I. The Amendment

On October 1, 2026, the Missouri Department of Commerce and Insurance (the Department) announced an amendment to a state administrative rule, 20 CSR 200-9.800 (the Rule), that “provides targeted regulatory relief for small and emerging third-party administrators (TPAs) operating in Missouri.” Effective September 30, the amended Rule “creates an exemption from mandatory independent audits by CPAs for qualifying small and newly established TPAs.” According to the Department, the amendment is intended to “significantly reduc[e] regulatory costs and administrative burden while fostering business growth across the state.”

Read More Missouri Eases Audit Burden for Small and Emerging Third-Party Administrators: Amendment to 20 CSR 200-9.800
  • California’s Senate Bill 354 enacted the California Insurance Information and Privacy Protection Act (CIIPPA), replacing the original Insurance Information and Privacy Protection Act and becoming operative July 1, 2028.
  • The CIIPPA applies to insurance department licensees, surplus line insurers, reinsurers, and their third-party service providers, while excluding HIPAA-covered
… Read More California Enacts Sweeping New Insurance Privacy Law: What Insurers Need to Know About CIIPPA (SB 354)

On September 28, 2026, the U.S. Senate passed, by unanimous consent, the Terrorism Risk Insurance Program Reauthorization Act of 2026 (S. 4395), which would extend the federal terrorism insurance backstop past its original expiration date of December 31, 2027, through 2034. The U.S. House of Representatives passed its own reauthorization…

Read More Senate Passes TRIA Reauthorization as House-Senate Differences Await Resolution

On September 29, 2026, the Texas Department of Insurance (TDI) published a proposed amendment to 28 Tex. Admin. Code § 21.1006, which prohibits insurers from declining to write or renew residential property insurance based on the age of a property or its components. TDI characterizes the proposed amendments as clarifying rather than substantive, stating that they “do not change the rule’s meaning or application” but instead “further the goals of Government Code Chapter 465 by making the rule clearer, more concise, and more consistent.” The public comment period runs through November 9, 2026, and TDI will hold a public hearing on the proposal on November 3, 2026.

Read More New Texas Rule Would Clarify That Insurers Cannot Deny Homeowners Coverage Based on Roof Age

On September 10, 2026, Senator Elizabeth Warren, ranking member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to the National Association of Insurance Commissioners (NAIC) that included an extensive list of questions targeted toward assessing state insurance regulators’ efforts to address risks arising from the growing ties between private investment firms and insurance companies. The stated goal of the letter was to obtain information to assess what actions both state and federal regulators must take to ensure that American families are protected. On September 24, 2026, the NAIC responded with a comprehensive 22-page letter defending the state-based regulatory framework and surveying the various efforts underway to strengthen oversight of complex investments and asset structures.

Read More Senator Warren Scrutinizes NAIC Oversight of Private Equity and Credit in Insurance — and the NAIC Responds

On September 21, 2026, Michigan signed into law Senate Bill 1013 (the Bill), which amends the Michigan Insurance Code by adding Section 2027a to prohibit the use of price optimization in property and casualty insurance ratemaking. The Bill took immediate effect upon signing.

Read More Michigan Enacts Statutory Prohibition on Price Optimization: Senate Bill 1013

In this episode of The Consumer Finance Podcast, host Chris Willis is joined by insurance regulatory and transactions partners Brian Casey and John Emmanuel to introduce Troutman Pepper Locke’s insurance regulatory practice and explore where insurance law and consumer finance regulation intersect.

Read More When Insurance Law Meets Consumer Finance: Navigating Embedded Insurance Products

On September 17, 2026, Connecticut Insurance Commissioner Joshua Hershman issued Bulletin PC-94-26 (the Bulletin), addressed to all companies licensed to write personal risk insurance in Connecticut, regarding new requirements for premium increase explanations under Public Act 26-69 (the Public Act). Effective January 1, 2027, the Public Act requires insurers to provide policyholders with a reasonable explanation for personal risk insurance premium increases upon request, and to include a prominent statement in premium billing notices informing insureds of their right to request such an explanation. The Bulletin prescribes the specific methods by which requests may be submitted, the content and formatting requirements for the prominent statement, and the timeline for insurer compliance.

Read More Connecticut Requires Insurers to Explain Personal Risk Premium Increases: Bulletin PC-94-26
  • The FCC has circulated a Report and Order (FCC-CIRC 2609-05) revising the Telephone Consumer Protection Act (TCPA) consent-revocation framework, with new rules set to take effect 30 days after Federal Register publication.
  • Under the revised rules, callers may treat a consumer’s revocation request
… Read More FCC Revises TCPA Revocation of Consent Rules That Were Set to Go Into Effect in January