Illinois Developments

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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?

On August 1, 2025, Governor JB Pritzker approved Senate Bill No. 1289, amending the definition of “home state” as it relates to more than one unaffiliated insured from a group and named as insureds on a single surplus lines insurance contract. Prior to the enactment of the bill, if…

Read More Illinois Amends the Definition of “Home State” for Unaffiliated Groups Under Its Surplus Lines Laws

On October 13, 2022, the Illinois Department of Insurance (the “Department”) issued Company Bulletin 2022-16 (the “Bulletin”).  The Bulletin is addressed to all domestic insurers and advises that the Department will now participate in the National Association of Insurance Commissioners Climate Risk Disclosure Survey (the “Survey”).
Read More Illinois to Participate in the Climate Risk Disclosure Survey

Locke Lord’s Privacy & Cybersecurity Newsletter provides topical snapshots of recent developments in the fast-changing world of privacy, data protection, and cyber risk management. For further information on any of the subjects covered in the newsletter, please contact one of the members of our privacy and cybersecurity team.
Read More Privacy & Cybersecurity Newsletter – July 2022

The Illinois House of Representatives has passed a new bill, HB 5534, entitled the Insurance ‎Business Transfer Act (the “IL IBT Act”), to address the current significant limitations that are in ‎place concerning the sale and transfer of blocks of insurance.‎…
Read More Illinois House of Representatives Passes Insurance Business Transfer Act

Illinois has passed Senate Bill 2176 which is effective as of June 25,2021, repeals the state’s former non-UETA “Electronic Commerce Security Act”, and includes the Uniform Electronic Transactions Act (UETA), making Illinois the 49th state to have adopted UETA and leaving New York as the only non-UETA state.
Read More Illinois Passes Uniform Electronic Transactions Act

In an effort to help struggling businesses deal with the fall-out from the COVID-19 pandemic, ‎legislatures in Florida, Illinois, Maine and Rhode Island have recently proposed legislation to ‎require insurance carriers to cover COVID-19 related business interruption claims. Traditionally, ‎business interruption policies require that a business suffer some sort of physical loss or damage ‎before the carrier will pay-out on a business interruption claim.‎…
Read More Various States Seek to Mandate Insurers Cover COVID-19 Related Business Interruption Claims

On February 26, 2021, a bill was introduced in the Illinois General Assembly that among other ‎changes would eliminate the diligent effort requirement for commercial business sourced by a ‎surplus lines producer through a retail insurance producer and would also reduce the requirement ‎for master policies and program business.‎…
Read More LL Surplus Lines Series (Entry 29): Illinois Looks to be Latest State to Streamline Diligent Search Requirements, and to Provide Clarity for Group Policies

The Illinois Department of Insurance has adopted a new rule, 50 Ill. Adm. Code 1305, Prior Notification of Dividends or Distributions.  Illinois Public Act 100-1118, effective November 27, 2018, added a new section to Article VIIC of the Illinois Insurance Code, Domestic Insurance Companies, namely, section 123C-26 [215 ILCS 5/123C-26] which mandates that captive insurance companies shall notify the Director when issuing dividends or distributions to policyholders [215 ILCS 5/123C-26.A] and which mandates that the Director approve that issuance and adopt rules to implement the approval process [215 ILCS 5/123C26.B].
Read More Illinois Department of Insurance Adopts Rule Mandating Prior Notification of Dividends or Distributions by Captive Insurance Companies

The Illinois Department of Insurance has adopted a new rule, 50 Ill. Adm. Code 630, Corporate Governance Annual Disclosure, effective May 29, 2020.  The new rule will require corporate governance reporting for insurers and provides for the confidential treatment of this information.
Read More Illinois Department of Insurance Adopts Rule to Require Corporate Governance Reporting for Insurers