In conjunction with the Locke Lord COVID-19 task force, we are reviewing, analyzing, and compiling regulatory updates to provide clients easy access to information during this unprecedented time.  If you have any questions on the subject matter below, do not hesitate to reach out.  The information below relates to state and federal bulletins, emergency orders, pending/enacted legislation, and other related actions taken in response to the COVID-19 pandemic.

All Lines of Insurance

Iowa:  On May 29, the Commissioner has published Bulletin 20-17, which extended the authorization to obtain a temporary license until June 30, 2020 for those individuals who are unable to take the insurance producer licensing test. This extends the time period of the original Bulletin 20-07, published April 9th, 2020, which first authorized temporary licenses through June 1, 2020.

Puerto Rico:  On May 28, the Commissioner of Insurance issued Circular Letter 2020-1968-D advising on the new extension of the effective dates for the different classes of licenses to participate in the insurance business.

Property and Casualty Insurance

Michigan:  On May 28, the Michigan Department of Insurance and Financial Services issued Order Number 2020-10-M, requiring auto insurers authorized to write automobile insurance in Michigan, who have not submitted a filing under Bulletin 2020-18-INS for premium waivers or refunds, and who have yet to implement such waivers or refunds, to provide a plan or an explanation to the Department by June 10, 2020. Additionally, those insurers that advertised or implemented waivers or refunds but have not submitted a filing must do so by June 3, 2020.

Health Insurance

New Jersey:  On May 28, the Commissioner released Bulletin 20-27 to companies authorized to sell accident and health insurance, and applies to products not previously addressed in Bulletin Nos. 20-11, 20-12, 20-13, or 20-14. Bulletin 20-07 directs these carriers to extend an emergency grace period for the payment of premiums, in recognition of the disturbance caused by COVID-19.