Property and Casualty News
November 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!
AGENT / PRODUCER LICENSING AND APPOINTMENT
California eliminated the 20-hour pre-licensing coursework requirement for certain Department of Insurance license applicants, retaining only the 12-hour ethics course certification and allowing CDI to charge associated fees. AB 943
Oklahoma issued the 2025 Appointment Renewal Notification outlining procedures and deadlines for insurers to renew producer, limited lines, title, motor service club, and managing general agent appointments. Renewals must be completed electronically via NIPR between November 25 and December 31, 2025, with fees due by the December 31 deadline; failure to pay results in termination of all appointments. The bulletin goes on to provide detailed guidance on payment methods and transaction fees. 2025 Appointment Renewal Notification
CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE
Mississippi issued guidance implementing HB 1611, which requires property and casualty, automobile, and workers’ compensation insurers to provide at least 45 days’ notice before policy renewal, cancellation, reduction of coverage, or non-renewal for policies issued or renewed on or after July 1, 2026. The bulletin clarifies compliance deadlines, defines reductions in coverage, addresses transfers of workers’ compensation policies to affiliates, and outlines policyholder rights if notice is not properly provided. Insurers must update their systems and submit amended forms via SERFF by February 28, 2026. Bulletin 2025-5
CAPTIVES
Alabama clarified that the temporary moratorium on licensing or registration of captive insurance companies under Bulletins 2025-01 and 2025-05 does not apply to registration applications from foreign risk retention groups, which will continue to be processed as usual by the Department. Clarification to Bulletins 2025-01 and 2025-05
CLAIMS / CLAIMS ISSUES
Michigan released a bulletin addressing improper claims administration practices in the automobile insurance industry, emphasizing compliance with the Insurance Code to ensure prompt, fair, and equitable claim handling. The bulletin identifies abusive practices such as misrepresentations, delayed investigations, underpayment of claims, and improper handling of total-loss vehicles. DIFS will investigate complaints and may impose sanctions, including fines or suspension/revocation of an insurer’s certificate of authority. Bulletin 2025-25-INS
New Mexico amended its Unfair Claims Practices law, adding a new subsection to prohibit insurers from treating inquiries about damage or loss as claims when no payment is made, the policy does not cover the inquiry, and the inquiry involves no deceptive conduct. This applies to all property and homeowner’s insurers. Bulletin 2025-010
CREDIT INSURANCE
Massachusetts issued a bulletin updating deviated case rates for credit life and credit accident and health insurance sold through motor vehicle dealers. Effective for policies issued or renewed from January 1, 2026, through December 31, 2028, single life insurance is set at $0.70 per $1,000 of coverage per month, joint life at $1.12, and credit accident and health insurance rates vary by year of coverage, starting at $0.70 per $100 of indebtedness. Bulletin 2025-05
CYBERSECURITY
Delaware issued a warning to regulated entities about an active phishing campaign targeting insurance carriers, TPAs, and others, involving fraudulent emails impersonating the DOI. The bulletin advises recipients not to click links or download attachments, to verify sender addresses, and to follow organizational cybersecurity protocols. The DOI emphasizes vigilance, staff training, and proactive security measures to protect sensitive information. Universally Applicable Bulletin 10
DISCRIMINATION
Delaware issued guidance on House Substitute 1 for House Bill 55 which prohibits unfair discrimination in insurance based on military status. Insurers may not deny, cancel, exclude, or modify coverage solely due to an individual’s military status, applying to active-duty service members, reservists, veterans, and their dependents. Carriers must update operational materials, maintain documentation for any legally authorized distinctions, and ensure marketing, sales, and claims practices comply with the Act. Domestic-Foreign Insurers Bulletin 161
FILINGS: PROPERTY / CASUALTY
Massachusetts issued filing guidance for insurers on new disclosure requirements addressing “junk fees” and Negative Option Features in personal lines property and liability insurance. Starting March 2, 2026, policies with these features must include both the insurance application and a separate policyholder notice meeting disclosure requirement sent 30 to 5 days before automatic renewal or action deadlines. All related forms must be submitted via SERFF by November 28, 2025. Filing Guidance Notice 2025-T
FEDERAL GOVERNMENT SHUTDOWN RELIEF
Alabama encourages insurers to offer reasonable accommodations, such as payment plans or premium extensions, to policyholders affected by the federal government shutdown. The Department advises impacted federal employees to contact their insurers directly to discuss available options. Bulletin 2025-07
Arizona issued a bulletin urging insurers to provide at least 60 days of relief to policyholders affected by the federal government shutdown. Recommended measures include extending grace periods, delaying cancellations, waiving late fees, and offering flexible payment plans. The Department clarified that such actions will not violate the Unfair Trade Practices Act if applied fairly and consistently. Bulletin 2025-10 (INS)
