News & Analysis as of

Comment Period Insurance Industry

Orrick, Herrington & Sutcliffe LLP

Fed requests comments on its Large Financial Institution rating system

On July 15, the Fed published a notice and request for comment in the Federal Register on revisions to its Large Financial Institution (LFI) rating system and the Insurance Supervisory Framework. The rating system governs...more

Rivkin Radler LLP

Advisory Council Recommends Amending NY’s Commercial Division Rules

Rivkin Radler LLP on

The Administrative Board of the Courts is seeking public comment on a proposal by the Commercial Division Advisory Council to amend the Commercial Division rules (22 NYCRR § 202.70) to clarify what types of insurance cases...more

Orrick, Herrington & Sutcliffe LLP

California privacy agency opens comment period on regulations

On May 9, the California Privacy Protection Agency (CPPA) announced it opened the formal public comment period for its proposed regulations concerning updates to the California Consumer Privacy Act. The proposed rules would...more

Sheppard Mullin Richter & Hampton LLP

California’s Privacy Regulator Had a Busy November: What Does It Mean for Businesses?

The California Privacy Protection Agency released proposed CCPA rules for a variety of topics in November, as well as announcing an investigative sweep for compliance with the Delete Act. Topics include the following, which...more

Troutman Pepper Locke

Iowa Insurance Division Releases Proposed AI Bulletin for Comment

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On October 10, 2024, the Iowa Insurance Division released for comment a proposed AI Bulletin based upon the NAIC AI Model Bulletin. Comments are due before October 31, 2024....more

Faegre Drinker Biddle & Reath LLP

NAIC’s Long-Term Care Insurance (B) Task Force Issues Recommendations for 2025 Charges

The NAIC’s Long-Term Care Insurance (B) Task Force (“Task Force”) has issued its recommendations for 2025 charges, which would disband the Task Force and reallocate the Task Force and the Long-Term Care (B) Working Group’s...more

Herbert Smith Freehills Kramer

NAIC Body Issues Guidance on Affiliated Investment Management for Insurers

Insurers that outsource investment management to affiliates should consider new guidance from insurance regulators on such arrangements. On March 19, 2024, following its March 16 session at the National Association of...more

Herbert Smith Freehills Kramer

Department of Financial Services Issues Guidance on Group Capital Calculation Exemptions

New York-domiciled insurers should consider new guidance from the New York Department of Financial Services (DFS) to determine whether they might be exempt from group capital calculation (GCC) requirements. In its proposed...more

McDermott Will & Emery

Discerning Congressional Purpose from the Proposed MHPAEA Regulations Comment Letters

McDermott Will & Emery on

We continue our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the Departments)...more

Benesch

Requirements Related to the Mental Health Parity and Addiction Equity Act

Benesch on

On July 25, 2023, the federal government introduced regulations and guidance aimed at improving adherence to the requirement that insurance companies must provide mental health and substance use disorder treatment benefits on...more

Eversheds Sutherland (US) LLP

NAIC releases highly-anticipated draft model bulletin on artificial intelligence systems used by insurers

On July 17, 2023, the Innovation, Cybersecurity and Technology (H) Committee of the National Association of Insurance Commissioners (NAIC) released for comment a highly anticipated model bulletin (Model Bulletin) on...more

Groom Law Group, Chartered

Proposed Rule Has Serious Implications on the Taxation of Fixed Indemnity and Other Similar Coverages

On July 7, the Departments of Labor, Treasury, and Health and Human Services published a proposed rule (“Proposed Rule”) regarding, among other things, the requirements for fixed and hospital indemnity insurance to be...more

Troutman Pepper Locke

NAIC Releases for Public Comment Draft Accelerated Underwriting Regulatory Guidance

Troutman Pepper Locke on

On Wednesday February 22, 2023, the National Association of Insurance Commissioners ‎‎(“NAIC”) Accelerated Underwriting (A) Working Group exposed for a ‎‎45-day comment period draft regulatory guidance while simultaneously...more

