Starting June 1, 2020, the Illinois Department of Insurance (the “Department”) will require insurers to submit their corporate governance practices on an annual basis, according to Company Bulletin 2020-01 Corporate Governance Annual Disclosure (CGAD) Filing ( the “Bulletin”) released on February 7th, 2020.

Article VIII 1/3 of the Illinois Insurance Code (215 ILCS 5/Article VIII.33) will require insurers or insurance groups to provide the Department with a summary of the insurer’s corporate governance structure, policies and practices, in order to permit the Department to understand the framework of the insurer’s corporate governance structure. This requirement will apply to insurers, which the Bulletin defines as “an insurance or surety company and shall be deemed to include a corporation, company, partnership, ‎association, society, order, individual or aggregation of individuals engaging in or proposing or ‎attempting to engage in any kind of insurance or surety business, including the exchanging of reciprocal ‎or inter-insurance contracts between individuals, partnerships and corporations, except that it does not ‎include agencies, authorities, or instrumentalities of the United States, its possessions and territories, the ‎Commonwealth of Puerto Rico, the District of Columbia, or a state or political subdivision of a state.” Importantly, this definition of insurer does not include HMOs not licensed as insurers, farm mutuals, group workers’ compensation pools, and religious and charitable risk pooling trusts.

According to the Bulletin, the associated regulation is currently in process and will include specific filing directions. The Department has also released a CGAD template, located here, which insurers may use to draft their CGAD submissions- although insurers may opt to use an alternative reporting method, as long as all information required under VIII.33 is included.