News & Analysis as of

Department of Labor (DOL) Consumer Insurance Products

Seyfarth Shaw LLP

Agencies Defer Final Action on Junk Insurance, While Suggesting Caution Against One Last “Binge”

Seyfarth Shaw LLP on

The agencies have finalized a portion of their proposed rules impacting so-called “junk insurance” regarding short-term limited-duration insurance, but deferred finalizing the more significant changes that would have impacted...more

Ballard Spahr LLP

Comprehending the Non-Comprehensive: Proposed Rules Tackle Non-Traditional Coverage

Ballard Spahr LLP on

The Departments of Labor, Health and Human Services, and the Treasury have published a set of proposed rules that impose new limits on two types of benefits: short-term limited-duration insurance (STLDI) and fixed indemnity...more

Seyfarth Shaw LLP

My Insurance Doesn’t Cover That? Agency Guidance on “Junk Insurance”

Seyfarth Shaw LLP on

Seyfarth Synopsis: Fresh on the heels of the IRS Chief Counsel Memorandum on wellness and indemnity products, discussed in our prior post here, the agencies have weighed in with more formal and more expansive guidance...more

Wiley Rein LLP

Ninth Circuit: Excess Carrier Not Entitled to Challenge Payment Decisions of Underlying Carriers

Wiley Rein LLP on

The United States Court of Appeals for the Ninth Circuit, applying California law, has held that an excess insurer could not second-guess the payment decisions of underlying insurers absent a showing of fraud or bad faith, or...more

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