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

Delaware:  On June 25, the Delaware Department of Insurance issued updated Domestic and Foreign Insurers Bulletin No. 117 (Producers and Adjusters Bulletin No. 33), providing guidance for insurers to comply with regulatory requirements during the COVID-19 crisis. The updated Bulletin covers topics such as relaxation of requirements for in-person appraisals/inspections; on-site examinations; administrative hearings and requests for arbitration; and temporary licenses.

Property and Casualty Insurance

California:  On June 25, the California Department of Insurance (“CDI”), issued Bulletin 2020-8 to extend the directives and reporting requirements set forth in Bulletins 2020-3 and 2020-4 to include premium relief for the month of June commensurate with any reduced exposure to risk.  Further, the Bulletin also extends the directives and reporting requirements set forth in Bulletins 2020-3 and 2020-4 to include premium relief for any months subsequent to June as conditions warrant.  Information regarding premium relief provided to policyholders for the month of June, and information regarding any premium relief provided to policyholders for the months of July and August as conditions warrant, shall be submitted to the Department no later than October 1, 2020.  Insurers shall continue to provide premium relief information to the Department on a quarterly basis for any future months in which a premium adjustment is provided.  If conditions warrant that any premium relief is to be provided for the months of September, October, or November, that information shall be submitted to the Department no later than January 1, 2021.  The extension of reporting required by Bulletin 2020-8 does not change the previous deadline for insurers to provide direct relief to policyholders for March, April, and May premiums by no later than August 11, 2020.

Health Insurance

Mississippi:  On June 25, the Mississippi Insurance Department released Bulletin 2020-10, extending Bulletins 2020-1 and 2020-9 regarding the use of telemedicine during the COVID-19 crisis. Bulletin 2020-10 extends the provisions, including directing insurers to encourage their policyholders to use telemedicine and suspending certain limitations applicable to such services, through September 30, 2020.