Holland & Knight LLP

En Colombia se publica proyecto de documento técnico sobre asuntos ASG en el sector asegurador

Holland & Knight LLP on

La Superintendencia Financiera de Colombia (SFC) publicó para comentarios el Proyecto de Documento Técnico No. 01 de 2023, titulado "Administración de Riesgos y Oportunidades Climáticas para el Sector Asegurador", por medio...more

Carlton Fields

A New Draft Privacy Model Blooms From the NAIC Privacy Working Group

Carlton Fields on

On February 1, the NAIC’s Privacy Working Group’s new privacy model germinated. After months of development, the exposure draft, titled “Insurance Consumer Privacy Protection Model Law #674” (Proposed Model), has finally...more

Eversheds Sutherland (US) LLP

NAIC Indexed Universal Life Illustration Subgroup solicits comment on options to revise Actuarial Guideline 49-A and to open NAIC...

On October 12th, the NAIC Life Insurance and Annuity (A) Committee’s Indexed Universal Life (IUL) Illustration (A) Subgroup (IUL Subgroup) exposed for comment four options to amend Actuarial Guideline (AG) 49-A to address a...more

Carlton Fields

NAIC Proposes Actuarial Guidelines for Index-Linked Variable Annuities

Carlton Fields on

On July 25, 2022, the Index-Linked Variable Annuity (A) Subgroup of the NAIC’s Life Insurance and Annuities (A) Committee issued for public comment an exposure draft of proposed actuarial guidelines for index-linked variable...more

Eversheds Sutherland (US) LLP

NAIC’s LATF solicits feedback on options to address concerns related to AG 49-A

​​​​​​​On August 15th, the NAIC’s Life Actuarial (A) Task Force (LATF) re-exposed for comment four options to address a concern raised by state insurance regulators regarding the use of illustrations for indexed universal...more

Carlton Fields

NAIC’s Privacy Protections Working Group Plans Extended Growing Season for Fall 2023 Harvest

Carlton Fields on

The NAIC’s Privacy Protections Working Group has updated its work plan, planting two crops for its fall 2023 harvest: Time will tell what other seedlings catch the NAIC’s eye. The above dates, however, are subject to growing...more

Herbert Smith Freehills Kramer

NAIC Discusses Best Practices for Restructuring Mechanisms

Insurers with legacy blocks of business, or with other motivations to enter into block transfers of business or corporate split-offs, should consider a recent regulator call on so-called Insurance Business Transfers (IBTs)...more

BCLP

Deadline Nears for Comments on S&P Capital Sufficiency Methodology

BCLP on

The April 29th deadline is rapidly approaching for insurers, reinsurers and other interested insurance industry participants to submit comments on S&P Global Ratings’ proposal for changing its methodology analyzing...more

Herbert Smith Freehills Kramer

NY DFS to Impose New Limits on Variable Products

Insurers writing variable annuities in New York will want to focus on newly proposed requirements from the New York Department of Financial Services (DFS) on separate account contracts...more

Eversheds Sutherland (US) LLP

Treasury publishes highly-anticipated notice of proposed rulemaking to update credit for reinsurance rules for Treasury-listed...

The US Department of the Treasury (Treasury), Bureau of the Fiscal Service (Fiscal Service) has published a Notice of Proposed Rulemaking relating to the federal regulations governing the corporate Federal surety bond program...more

Bass, Berry & Sims PLC

A Glimpse into Required Climate Risk Disclosure Considerations by the SEC

On July 28, Securities and Exchange Commission (SEC) Chair Gary Gensler delivered remarks at the Principles for Responsible Investment’s Climate and Global Financial Markets Webinar. In his remarks, he offered a glimpse of...more

Faegre Drinker Biddle & Reath LLP

NAIC Issues Recommendations to Support Racial Equity

The National Association of Insurance Commissioners’ (NAIC) Special (EX) Committee on Race and Insurance met during the virtual Spring National meeting on April 12 to discuss its recently proposed 2021 charges. The lengthy...more

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