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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
  • California’s Senate Bill 354 enacted the California Insurance Information and Privacy Protection Act (CIIPPA), replacing the original Insurance Information and Privacy Protection Act and becoming operative July 1, 2028.
  • The CIIPPA applies to insurance department licensees, surplus line insurers, reinsurers, and their third-party service providers, while excluding HIPAA-covered
… Read More California Enacts Sweeping New Insurance Privacy Law: What Insurers Need to Know About CIIPPA (SB 354)

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 Age

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 Products

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-94-26
  • The FCC has circulated a Report and Order (FCC-CIRC 2609-05) revising the Telephone Consumer Protection Act (TCPA) consent-revocation framework, with new rules set to take effect 30 days after Federal Register publication.
  • Under the revised rules, callers may treat a consumer’s revocation request
… Read More FCC Revises TCPA Revocation of Consent Rules That Were Set to Go Into Effect in January

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 Retention
  • The California Supreme Court unanimously held in Fox Paine & Company, LLC v. Twin City Fire Insurance Company that insureds may seek declaratory relief against excess insurers before underlying insurance is exhausted, provided the loss is reasonably likely to reach the excess layer.
  • An insured may also, under
… Read More California Supreme Court Allows Declaratory Relief and Bad Faith Claims to Proceed Against Excess Insurers Before Underlying Exhaustion

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 List

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