California released a notice urging insurers and related entities to provide protective measures for policyholders affected by the federal government shutdown, particularly federal employees. The DOI requests grace periods for premium payments, postponement of cancellations or non-renewals, and extensions or waivers of claim and underwriting deadlines for at least 30 days or through the duration of the shutdown. Notice of October 23, 2025
Colorado urges insurers to provide relief to policyholders affected by the federal government shutdown, particularly federal employees. Recommended measures include a 30-day grace period for premium payments, waiving late fees and penalties, offering flexible payment options, and clearly communicating available support to prevent coverage lapses or cancellations. Bulletin B-6.05
Connecticut released a bulletin directing insurers to provide at least a 60-day grace period or flexible payment options for federal employees affected by the ongoing government shutdown. The bulletin applies to life, health, auto, property, casualty, and other insurance lines, aiming to prevent cancellations or penalties for nonpayment of premiums while maintaining policy terms. Bulletin IC-46
Delaware released a bulletin guiding insurers to provide relief for federal employees affected by the government shutdown. Carriers are encouraged to offer at least a 60-day premium payment grace period, suspend late fees and penalties, refrain from cancellations or non-renewals due to nonpayment, accept proof of federal employee status, and provide extensions for property repairs. These accommodations should remain in effect during the shutdown and for 30 days afterward. Domestic-Foreign Insurers Bulletin 160
Illinois requests property and casualty insurers protect federal employees affected by the government shutdown. Insurers are asked to place a moratorium on cancellations or non-renewals for unpaid premiums for at least 30 days or through the shutdown, with an additional 30-day extension if compensation remains unpaid. The bulletin also requests extending repair deadlines by at least 30 days for consumers unable to complete repairs within policy timeframes. Bulletin 2025-17
Maine issued a bulletin urging licensed insurers to provide relief to policyholders affected by the federal government shutdown, including federal employees and those dependent on federal funding. Carriers are encouraged to offer a minimum 60-day grace period for premium payments or flexible payment options to prevent cancellations or penalties, while maintaining policy terms. Bulletin 488
Oregon asks insurers to assist policyholders affected by the federal government shutdown by offering at least a 30-day grace period for premium payments, refraining from cancellations or non-renewals, waiving or providing flexible options for late fees, and extending deadlines for claims or other communications. Insurers are also encouraged to proactively communicate available assistance and ensure customer service and producers are prepared to support impacted individuals. Bulletin DFR 2025-8
MISCELLANEOUS
Colorado adopted rules requiring insurers to respond to requests for commercial or personal automobile policy information and certified copies of homeowner insurance policies within 30 calendar days of receipt. Insurers must provide copies of the requested policies, retain records of requests and responses for the current year plus two prior years, and, if the Commissioner is the registered agent, provide an electronic mailing address to facilitate submissions. 3 CCR 702 Reg. 5-1-27
Tennessee advises insurers to use aerial imagery responsibly in property and homeowners insurance, ensuring it is recent, accurate, and supplemented by physical inspections. Homeowners must be notified, allowed to review or dispute imagery, and given time for repairs before adverse actions. Relying solely on outdated or unclear imagery for claims or policy decisions is considered an unfair practice, and noncompliance may result in penalties. Bulletin 25-03
PERSONAL LINES INSURANCE
California requires insurers effective 1/1/26, after a total dwelling loss due to a declared state of emergency, to offer 60% of personal property coverage limits (up to $350,000) without an itemized claim and extends the proof-of-loss deadline to 100 days. The bill also enacts the Insurance and Climate Risk Market Intelligence Act, requiring large admitted insurers to annually report reinsurance and catastrophe model data to the Department of Insurance. SB 495
Colorado issued a bulletin to clarify that auto insurance deductibles are the policyholder’s contractual responsibility and to prohibit insurers from participating in or condoning arrangements where repair shops waive deductibles. Insurers must ensure producers and representatives do not promote deductible waivers, communicate this obligation to policyholders, and investigate or report any instances of deductible waivers that may constitute fraud or violate state law. Bulletin B-5.54
PHARMACY BENEFIT MANAGERS
