- President: Virginia Insurance Commissioner Scott A. White.
Paige Waters
Paige brings extensive experience in insurance and reinsurance law, handling transactional, regulatory, and insolvency matters for national and international clients.
Can Illinois Insurance Regulators Request Nationwide Homeowners Policy Information Under Examination Laws?
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.Read More Can Illinois Insurance Regulators Request Nationwide Homeowners Policy Information Under Examination Laws?
Colorado Division of Insurance Expands AI Governance and Framework Regulation to Private Passenger Auto and Health Benefit Plan Insurers
On August 20, 2025, the Colorado Division of Insurance (Division) amended Regulation 10-1-1 to expand its existing limited applicability to insurers offering individual life insurance to apply to insurers offering private passenger auto and health benefit plans effective October 15, 2025. Evidence of compliance with the amended regulation must be made available to the Division upon request for private passenger auto and health benefit plan insurers beginning on July 1, 2026.Read More Colorado Division of Insurance Expands AI Governance and Framework Regulation to Private Passenger Auto and Health Benefit Plan Insurers
Red Teaming Is an Effective Tool for Insurer Assessment of AI Risks
The insurance industry is facing increased scrutiny from insurance regulators related to its use of artificial intelligence (AI). Red teaming can be leveraged to address some of the risks associated with an insurer’s use of AI. The U.S. Department of Commerce’s National Institute of Standards and Technology (NIST) defines a “red team”[1] as:Read More Red Teaming Is an Effective Tool for Insurer Assessment of AI Risks
Pennsylvania Enacts New Digital Forgery Law
On July 7, 2025, Pennsylvania Governor Josh Shapiro enacted a new Digital Forgery Law by signing SB 649 into law, which will take effect in 60 days. SB 649 creates “new criminal penalties for anyone who uses artificial intelligence (AI) to produce non-consensual “forged digital likenesses” — like deepfakes or…
Read More Pennsylvania Enacts New Digital Forgery LawNAIC Responds to Proposed 10-Year Moratorium on State Regulation of AI in One Big Beautiful Bill Act
There is a proposed 10-year moratorium on the enforcement of state laws that regulate artificial intelligence (AI) contained in Section 43201(c) of H.R.1 – One Big Beautiful Bill Act. The National Association of Insurance Commissioners (NAIC) recently submitted its response to members of the U.S. Senate (attached at the link), raising various concerns that the moratorium will have unintended consequences, including:Read More NAIC Responds to Proposed 10-Year Moratorium on State Regulation of AI in One Big Beautiful Bill Act
Wisconsin Becomes the 24th State to Adopt the NAIC Model Bulletin on the Use of AIS in Insurance
On March 18, Wisconsin Insurance Commissioner Nathan Houdek issued Wisconsin’s new bulletin on the use of artificial intelligence systems (AIS) in insurance, becoming the 24th state to adopt the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers. A copy of the bulletin is found at this link.Read More Wisconsin Becomes the 24th State to Adopt the NAIC Model Bulletin on the Use of AIS in Insurance
NAIC Establishes the Risk-Based Capital Model Governance (EX) Task Force in 2025
The 2025 National Association of Insurance Commissioners (NAIC) President and North Dakota Insurance Commissioner Jon Godfread has stated that:
“As state insurance regulators and NAIC Members, our efforts are anchored by two core principles: maintaining fair, sound, and stable insurance markets, and protecting and educating consumers.”Read More NAIC Establishes the Risk-Based Capital Model Governance (EX) Task Force in 2025
New Jersey Adopts Bulletin on AI Use in Insurance
On February 11, New Jersey Banking and Insurance Commissioner Zimmerman issued Bulletin 25-03 regarding the use of artificial intelligence systems (AIS) in insurance, applicable to all insurers authorized or admitted in New Jersey. New Jersey becomes the 23rd state to adopt the bulletin based on the NAIC Model Act on the Use of AIS by Insurers.Read More New Jersey Adopts Bulletin on AI Use in Insurance
Delaware Insurance Commissioner Navarro Issues Bulletin No. 148 Re: Use of Artificial Intelligence Systems in Insurance
On February 5, Delaware joined 21 jurisdictions who adopted guidance similar to the NAIC Model Bulletin on the Use of Artificial Intelligence (AI) Systems by Insurers in 2024, and four additional jurisdictions have otherwise issued guidance or regulation.
In addition to other detailed guidance, Bulletin No. 148 also reiterates the…