Property and Casualty News
September 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!
ADVERTISING / SALES & MARKETING
New Mexico updated Bulletin 2025-006 to revise insurer notification requirements for offering value-added products or services, including adding inception and termination dates, clarifying that charges are not built into rates if free, and removing the need to specify separate charges when fees apply. Bulletin 2025-006 (Updated)
United States Federal Communications Commission (FCC) amended its regulations to comply with a court mandate that reinstates the prior version of 47 CFR 64.1200(f)(9), governing prior express written consent for telemarketing calls. This change requires telemarketers to obtain a signed, written agreement—electronic signatures included—that clearly authorizes automated or prerecorded telemarketing calls and discloses that signing is not a condition of purchase. 47 CFR 64.1200
United States Federal Trade Commission (FTC) issued a correction to the Telemarketing Sales Rule (TSR) fees, clarifying that the updated fees for accessing the National Do Not Call Registry will take effect on October 1, 2025, not October 1, 2024, as previously stated. This correction, effective immediately as of September 5, 2025, aligns with the Do-Not-Call Registry Fee Extension Act of 2007. 16 CFR 310.8
AUTOMOBILE INSURANCE
Colorado has amended its regulations to establish governance and risk management standards for insurers using external consumer data (ECDIS), algorithms, and predictive models in individual life, private passenger auto, and health benefit plans, with a focus on preventing unfair discrimination. Insurers must implement detailed oversight frameworks, conduct testing, and report compliance progress by June 1, 2024 (life insurers), and by December 1, 2025, for auto and health insurers. 3 CCR 702 Reg. 10-1-1 s 1
Colorado issued guidance to property and casualty insurers regarding House Bill 25-1179, which mandates coverage for the replacement of child restraint systems involved in motor vehicle accidents. Effective January 1, 2026, insurers must ask claimants if a child restraint system was present in the vehicle and, if so, cover its replacement under specified coverages—regardless of occupancy at the time of the loss. Bulletin B-5.52
Georgia updated its Department of Driver Services regulations to strengthen liability insurance requirements related to DUI offenses and probationary licenses in compliance with SB 121 passed in April 2025. Minimum coverage increases from standard amounts to higher thresholds for first DUI convictions and even greater amounts for subsequent DUIs. 375-3-3-.02
CAPTIVES
Alabama has extended its temporary moratorium on the licensing or registration of new captive insurers and domestic risk retention groups until June 30, 2026. The Department of Insurance advises affected entities not to submit applications or fees during this period, though applications submitted before March 1, 2025, will continue to be processed. Bulletin 2025-05
COMMERCIAL LINES INSURANCE
Michigan’s Department of Insurance and Financial Services updated the list of municipalities participating in the Fire Insurance Withholding Program, effective October 1, 2025. The program allows certain municipalities to escrow 25% of fire insurance settlements for specified property losses, with participation and coverage varying by municipality population and county size. Insurers must be notified at least 30 days before new municipalities apply the program’s provisions. Notice Dated 9/1/25
CROP HAIL INSURANCE
United States' Risk Management Agency (RMA) issued a bulletin outlining amendments to the Federal Crop Insurance Act under the One Big Beautiful Bill Act (OBBBA). Key changes include expanded benefits and premium subsidies for Beginning Farmers or Ranchers, increased coverage levels and subsidies for Whole-Farm Revenue Protection and Supplemental Coverage Option policies, and updated premium subsidy rates for various unit elections. Approved insurance providers must distribute the amendment to affected insureds within 30 days of the bulletin or prior to cancellation. MGR-25-006
FILING REQUIREMENTS / PROCEDURES
Delaware issued a revised bulletin clarifying its policy on miscellaneous fees in property and casualty insurance policies. The Department of Insurance specifies that only certain fees—such as installment, late payment, reissuance, and rejected payment fees—may be charged, and all such fees must be actuarially justified and included in rate filings. Carriers have six months from July 23, 2025, to bring filings into compliance, and transaction fees may only be passed to customers under strict conditions. Forms and Rates Bulletin 41 (Revised)
MISCELLANEOUS
California issued a bulletin outlining procedures for year-end review of corporate insurance filings requiring Department of Insurance approval by the end of 2025. General corporate filings must be submitted by September 15, and Holding Company Act applications by October 13, with strict requirements for completeness and deadlines for curing deficiencies. Notice Dated 8/15/25
New York's Governor declared a state of emergency from September 5 to October 5, 2025, enabling licensed physicians, nurse practitioners, and pharmacists to prescribe, order, and administer COVID-19 vaccines to patients aged three and older, with expanded authority for pharmacists to deliver vaccines via multiple methods under specific regimens. Executive Order 52
PERSONAL LINES INSURANCE
California reminds property and casualty insurers of their legal obligation to provide wildfire-related claim documents to claimants within 15 calendar days of a request. This notice, issued in response to complaints from 2025 Southern California wildfire survivors, reinforces that all materials related to damage evaluation—such as estimates, reports, and scopes of loss—must be disclosed, excluding privileged or exempt documents. Notice Dated 8/25/25
