, life, health, and accident insurance. The bulletin outlines filing deadlines, submission methods, and statutory references, emphasizing timely compliance. Bulletin 26-03
North Carolina announced that the Rate Bureau will implement standardized templates for personal lines statistical reporting in 2026, starting with Private Passenger Auto and Homeowners policies, with Dwelling policies to follow. Member companies must submit data through their Statistical Organizations, with initial deadlines beginning August 1, 2026. Circular Letter Circular Letter P-26-1
REPORTS - DATA CALLS & OTHER REPORTS
Alabama announced the release of its most recent Liability Insurance Coverage Data Call report, which analyzes how liability insurance coverage affects insurance claims costs. Liability Insurance Data Call 1/15/2026
Minnesota launched a data call requiring property and casualty insurers to submit firearms-related policy and claims data for homeowners’ insurance by April 6, 2026. The data, submitted via SFTP at the company level, will support a report to the Governor on reducing gun violence. Memorandum Dated 2/1/26
SURPLUS LINES
Alaska issued a bulletin updating its surplus lines insurer “white list,” clarifying eligibility standards under the NRRA and Alaska law. The bulletin explains insurer removal criteria, annual certification requirements for foreign insurers, the distinction between “White Listed” and “Listing Approved” statuses, and notes that alien insurers on the NAIC Quarterly Listing remain eligible but are no longer included on the white list. Bulletin B 26-01
New Jersey issued a memorandum outlining 2026 renewal requirements for domestic surplus lines insurers, including submission of company details and prior-year premiums. Insurers must file reports through the Surplus Lines Information Portal by April 1, with a $100 fee required only if no New Jersey premiums were written. Notice Dated 1/14/26
New Jersey published updated lists of eligible foreign, domestic, and alien surplus lines insurers, noting additions, deletions, name changes, and redomiciled companies. Notice Dated 2/6/26
Oregon released a bulletin guiding surplus lines and retail producers on placing commercial property and liability insurance for affordable housing entities under Senate Bill 829. The law allows coverage from surplus lines carriers without a diligent search of admitted markets for properties meeting the state’s affordable housing criteria. Bulletin 2026-1
Wyoming rescinded all prior exemptions previously granted for non-competitive insurance markets. The Department determined the state now has a competitive market, so all insurers, producers, and surplus lines brokers must fully comply with the Wyoming Insurance Code and regulations. Bulletin 01-2026
TRADE PRACTICES
Alabama released a revised bulletin prohibiting insurers from canceling, non-renewing, surcharging, or rerating personal or commercial property and automobile policies based solely on catastrophe or weather-related claims. Insurers must amend noncompliant rating rules while allowing cancellations for fraud or misrepresentation and permitting removal of claims-free discounts in limited circumstances. Bulletin 2025-08 (Revised)
WORKERS' COMPENSATION
California announced the publication of 2025 Utilization Review investigation results for claims administrators, conducted as part of the Division of Workers’ Compensation’s five-year profile audit reviews. The posted results reflect UR performance ratings based on compliance with regulatory standards for timeliness, notice accuracy, and proper notification. DWC Release 2026-06
California issued a reminder from the Division of Workers’ Compensation requiring claims administrators to submit the 2025 Annual Report of Inventory (ARI) by April 1, 2026, detailing claims activity at each adjusting location, even if no claims were reported. Administrators must also report any changes to submitted information within 45 days, with late or missing filings resulting in penalties. DWC Release 2026-05
California released a Labor Commissioner bulletin implementing the Workplace Know Your Rights Act which requires employers to provide annual written notices outlining workers’ labor, immigration, safety, and organizing rights, and to allow designation of an emergency contact. The bulletin also highlights related 2026 employment law changes, including a higher statewide minimum wage, expanded Equal Pay Act protections, and updates to paid sick leave rules. DWC Release 2026-14
California released a progress report on the Independent Bill Review (IBR) program summarizing billing dispute outcomes for medical and medical-legal services in workers’ compensation claims during 2023–2024. The report shows steady IBR usage, with providers prevailing in 60 percent of decided cases and more than $7.7 million awarded. DWC Release 2026-13
District of Columbia updated its workers’ compensation rates, setting the maximum weekly rate at $1,852.07 and the minimum at $463.02, with a 2.4 percent increase in supplemental allowances for permanently totally disabled claimants and eligible surviving spouses or domestic partners. Employers and insurers must file amended Form 9s and comply with all updated compensation requirements. WC Notice of Weekly Compensation Rates 01/13/26
Massachusetts issued a notice allowing employers and producers applying to the Workers’ Compensation Assigned Risk Pool to opt in to receive electronic correspondence. While most communications can be sent electronically, Notices of Cancellation and Nonrenewal must still be mailed, with proof of mailing retained by carriers. WCRIBMA Notice to Pool Carriers 26-1