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