Hawaii’s Insurance Division issued guidance on Act 110, effective January 1, 2026, updating cancellation and nonrenewal notice requirements for insurance policies covering properties used for residential purposes. The amendments apply to both personal and commercial policies where the property is wholly or partially residential—including single-family homes, multi-family dwellings, condominiums, and mixed-use buildings with residential units. Memorandum 2025-6R
Rhode Island issued guidance on the use of aerial and satellite imagery in homeowners insurance underwriting and claims, requiring images to be clear, accurate, and no older than 15 months. Insurers cannot base cancellations, non-renewals, or claim decisions solely on low-quality or outdated images and must conduct further investigation when necessary. Best practices include notifying homeowners before non-renewal, sharing imagery, allowing disputes, and providing repair time; failure to comply may be deemed unfair trade or claims settlement practices. Bulletin 2025-3
REINSURANCE
New Jersey published updated lists of reinsurers—including accredited reinsurers, licensed out-of-state reinsurers, and those maintaining trust funds—allowing insurers to take full credit for reinsurance ceded to these reinsurers through September 1, 2026, in compliance with state credit-for-reinsurance laws. Notice Dated 9/1/25
REPORTS - DATA CALLS & OTHER REPORTS
Delaware now requires insurers and related parties to complete a liability insurance survey by September 18, 2025, in response to growing challenges faced by childcare and foster care businesses in securing coverage. The Department of Insurance seeks detailed information on various liability products—including general, professional, abuse and molestation, and foster parent liability—to assess market availability and inform future action. Bulletin 156
SURPLUS LINES
Alaska will hold a public hearing on October 15, 2025, to gather testimony on insurance types that are difficult to obtain from admitted insurers, aiming to update the surplus lines placement list under 3 AAC 25.040. The hearing will take place at Wedgewood Resort in Fairbanks, with options to participate via video conference or phone. Notice Dated 9/8/25
District of Columbia requires all licensed surplus lines producers to transition to the OPTins electronic filing system for surplus lines premium tax filings, effective January 1, 2026. Monthly reports of unauthorized business must be filed electronically only if there is activity, while semi-annual reports are mandatory regardless of activity. Bulletin 25-IB-002-
New Jersey published updated lists of eligible foreign, domestic, and alien surplus line insurers, including additions, deletions, name changes, and redomiciled insurers with updated alien identification numbers. Notice Dated 8/26/25
WORKERS' COMPENSATION
California's Division of Workers’ Compensation (DWC) posted additional adjustments to the Official Medical Fee Schedule for Hospital Outpatient Departments and Ambulatory Surgical Centers. The updated order is effective for services rendered on or after July 1, 2025, and is available on the DWC website. DWC Release 2025-86
Connecticut's Workers’ Compensation Commission updated the average weekly wage, maximum compensation rates, and cost-of-living adjustments. The new maximum compensation rate for total disability and dependent benefits is $1,716.00, while the rate for partial disability is $1,220.00, based on manufacturing sector earnings. Memorandum 2025-04
Kentucky's Department of Workers’ Compensation issued the 2026 Workers’ Compensation Benefit Schedule, reflecting an average weekly wage of $1,161.81 for 2024. As a result, the maximum weekly indemnity benefit for total disability or death in 2026 will increase to $1,277.99, and the minimum weekly indemnity benefit will rise to $232.36. A complete schedule of benefits accompanies the notice. Notice Dated 9/2/25
Michigan’s Compensation Advisory Organization (CAOM) announced that 2026 experience modifications will be issued starting October 15, 2025. Carriers must notify CAOM by October 8, 2025, to avoid revisions, and rating plan changes must be submitted at least 60 days before their effective date. Experience rating factors have shifted from the DCA Publication to the Facility Filing, and insurers must file rating plans with the DOI while separately notifying CAOM. Renewal modifications will be distributed starting October 16, and non-renewal quotes from November 1. WC Circular Letter 360 CAOM
Minnesota’s Department of Commerce updated the Minnesota Basic Manual in compliance with legislative changes to home care services workers under House File 3228, effective October 1, 2025. The issued circular revises Rule 3.D. and includes exhibits showing the updated language. WC Circular Letter 25-1865
Nebraska’s Workers’ Compensation Court updated its mandatory Release of Liability forms, now requiring exclusive use of the new General and future medical liability release forms without modifications or unauthorized attachments. Filings not adhering to these requirements will be rejected. WC Notice Dated 9/8/25
North Carolina's Rate Bureau announced their submission of a filing proposing a 7.8% average decrease in workers' compensation advisory loss costs and related rating values for policies effective April 1, 2026, with a 12.8% average decrease for classifications under the Longshore and Harbor Workers' Compensation Act. Circular Letter C-25-8
Ohio's Bureau of Workers' Compensation amended its rules to clarify that premiums for elective coverage are due by the invoice date and to allow employers to cancel elective coverage by phone. Rule 4123-17-07
Oregon's Workers' Compensation Division updated supplemental disability payment and reimbursement procedures, republishing Bulletin 325 with revised forms (3530, 3531, and 3504) that include updated logos, contact info, and terminology changes. These forms are required for elections not to pay benefits, physician authorization, and quarterly reimbursement requests, with specific rules on payment timing and benefit calculations. Bulletin 325 (Revised)