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During the last legislative session, Texas enacted Insurance Code Chapter 831 to adopt the corporate governance annual disclosure (“CGAD”) annual filing requirement for all Texas domestic insurers and HMOs. The purpose of the CGAD filing is to have insurers or insurance groups disclose information about the corporate governance structure, policies, and practices to permit the Texas commissioner to gain and maintain an understanding of the insurer's corporate governance framework.

The Texas Department of Insurance (“TDI”) published a bulletin stating that TDI is developing rules to implement the CGAD requirement and that TDI will not require a CGAD filing for this year. However, an insurer or HMO that is a part of an insurance group, and has a lead state other than Texas, should check their lead state's filing requirements.

A copy of the Texas Commissioner’s bulletin can be found here.