Zoning In - Fall 2026

Northeast Zone

Connecticut

Bulletin PC-94-26, dated September 17, 2026, addresses the new requirements for personal risk insurance policy premium increases explanations effective January 1, 2027. By way of background, HB 5373 (Public Act 26-69) “allows the Insurance Commissioner to prescribe how an insured’s request for an explanation of a premium increase (a ‘Request’) may be submitted to its insurer, and the requirements for the statement to be included by insurers in the premium billing notice regarding the Request process. This Bulletin specifically addresses both items for homeowners, tenants, private passenger non-fleet automobile, and mobile manufactured home insurance. For other property and casualty insurance for personal, family or household needs, insurers may exercise their discretion regarding the requirements of the Public Act.” The bulletin provides details on the:

• Public act billing notice and reasonable explanation requirements

• Insureds' options for submitting a request and trigger of review period

• Prominent statement requirements

Regarding insurers’ revision of their premium billing notices, the Department is requesting that “insurers file, for informational purposes, the premium billing notices for renewal policies through SERFF before December 1, 2026.” New notices to policyholders are required on January 1, 2027, for future renewal effective dates.

Delaware

Current Delaware law provides that a life insurance policy may contain a provision excluding or restricting coverage in the event of death by suicide within two years from the date of issue of the policy. HB 299, effective March 3, 2027, reduces the time period to one year from the date of issue of the policy. Additionally, HB 299 also requires that, in the event any death benefit is denied because the insured dies as a result of suicide within one year from the date of issue of the policy, the insurer must refund all premiums paid for coverage providing the denied death benefit on the insured.

Maryland

Bulletin 26-24, dated October 15, 2026, notifies carriers of the adoption of the uniform continuity of care request form described in § 15-112(y)(4) of the Insurance Article. House Bill 684, Chapter 651, Acts of 2026 requires the “commissioner to develop a uniform form that carriers, providers, and health systems must use for certain requests from patients to continue to receive health care services from a health care provider whose network participation with a carrier has been terminated. The uniform continuity of care form must be used for all requests made in accordance with § 15-112(b) of the Insurance Article or 42 U.S.C. § 300gg–113.” In accordance with the Chapter 651 requirement, the Commissioner has adopted the required Continuity of Care Request Form for use. The bulletin notes that “a carrier may convert the Continuity of Care Request Form into any electronically equivalent format that contains all the instructions and information included in the required template form. The language included in each field of the Continuity of Care Request form must be included verbatim in the electronic equivalent of the physical form.” Applicability to stand-alone dental products is also addressed.

New Hampshire

Bulletin INS 26-052-AB of August 12, 2026 addresses terminations for nonpayment at renewal. In that bulletin, the New Hampshire Insurance Department (“NHID”) notes that some personal lines automobile insurers may not be issuing policy termination notices that fully comply with RSA 417-A:5. Under that statute, “if an insured fails to timely pay a renewal premium, the insurer may issue a notice of termination. To be legally compliant, that notice must provide the insured with a cure period of at least ten (10) days during which the insured may pay the overdue premium and continue coverage without a lapse.” The Bulletin further states that a policy may not be terminated for nonpayment of a renewal premium until after the insurer has issued a legally compliant termination notice and the expiry of the cure period.

“Accordingly, all personal lines automobile insurers shall review their current policy termination notices and related procedures to ensure compliance with these statutory requirements. Any insurer utilizing notices that are inconsistent with RSA 417-A:5 should file revised notices with the NHID no later than October 1, 2026.” The NHID indicates it may audit insurer notices and business practices to verify compliance with RSA 417-A:5.

Southeast Zone

Florida

Effective September 28, 2026, insurers subject to section 626.9891, relating to anti-fraud investigative units and anti-fraud plans, must submit the required anti-fraud plan at https://antifraudportal.fldfs.com/Default.aspx (previously at www.myfloridacfo.com). Additionally, insurers or other entities or persons subject to mandatory reporting requirements of section 626.989, relating to fraudulent insurance acts, must report suspected fraudulent acts only on the Division's website at www.myfloridacfo.com (previously at www.myfloridacfo.com or via an electronic reporting interface that is linked to the Division), and use the updated version of Form DFS-L1-1691, Suspected Fraud Referral Form (Eff. 04/26).

Mississippi

Issued October 9, 2026, Insurance Department Bulletin 2026-11 includes a directive to insurers to update the policyholder bill of rights form. Specifically, “homeowners insurance companies are directed to review their Policyholder Bill of Rights form and ensure that the form is updated to reflect the 45 days' notice requirement. All new policies issued and all renewals effective on and after January 1, 2027, shall use the amended Policyholder Bill of Rights form as found in Title 19, Part 1, Rule 34.04. To ensure timely compliance, insurers must amend and file their Policyholder Bill of Rights forms to reflect the 45 days' notice requirement with MID through SERFF before December 15, 2026.”

West Virginia

Bulletin No. 2026-03, dated October 9, 2026, states that “It has come to the attention of the Offices of the Insurance Commissioner (“OIC”) that some property and casualty insurers issuing personal lines policies may be using "price optimization" to rate insurance policies in West Virginia.” The Bulletin further describes price optimization and states that “The OIC has determined that the use of price optimization results in rates that are unfairly discriminatory and in violation of West Virginia law. Insurance rates are to be based on risk of loss and not on whether a consumer is likely to accept a higher price. While insurers may employ sound actuarial judgment in setting rates, judgmental adjustments to a rate may not be based on non-risk-related policyholder characteristics.”

