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