On January 22, the U.S. House of Representatives passed on a bipartisan basis HR 7148, the Consolidated Appropriations Act, 2026 (HR 7148). If it also wins passage in the Senate, the bill would, among other Trump administration priorities, impose new rules and requirements for pharmacy benefit managers (PBMs) and pharmacy benefit administration more generally. As with prior federal legislative proposals, HR 7148 attempts to bring more transparency to the administration of pharmacy benefits for both fully insured and self-funded groups and would impose enhanced transparency requirements for PBMs contracting with Medicare Part D prescription drug plans PDP sponsors. Specifically, among other requirements, HR 7148 proposes the following new rules and regulations impacting PBM arrangements:Read More House Passes HR 7148, Advancing New PBM Transparency and Compensation Rules
Now Available: Surplus Lines Update Portal – Weekly Subscription
We’re pleased to announce the launch of our Weekly Surplus Lines Update Portal, a comprehensive subscription service designed to help surplus lines carriers and brokers stay ahead of regulatory developments across all 50 states and U.S. territories. Navigating the surplus lines marketplace requires constant vigilance, and this portal delivers…
Read More Now Available: Surplus Lines Update Portal – Weekly SubscriptionNinth Circuit Holds that Texts Are “Calls” Under the TCPA But Embedded Videos Are Not Recorded Messages
On January 13, the U.S. Court of Appeals for the Ninth Circuit issued a decision in Howard v. Republican National Committee (RNC) offering two important interpretations of the applicability of the Telephone Consumer Protection Act (TCPA) to certain text message communications:Read More Ninth Circuit Holds that Texts Are “Calls” Under the TCPA But Embedded Videos Are Not Recorded Messages
Financial Responsibilities in the Surplus Lines Market
In the fourth episode of our Surplus Lines 360 series, John Emmanuel and Zachary Lerner discuss why using surplus lines insurance to satisfy state financial responsibility requirements can be problematic and varies by state, and why newer rideshare laws provide clarity that traditional commercial auto insurance lacks.Read More Financial Responsibilities in the Surplus Lines Market
Texas Will Have a New Insurance Commissioner
Current Texas Insurance Commissioner Cassie Brown announced this week that she will be retiring on February 2. Brown has led the Texas Department of Insurance (TDI) for the past four years, and her tenure with TDI has spanned many more. Before serving as commissioner, Brown was the commissioner of TDI’s…
Read More Texas Will Have a New Insurance CommissionerUK, Bermuda and EU Markets: For US Business, Ditch Direct Procurement, Go Surplus Lines
This article was originally published on Insurance Business UK and is republished here with permission as it originally appeared on December 23, 2025.
It’s a tale as old as time: A U.S. insurance broker wants to place bespoke coverage for its U.S. client. Sometimes, it’s a layer within a commercial tower. Perhaps there are some participating admitted (licensed) U.S. carriers, mixed in with an array of eligible surplus lines insurers. But alas, satisfying all layers through the admitted and surplus lines markets proves allusive, so the broker approaches an unauthorized carrier in Bermuda, a European country, or another non-U.S. jurisdiction. It makes sense, right? The broker tried its best to find coverage another way, and it wants to do right by its client.Read More UK, Bermuda and EU Markets: For US Business, Ditch Direct Procurement, Go Surplus Lines
Demystifying Surplus Lines Group Insurance
In this episode, John Emmanuel and Zachary Lerner unpack one of the hottest regulatory topics in surplus lines: group insurance. Learn how affiliated and unaffiliated groups are treated under the NRRA, why “home state” determination drives compliance and tax obligations, and the state-by-state rules that can make or break a group structure.Read More Demystifying Surplus Lines Group Insurance
December 2025 Developments in the Insurance Industry
- President: Virginia Insurance Commissioner Scott A. White.
Understanding the Surplus Lines Broker’s Role: Key Responsibilities and Regulatory Insights
Join Troutman Pepper Locke Partners John Emmanuel and Zachary Lerner as they break down the critical role of surplus lines brokers in insurance transactions. Learn the distinctions between admitted and surplus lines markets, the unique responsibilities brokers shoulder, and the regulatory requirements that shape their relationships with agents. Gain practical insights into enforcement actions and the importance of careful delegation in surplus lines placements.Read More Understanding the Surplus Lines Broker’s Role: Key Responsibilities and Regulatory Insights
Connecticut Insurance Commissioner to Retire
Insurance Commissioner Andrew Mais will retire as of November 28, 2025. Mais was appointed as Connecticut insurance commissioner in February 2019. Governor Ned Lamont will formally nominate Josh Hershman to replace Mais in February when the Legislature is back in session. Hershman will serve as interim insurance commissioner beginning December…
Read More Connecticut Insurance Commissioner to Retire