On October 10, 2025, the Illinois attorney general, on behalf of the Illinois insurance director, filed a complaint in the Circuit Court of Cook County, Chancery Division, Case No. 2025 CH 10454, against a large group of Illinois domestic property and casualty insurers (insurer), alleging that the insurer failed to comply with Illinois insurance laws by refusing to provide information about the homeowners policies the insurer has issued nationwide. A copy of the complaint is found here. In particular, the insurance director has asserted that the insurer’s refusal to provide the information on a nationwide basis in the context of a targeted financial examination violates the following insurance examination statutes (collectively, the examination laws): (a) Conduct of examinations; appointment of examiners (215 ILCS 5/132.4(b)); (b) Market conduct examinations (215 ILCS 5/132(d)); (c) Insurance Holding Company System Act – Examination of registered insurers (215 ILCS 5/131.21(1.5)); and Unfair Methods of Competition and Unfair and Deceptive Acts and Practices – Examinations and investigations (215 ILCS 5/425). The alleged violations arise under a targeted financial exam warrant issued to the insurer in November 2024 (warrant). The warrant references the insurance director’s statutory authority under the examination laws, as well as the insurance director’s general powers and enforcement authority. The court has scheduled a hearing for December 15, 2025. The insurance director is seeking declaratory relief from the court that would require the insurer to provide the nationwide information requested.
The insurance director describes the underlying issue to be investigated as follows:
State Farm is the largest homeowners insurer in the country, and its premiums have been rising rapidly in recent years. In 2024, its written homeowners premiums rose by over 16 percent nationwide, the largest yearly increase since 2002. In July 2025, it implemented a 27 percent rate increase on its millions of policyholders in Illinois. A complete understanding of the affordability crisis in homeowners insurance requires comprehensive data on the financial condition of State Farm, the market and nonfinancial practices of State Farm, and the enterprise risks faced by State Farm. In order to assess these aspects of State Farm’s business, the Director and the Department require complete data from State Farm at the zip-code level as to policies that it writes to insure homes across the country.
Complaint, Paragraph 6. Additionally, the complaint describes the insurer’s alleged noncompliance as follows:
The Director accordingly initiated an examination of State Farm to obtain those data in November 2024, but State Farm has spurned the examination, flouting its legal obligations under multiple provisions of the Illinois Insurance Code. Specifically, State Farm has (1) refused to produce data available in Illinois on the basis that those data reveal information about policies for homes located outside of Illinois and (2) objected to production of the data based on purported concerns that the Director will violate confidentiality protections found in the very Insurance Code that the Director herself administers.
Complaint, Paragraph 7.
The complaint seeks declaratory relief from the court that the examination laws should be interpreted to recognize the statutory authority of the insurance director to examine the insurer’s homeowners policies issued outside of Illinois. This case has the potential to test the scope and breadth of the examination laws.