As Troutman Pepper Locke recently reported, on September 2, 2026, the Texas Department of Insurance (TDI) issued Commissioner’s Bulletin # B-0007-26, addressed to all insurance companies and their agents and representatives, which stated TDI’s position that any use of price optimization in the ratemaking or pricing process is unfairly discriminatory and violates the Texas Insurance Code. Shortly thereafter, as Troutman also reported, on September 21, 2026, Michigan signed into law Senate Bill 1013, which amends the Michigan Insurance Code by adding Section 2027a to prohibit the use of price optimization in property and casualty insurance ratemaking. Unlike the Texas bulletin, which relied on existing ratemaking and anti-discrimination statutes, Michigan codified the prohibition as a standalone statutory provision.
Read More West Virginia and Washington Join Texas and Michigan in Targeting Price Optimization
John Emmanuel
John represents a broad spectrum of clients in the insurance industry, including insurance and reinsurance carriers, surplus lines insurers, captives, risk retention and purchasing groups, insurance agents, brokers, and third-party administrators. His clients value his significant industry experience and ability to deliver pragmatic advice on achieving business objectives and complying with complex regulations.
Missouri Eases Audit Burden for Small and Emerging Third-Party Administrators: Amendment to 20 CSR 200-9.800
I. The Amendment
On October 1, 2026, the Missouri Department of Commerce and Insurance (the Department) announced an amendment to a state administrative rule, 20 CSR 200-9.800 (the Rule), that “provides targeted regulatory relief for small and emerging third-party administrators (TPAs) operating in Missouri.” Effective September 30, the amended Rule “creates an exemption from mandatory independent audits by CPAs for qualifying small and newly established TPAs.” According to the Department, the amendment is intended to “significantly reduc[e] regulatory costs and administrative burden while fostering business growth across the state.”
Read More Missouri Eases Audit Burden for Small and Emerging Third-Party Administrators: Amendment to 20 CSR 200-9.800New Texas Rule Would Clarify That Insurers Cannot Deny Homeowners Coverage Based on Roof Age
On September 29, 2026, the Texas Department of Insurance (TDI) published a proposed amendment to 28 Tex. Admin. Code § 21.1006, which prohibits insurers from declining to write or renew residential property insurance based on the age of a property or its components. TDI characterizes the proposed amendments as clarifying rather than substantive, stating that they “do not change the rule’s meaning or application” but instead “further the goals of Government Code Chapter 465 by making the rule clearer, more concise, and more consistent.” The public comment period runs through November 9, 2026, and TDI will hold a public hearing on the proposal on November 3, 2026.
Read More New Texas Rule Would Clarify That Insurers Cannot Deny Homeowners Coverage Based on Roof AgeWhen Insurance Law Meets Consumer Finance: Navigating Embedded Insurance Products
In this episode of The Consumer Finance Podcast, host Chris Willis is joined by insurance regulatory and transactions partners Brian Casey and John Emmanuel to introduce Troutman Pepper Locke’s insurance regulatory practice and explore where insurance law and consumer finance regulation intersect.
Read More When Insurance Law Meets Consumer Finance: Navigating Embedded Insurance ProductsConnecticut Requires Insurers to Explain Personal Risk Premium Increases: Bulletin PC-94-26
On September 17, 2026, Connecticut Insurance Commissioner Joshua Hershman issued Bulletin PC-94-26 (the Bulletin), addressed to all companies licensed to write personal risk insurance in Connecticut, regarding new requirements for premium increase explanations under Public Act 26-69 (the Public Act). Effective January 1, 2027, the Public Act requires insurers to provide policyholders with a reasonable explanation for personal risk insurance premium increases upon request, and to include a prominent statement in premium billing notices informing insureds of their right to request such an explanation. The Bulletin prescribes the specific methods by which requests may be submitted, the content and formatting requirements for the prominent statement, and the timeline for insurer compliance.
Read More Connecticut Requires Insurers to Explain Personal Risk Premium Increases: Bulletin PC-94-26Texas Takes Aim at Price Optimization in Insurance Ratemaking
On September 2, 2026, the Texas Department of Insurance (TDI) issued Commissioner’s Bulletin # B-0007-26 (the Bulletin), addressed to all insurance companies and their agents and representatives, regarding the use of price optimization in ratemaking and pricing. The Bulletin defines price optimization, identifies the statutory provisions it implicates, and states TDI’s position that any use of price optimization in the ratemaking or pricing process is unfairly discriminatory and violates the Texas Insurance Code.
Read More Texas Takes Aim at Price Optimization in Insurance RatemakingNew Hampshire Scrutinizes Personal Lines Auto Cancellations
On August 12, 2026, New Hampshire Insurance Commissioner David J. Bettencourt issued Bulletin Docket No. INS 26-052-AB (the Bulletin), directed to all “personal lines automobile insurers” operating in the state. The Bulletin addresses the New Hamshire Insurance Department’s (the NHID) interpretation and enforcement of N.H. Rev. Stat. Ann. § 417-A:5 as it relates to policy termination notices issued following an insured’s failure to make a renewal premium payment by its due date.
Read More New Hampshire Scrutinizes Personal Lines Auto CancellationsMassachusetts Prohibits Insurer Restrictions on Public Adjuster Retention
On August 7, 2026, Governor Maura Healey signed into law Chapter 187 of the Acts of 2026 (the Act), formerly Senate Bill No. 785, titled “An Act Relative to Insurance Claims.” The new law, introduced by Senator Joan B. Lovely, amends two chapters of the Massachusetts General Laws, Chapter 175 and Chapter 176D, to prohibit insurers, including any non-admitted or surplus lines insurers, from including in a property and casualty policy any language that restricts an insured’s ability to hire a public insurance adjuster as a condition of recovery.
Read More Massachusetts Prohibits Insurer Restrictions on Public Adjuster RetentionPennsylvania Adds Cannabis Operations and AI Coverages to Its Export List
On August 1, 2026, the Pennsylvania Insurance Department (the Department) published an updated export list in the Pennsylvania Bulletin (the Export List). Under section 1604(2)(ii) of The Insurance Company Law of 1921 (40 P.S. § 991.1604(2)(ii)), the Insurance Commissioner declares the coverages on the Export List to be “generally unavailable…
Read More Pennsylvania Adds Cannabis Operations and AI Coverages to Its Export ListHawaii Insurance Division Reclassifies Pet Insurance as Property Insurance
On July 17, 2026, the State of Hawaii Department of Commerce and Consumer Affairs Insurance Division issued Memorandum 2026-5PC (the Memorandum) titled “Hawaii Pet Insurance” to “All Insurers Issuing Pet Insurance Products.” The Memorandum states that effective January 1, 2026, under Hawaii Act 79 (the Act), “pet insurance is now…
Read More Hawaii Insurance Division Reclassifies Pet Insurance as Property Insurance