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?
Stephanie O’Neill Macro
Stephanie brings more than 25 years of experience in insurance regulatory and transactional matters, assisting clients with a broad spectrum of issues, including insurance company mergers and acquisitions; formation and licensing of insurance entities; holding company system act matters, including change of control, affiliate transactions, and enterprise risk reporting; own risk self-assessment (ORSA); and entry and withdrawal from markets.
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