News & Analysis as of

Insurance Regulations Employee Benefits

Carlton Fields

SEC Staff Updates Guidance on Rate Sheet Supplements to Include Changes to Index Loss Limits in RILAs

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On August 4, SEC staff updated guidance on the use of rate sheet supplements in disclosing changes to terms in insurance products. As revised, updated ADI 2018-05 enables insurers to use rate sheet supplements to notify...more

Carlton Fields

NAIC Annuity Suitability Working Group Issues Guidance on Insurers’ Oversight of Third-Party Supervising Entities

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On August 7, 2025, the National Association of Insurance Commissioners’ Annuity Suitability (A) Working Group issued draft safe harbor regulatory guidance with a comment period that ends on September 22, 2025. The draft...more

Carlton Fields

Unsafe Harbor? Deregulation and the Limit of the Secure Act Safe Harbor for Selection of Lifetime Income Provider

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On January 31, 2025, President Trump signed Executive Order 14192, titled“ Unleashing Prosperity Through Deregulation.” Its stated purpose was to encourage the reduction of private expenditure required to comply with federal...more

Stinson - Benefits Notes Blog

Federal Agencies Hit Pause on MHPAEA 2024 Final Rule Enforcement

On May 15, 2025, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) issued a statement of non-enforcement (the “Statement”) announcing that they will not enforce the 2024 Final Rule under...more

Davis Wright Tremaine LLP

What Relief Does the Mental Health Parity and Addiction Equity Act Nonenforcement Policy Actually Provide to Employers?

Employers navigating the complexities of the Mental Health Parity and Addiction Equity Act ("MHPAEA") may find themselves questioning the true impact of the federal government's recently issued nonenforcement policy. This...more

Verrill

Preventive Services vs. Preventive Care

Verrill on

In the context of medical coverage, the terms “Preventive Services” and “Preventive Care” are often used interchangeably. The two terms, however, have very different meanings. Understanding the difference can have significant...more

Venable LLP

Government Issues Nonenforcement Statement on Mental Health Parity Rules

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The government recently stated that it will delay enforcement of the 2024 final rules on the Mental Health Parity and Addiction Equity Act (MHPAEA). (Our previous alert regarding the 2024 final rules can be found here.) This...more

Carlton Fields

NAIC Life and Annuity Illustration Subgroup and Suitability Working Group Construct More Guidance

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At the NAIC Spring National Meeting, the Illustration Subgroup and the Suitability Working Group reported that they are building out the following additions...more

Maynard Nexsen

Can ERISA Plans Avoid California Insurance Code Section 10110.6 with Choice-of-Law Provisions?

Maynard Nexsen on

The Ninth Circuit is considering the enforceability of a choice of law provision in an ERISA plan in William White v. Guardian Life Insurance Company, et al., Case No. 24-2681, appeal pending from the United States District...more

Carlton Fields

Will Insurers Be Required to Don a Deerstalker? The Case of Third-Party Vendors in Insurance

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Regulators are growing concerned about the delegation of various insurance company functions, prompting a closer examination of third-party vendors. Several groups within the National Association of Insurance Commissioners...more

Carlton Fields

Expect Focus - Volume IlI, September 2024

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Gone With the Wind? Closed-End Funds Risk Extinction - Shares of SEC-registered closed-end funds (CEFs) have long held significant potential advantages for some investors. For example, unlike shares of mutual funds...more

Nelson Mullins Riley & Scarborough LLP

Gold Dome Report - Legislative Day 37 - March 2024

Senate committee meetings continue under the Gold Dome as this report is published on Wednesday. With the Senate’s requirement that bills pass out of committee before the chamber convenes for Legislative Day 38, legislators...more

Pullman & Comley - Labor, Employment and...

Group Health Plans and Medicare Secondary Payer Rules: Do the Mandatory Reporting Obligations Apply to You?

The Medicare Secondary Payer provisions (MSP) apply to group health plans sponsored by employers with 20 or more employees, in both the private and public sectors. MSP’s mandatory reporting requirements are designed to...more

Carlton Fields

Expect Focus - Volume III, September 2023

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Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Polsinelli

Third Party Administrator Newsletter - December 2021

Polsinelli on

New Law Regulating Health Care Benefit Managers in Washington State - We have previously reported on the new law that became effective this past summer in Washington requiring TPAs that administer self-funded workers’...more

Ballard Spahr LLP

Short-Term Limited Duration Insurance Rule Upheld

Ballard Spahr LLP on

The U.S. Court of Appeals for the District of Columbia Circuit upheld the final regulations issued by the Trump administration that increased the availability of short term, limited duration insurance (STLDI). ...more

Morgan Lewis

New Laws And Regulations: Insights For 2020

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A constantly evolving framework of laws governing how multinational businesses can contact customers to how nonprofits report business income to how overtime is calculated and paid will influence how companies do business...more

Carlton Fields

Suitability Working Group Stirs Ingredients for Suitability Model Potion

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On October 22 and 23, the NAIC Annuity Suitability (A) Working Group (Suitability WG) held an interim meeting to review comments received on the Suitability in Annuity Transactions Model Regulation (Model 275) (Suitability...more

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