Steven Kass

Steven Kass

Carlton Fields

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A Constitutional Challenge to Florida's New Unclaimed Property Act Amendments

In April, Florida amended its Disposition of Unclaimed Property Act (“Act”) to require life insurers to perform Death Master File (DMF) searches for all policies issued since 1992. The amended Act also provides that a DMF...more

8/26/2016 - Death Benefits Death Master Files Due Process Florida Impairment of Contracts Insurance Industry Life Insurance Remedial Actions Retroactive Application Unclaimed Property

Florida Imposes Additional Unclaimed Property Requirements on Life Insurers

On April 12, Florida Governor Scott signed Senate Bill 0966 into law. SB 0966 amends the insurance benefits provisions of Florida’s Uniform Unclaimed Property Act, Fl. Stat. Section 717.107. These amendments effectively...more

4/13/2016 - Death Benefits Florida Insurance Industry Insurance Regulations Life Insurance New Legislation Unclaimed Property

Storm Clouds Gather for Life Insurers’ Cost of Insurance Rate Increases

For more than two decades any insurer increasing its cost of insurance (COI) rates on its universal life policies was likely to be met with policyholder lawsuits and even, occasionally, regulatory resistance. Until the past...more

2/24/2016 - Insurance Industry Insurance Rates Life Insurance

Bill to Amend Florida’s Unclaimed Property Act Regarding Unclaimed Insurance Benefits Moves to Senate Floor

On January 19, the Florida Senate Banking and Insurance Committee approved a Senate bill (“SB 966”) that would modify Florida’s existing Unclaimed Property Act (the “Act”) requirements regarding unclaimed insurance benefits....more

1/26/2016 - Florida Insurance Industry Life Insurance Pending Legislation Unclaimed Property

Florida's OIR Provides Guidance on Annuity Maturity Date Extensions

On December 15, the Florida Office of Insurance Regulation (OIR) issued an Informational Memorandum, OIR-15-08M (Memorandum) regarding the extension of annuity contracts maturity dates beyond their original date. The...more

1/6/2016 - Annuities Extensions Insurance Industry Insurance Regulations Life Insurance Variable Annuities

Cuba Sanctions Relief: Baby Steps Today, But What About Tomorrow?

For more than 50 years, an embargo and related sanctions regime has restricted U.S. businesses and individuals from virtually all economic activity involving Cuba or its nationals. This regime was implemented through a...more

10/7/2015 - BIS Cuba Embargo Executive Orders Financial Institutions Interpretive Rule Investors OFAC Sanctions Shipping Telecommunications Trade Policy U.S. Treasury

Cuba Sanctions Relief: The Knot Further Loosens

Effective September 21, the U.S. Department of Treasury amended its Cuban Assets Control Regulations (CACR), providing further Cuba sanctions relief. In a coordinated action, the U.S. Department of Commerce simultaneously...more

9/22/2015 - BIS Critical Infrastructure Sectors Cuba Cuban Assets Control Regulations (CACR) EAR Export Administration Regulations Financial Institutions Obama Administration OFAC Sanctions Shipping Telecommunications Trade Policy U.S. Commerce Department

Georgia Provides Guidance on Variable Annuity Sales Disclosures

On March 19, the Georgia Office of Insurance and Safety Fire Commissioner (the "Department") issued Bulletin 15-EX-1 (the "Bulletin") to clarify Georgia's required variable annuity sales disclosures. This guidance follows the...more

3/26/2015 - Disclosure Requirements Insurance Industry Variable Annuities

Trick or Treat? Halloween Meeting of NAIC's Contingent Deferred Annuity Working Group

During its October 31 conference call, the NAIC's Contingent Deferred Annuity (CDA) Working Group startled issuers and those considering issuing CDAs by reawakening a discussion on whether CDAs should contain nonforfeiture or...more

11/5/2014 - Annuities NAIC

Florida Modifies Its Annuity Suitability Rule

On October 1, the Florida Department of Financial Services (DFS) amended Florida Administrative Code Rule 69B-162.011, "Suitability and Disclosures in Annuity Contracts – Forms Required" (the Suitability Rule). This amendment...more

10/9/2014 - Annuities Department of Financial Services Life Insurance

NAIC Unclaimed Life Insurance Benefits Working Group Recommends Development of Model Law and Comment Letter to Uniform Law...

On September 17, 2014, the NAIC's Unclaimed Life Insurance Benefits (A) Working Group (Working Group) discussed its recommendations to the Life Insurance and Annuities (A) Committee (the (A) Committee) concerning unclaimed...more

9/23/2014 - Life Insurance NAIC Proposed Legislation Unclaimed Life Insurance Benefits Act

Louisiana Issues Advisory Letter Regarding Use of the Social Security Administration's Death Master File

On September 4, the Louisiana Department of Insurance issued Advisory Letter 2014-04 (the "Advisory") to advise all life and annuity insurers licensed in Louisiana regarding use of the Social Security Administration's Death...more

9/17/2014 - Annuities Death Master Files Life Insurance Social Security Social Security Administration (SSA)

Florida Proposes Rule for Annuity and Life Insurance Surrender Disclosures

On September 4, the Florida Department of Financial Services (the "Department") published a Notice of Rule Development for Proposed Rule 69B-215.090, Florida Administrative Code (the "Proposed Rule") setting out disclosure...more

9/9/2014 - Annuities Life Insurance

Florida Court Rejects "Date of Death" Trigger for Escheating Life Insurance Death Benefits Under Florida's Unclaimed Property Act

On August 5, Florida's First District Court of Appeal reversed a ruling issued by Florida's Department of Financial Services ("DFS") that would have triggered an insurer's duty to escheat life insurance benefits under...more

8/20/2014 - Death Benefits Escheat Life Insurance Unclaimed Property

NAIC's Newly Appointed Unclaimed Life Insurance Benefits Working Group Seeks Comments Before The Spring National Meeting

During its March 13, 2014 conference call, the NAIC's Life Insurance and Annuities (A) Committee appointed an Unclaimed Life Insurance Benefits (A) Working Group charged with "undertaking a study to determine if...more

3/17/2014 - Life Insurance NAIC Unclaimed Life Insurance Benefits Act

Department Of Commerce Seeks Public Comment On Certification Program For Death Master File Access

In response to privacy-related concerns about the potential misuse of the Social Security Administration's Death Master File (DMF), Congress restricted access to the DMF in late 2013. Section 203 of the Bipartisan Budget Act...more

3/6/2014 - Death Master Files Social Security Social Security Administration (SSA) U.S. Commerce Department

West Virginia Court Dismisses Lawsuits Challenging Life Insurers’ Unclaimed Death Benefits Practices

On December 27, 2013, a West Virginia court dismissed 63 separate lawsuits brought by the Treasurer of the State of West Virginia ("Treasurer") against life insurance companies doing business in West Virginia. The court...more

1/6/2014 - Death Benefits Life Insurance Unclaimed Property

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