On July 17, 2023, the New York Department of Financial Services (DFS) issued Insurance Circular Letter No. 6 (2023) (“Letter No. 6”) and a concurrent press release seeking to clarify, and in our opinion repeal, earlier...more
Information data security has been a hot topic for the insurance industry in recent years, particularly the development of information security programs (“ISPs”) by insurers, producers, and other insurance licensees. New York...more
When an insurer discovers that insureds are being treated differently in any scenario, it is important to consider very seriously whether such differential treatment could be contrary to unfair trade practices laws....more
Like nearly every sector of the U.S. economy, the insurance industry, including insurance carriers, agents, brokers, adjusters, and other licensees, is being severely affected by the COVID-19 outbreak. Beginning in early...more
In our blog post of July 10, 2018, we discussed the key elements of the Final Rule issued on June 21, 2018 with respect to Association Health Plans (AHPs). As we noted, the expansion of ERISA’s definition of an employer and...more
Health Plans and health care providers are getting into each other’s business. This payor/provider convergence has taken different forms. Health systems have ventured into the health insurance business by acquiring or...more
The National Association of Insurance Commissioners (NAIC) Cybersecurity (EX) Task Force released its second version of the Insurance Data Security Model Law (Model) on August 17. The first version was exposed on March 3, and...more
Last week, the National Association of Insurance Commissioners (NAIC) hosted the 2016 NAIC International Insurance Forum. The Forum addressed topics such as the management of catastrophic disaster risks, industry perspectives...more
The National Association of Insurance Commissioners (NAIC) Spring 2016 National Meeting, which was held from April 3 – 6 in New Orleans, offered insight into numerous issues being considered by state commissioners nationwide....more
4/19/2016
/ Accreditation ,
Affordable Care Act ,
Annuities ,
Big Data ,
Cybersecurity ,
Department of Labor (DOL) ,
Fiduciary Duty ,
Health Insurance ,
Insolvency ,
Insurance Industry ,
Life Insurance ,
Mortgage Insurance ,
NAIC ,
NARAB ,
Peer-to-Peer ,
Popular ,
Receivership ,
Reinsurance ,
Sharing Economy ,
Surplus Lines Insurance ,
Workers Compensation Reform
On November 11, 2015, Governor Scott Walker signed Senate Bill 287 into law as 2015 Wisconsin Act 90. The law is a collection of miscellaneous changes and updates to Wisconsin’s Insurance Code, including technical corrections...more
On November 9, 2015, the New York Department of Financial Services (NYDFS) issued a letter that describes what insurers can expect from the Department’s ongoing assessment of cybersecurity measures. The letter parallels...more
As expected, on Monday, November 9, 2015, the U.S. Department of Health & Human Services (HHS) filed a Notice of Appeal from the decision issued by Judge Royce Lamberth of the United States District Court for the District of...more
On October 14, 2015, the National Association of Insurance Commissioners’ (NAIC) Cybersecurity Task Force adopted the Cybersecurity Bill of Rights, a document meant to inform consumers of the services they can expect from...more
11/5/2015
/ Breach Notification Rule ,
Consumer Reporting Agencies ,
Credit History ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Breach ,
Data Breach Plans ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
Data-Sharing ,
Fair Credit Reporting Act (FCRA) ,
Fraud Alerts ,
Free Identity Theft Protection ,
Insurance Industry ,
NAIC ,
Personal Data ,
Privacy Policy
The Iowa Commissioner of Insurance (the “Commissioner”) filed a petition, on January 29, 2015, seeking to liquidate CoOpportunity Health, Inc. (“CoOpportunity”), a Consumer Operated and Oriented Plan (“CO-OP”) established...more
In 2014, the Florida Legislature enacted a law that makes significant changes to the way insurance agencies are licensed in Florida. The new law amends Florida’s insurance agency licensure law, and is intended to streamline...more
The National Association of Registered Agents and Brokers Reform Act of 2015 (NARAB Reform Act) amends the Gramm-Leach-Bliley Act and establishes the National Association of Registered Agents and Brokers (Association). ...more
The Iowa Insurance Commissioner obtained an Order for Rehabilitation with respect to CoOportunity Health, Inc. (“CoOportunity”) on December 24, 2014. With the Rehabilitation Order, the Iowa Insurance Commission took...more