Midwest Zone

Illinois

Company Bulletin #2026-13, dated October 13, 2026, addresses farm mutual insurance companies writing property insurance coverage and the applicable reinsurance requirements in 215 ILCS 120/10. The bulletin indicates that parametric covers do not qualify as reinsurance for purposes of complying with that statute. As parametric covers are “not designed to indemnify a company for actual losses or liabilities by reason of the original insurance, risk transfer requirements per Statements of Statutory Accounting Principles (SSAP) No. 62 are not met. As a result, reinsurance credit cannot be taken.” The bulletin further identifies the following:

• Any farm mutual insurance company that has entered into a signed parametric contract prior to the effective date of this bulletin, and has been using reinsurance accounting, is required to use deposit accounting until the expiration of the contract.

• Subsequent to the date of this bulletin and expiration of current in-force parametric contracts, farm mutual insurance companies are not allowed to renew, amend, or enter into a new parametric contract as these types of agreements are considered a form of a derivative or investment instrument.

• 215 ILCS 120/10 requires Director approval of the utilization of any investments other than those identified in the statute.

Michigan

Effective September 21, 2026, SB 1013 enacted new Insurance Code section 500.2027a regarding unfair and deceptive practices in property insurance price optimization. The statute describes price optimization and states that it is “an unfair method of competition and an unfair or deceptive act or practice in the business of insurance for a property and casualty insurer to use price optimization in ratemaking.” Prohibited practices include considering the likelihood of policy turnover, estimating an insured's willingness to pay higher premiums, and using measures of consumer price elasticity of demand.

Nebraska

LB 967 provides in § 44-306 that “Beginning January 1, 2027, a health insurance plan, its contractors, and its affiliates shall not restrict the method of claim payment to a health care provider for health care services to a credit, charge, or debit card, or any combination thereof.”

Western Zone

California

Bulletin 2026-7, dated October 26, 2026, sets forth the 2026 Export List. The updated list includes two additions: “Standalone, Private, Primary Flood – Personal” and “Standalone, Private, Primary Flood – Commercial.”

Oregon

Effective October 1, 2026, the Oregon Insurance Division adopted amendments to rules governing the Prescription Drug Price Transparency program in OAR chapter 836. The amendments include revised definitions, reporting thresholds, filing requirements, procedures for requesting additional information, public disclosure requirements, and assessments applicable to prescription drug manufacturers.

Texas

Bulletin B-0008-26, dated September 16, 2026, addresses premium discounts for loss mitigation applicable to residential property insurance. The Bulletin describes effective loss mitigation benefits and includes a reference to Insurance Code Chapter 2251, which provides that insurance companies may group risks by classification to set rates. It further indicates that “actions companies can take to recognize consumers who have made loss mitigation investments include:

• Explicitly incorporating each loss mitigation item into rating plans and premium calculation frameworks.

• Informing policyholders of credits available for windstorm, wildfire, and other loss mitigation efforts.

• Minimizing administrative burdens on consumers such as forcing homeowners to submit separate, redundant loss mitigation surveys or inspection forms along with any certificates or official designations.”

Utah

Bulletin 2026-5, dated October 13, 2026, addresses the use of an insurer's licensed name, an alias, and contact information in the offering of accident and health insurance. Insurers are reminded of the requirement to use their actual licensed name on explanations of benefits (EOBs) and advertisements. The Bulletin provides the statutory and regulatory citations requiring an insurer's actual licensed name to appear on EOBs and advertising materials, as well as other requirements. Additional specific requirements detailed in the bulletin include the following:

• An insurer who uses an alias on file with the Department is required to include their actual licensed name on EOBs and advertisements. Insurers may not include multiple insurers' names unrelated to the insured's coverage, as this practice misleads insureds of the actual underwriting insurer.

• All consumer-facing documents, including claim notices, statements, and advertisements, must clearly state the full licensed name of the underwriting insurer.

• Insurers are also required to include current contact information for the insurer and the Department as required by § 31A-22-629, R590-192-7, R590-203-4, and R590-261-5.

• Insurers' EOBs are required to describe how to initiate an appeal or independent review and shall conspicuously disclose the insurer's current contact information before the Department's current contact information.

The Utah Insurance Department indicates that it will conduct an examination of insurers' EOBs and advertisements after March 1, 2027.

Washington

Advisory T-2026-01, dated October 12, 2026, sets forth and “reaffirms guidance the agency issued in 2015 addressing the practice of price optimization. That guidance noted that to the extent price optimization results in premiums, rates, or rating factors unrelated to cost and risk, it is unfairly discriminatory under Washington State law governing permissible rates.” The Advisory describes price optimization and further states: “Charging different premiums to insureds based on their expected price sensitivity does not reflect a genuine difference in expected cost incurred by the insurer based on increase risk for these insureds. This practice is considered by the Insurance Commissioner to be unfairly discriminatory and in violation of Washington State law. Rates that are unlawfully discriminatory will not be approved.”

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Kathy Donovan is Senior Compliance Counsel, Insurance with Wolters Kluwer Financial Services. Kathy has more than two decades of experience in insurance compliance. Her expert commentary on legal and regulatory issues affecting the insurance industry is widely published, and she is a regular presenter at various industry events.