The District of Columbia Department of Insurance, Securities and Banking recently issued Bulletin 10-1B-04 (the “Bulletin”) providing insurers with guidance regarding the implementation of the Religious Freedom and Civil Marriage Equality Amendment Act of 2009 (the “Act”), which allows same sex couples to marry in the District of Columbia. The Act requires insurance products covering the spouse of a primary insurance policyholder or an employee covered under a group policy to provide the same-sex spouse of an insured with the same coverage, rights and privileges that are granted to a policyholder’s spouse of the opposite sex.