California has enacted reforms governing pharmacy benefit managers (PBMs) and prescription drug cost-sharing. The bill establishes fiduciary duties for PBMs, prohibits spread pricing, mandates passthrough pricing and full rebate disclosure, and bans discriminatory practices against nonaffiliated pharmacies. It also bars insurers from charging enrollees cost-sharing amounts exceeding what the plan actually pays for prescription drugs and requires contracts and oversight measures to ensure compliance. SB 41
New Mexico updated its licensing and compliance procedures for Pharmacy Benefit Managers (PBMs) under the Pharmacy Benefits Manager Act. PBM license applications must now be submitted through the Company Licensing Bureau, with renewal and annual report fees required by March 1 each year, while compliance reporting is completed via SERFF. The bulletin details required documents, reporting deadlines, and confidentiality procedures, emphasizing that noncompliance may result in penalties. Bulletin 2025-011
PROPERTY INSURANCE
California amended its Civil Code Section to expand the unenforceability of restrictive covenants that limit residential use, extending protections to developments redeveloping commercial properties for housing under state or local housing laws. The bill also applies these provisions to restrictions in reciprocal easement agreements and requires county officials to verify eligibility and record modification documents for qualifying affordable housing developments. AB 1050
California extended existing wildfire-related non-renewal protections to commercial property insurance policies. Under new Insurance Code Section 675.55, insurers are prohibited from canceling or refusing to renew commercial property insurance for one year after a declared state of emergency if the property is within or adjacent to the fire perimeter, except under specified conditions such as willful misconduct or material risk changes. SB 547
Virginia clarified that labor and other nontangible costs (e.g., taxes, fees, overhead, profit) cannot be depreciated when calculating actual cash value (ACV) for property insurance claims. Only physical property may be depreciated, and improper depreciation of labor or intangibles constitutes an unfair claims settlement practice. This guidance applies to all insurers writing fire, homeowners, or dwelling property insurance in Virginia. Administrative Letter 2025-06
REPORTS - DATA CALLS & OTHER REPORTS
Texas published a bulletin requiring licensed property and casualty insurers (excluding farm mutuals and surplus lines) to submit 2025 annual experience and workers’ compensation deductible data by February 6, 2026. The data supports TDI’s annual report to state leadership and the public and must be retained until February 6, 2027. Forms and instructions are provided by TDI. Bulletin B-0016-25
SURPLUS LINES
Alabama adopted the SLIP+ for States platform for reporting and payment of surplus line policy data and taxes, replacing the NAIC’s OPTins platform. Surplus line brokers and non-admitted carriers must use SLIP+ for States for policies effective on or after January 1, 2026, with a 6% surplus line tax and a 0.175% transaction fee applied to each transaction. The bulletin also outlines quarterly and annual reporting and payment procedures, with annual tax remittances due by March 1 each year. Bulletin 2025-06
Connecticut issued a bulletin to revise and clarify surplus lines placement requirements for Property & Casualty licensees, superseding Bulletins SL-3 and SL-5. The bulletin updates the diligent effort requirement for brokers, electronic tax filings through OPTins, and guidance for flood insurance and exempt commercial purchasers. Bulletin SL-6
Delaware reminds licensed Surplus Lines Brokers of their responsibility to collect and remit annual premium taxes on surplus lines policies, as required under 18 Del. C. Section 1925. The published bulletin details mandatory electronic filing forms through OPTins, due dates, submission requirements, and the use of individual Delaware license numbers, emphasizing that brokers, not producers, are solely responsible for compliance. Surplus Lines Bulletin 22
TITLE INSURANCE / AGENTS
FinCEN renewed its Geographic Targeting Orders (GTOs), now requiring title insurance companies to identify the natural persons behind shell companies in non-financed residential real estate purchases. The orders apply to specified counties in major metropolitan areas across 14 states and D.C., with a $300,000 purchase threshold ($50,000 in Baltimore), and aim to prevent illicit activity in the real estate market. Compliance resources and guidance are available on FinCEN’s website. FinCEN Notice Dated 10/9/25
WORKERS' COMPENSATION
Arizona approved a 6.7% reduction in Workers’ Compensation rates effective January 1, 2026, marking the 12th consecutive year of decreases. The reduction, based on NCCI’s annual rate filing, reflects declining claims frequency and utilization. Notice Dated 11/3/25
California expanded worker safety protections in the artificial stone fabrication industry by classifying silicosis and silica-related lung cancer as “serious injuries or illnesses” under the Labor Code. The amendments also update the definition of “serious physical harm” to include these conditions, strengthening penalties and oversight for workplace safety violations involving silica exposure. SB 20
California updated the inpatient hospital section of the Official Medical Fee Schedule (OMFS) to align with recent Medicare payment system changes. The revised fee schedule takes effect December 1, 2025, with additional details are available on the Division of Workers’ Compensation website. DWC Release 2025-110