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 OptimizationRegulatory
When 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-94-26Congress Moves to Extend the Terrorism Risk Insurance Act Until 2034
On June 29, 2026, the House of Representatives passed H.R. 7128, “TRIA Program Reauthorization Act of 2026” (the Act). The Act concerns the Terrorism Risk Insurance Act of 2002 (TRIA), which was passed in the aftermath of the September 11, 2001, terrorist attacks. TRIA requires commercial property and casualty insurers…
Read More Congress Moves to Extend the Terrorism Risk Insurance Act Until 2034NAIC Signals Potential Tightening of Annuity Illustration Practices
By Paige Waters on
Regulatory Landscape
In 2026, the NAIC Life Insurance and Annuities (A) Committee, chaired by Iowa and vice chaired by Michigan, is largely focusing on annuity sales practices, including annuity buyers guides, suitability, and annuity illustrations. Of particular interest to the life and annuity industry is the formation of the Life Insurance and Annuities Illustrations (A) Working Group (Working Group) chaired by Minnesota. The Working Group’s current charge is to “evaluate concepts for improving life insurance and annuity illustrations and disclosures, and consider revisions to relevant NAIC models or develop other guidance where feasible and appropriate.” The Working Group has asked for input on how to ensure that indexed annuity illustrations give consumers reasonable expectations, after regulators observed materials suggesting annual returns of 10–25% for multiple years. The comment record — including responses from industry trades, actuarial bodies, consumer advocates, and vendors — strongly suggests that current practices around indexed annuity illustrations and disclosures will be revisited. The Working Group is considering short-term and long-term approaches designed to ensure consumers receive reasonable expectations for indexed annuity returns at the point of sale.
Read More NAIC Signals Potential Tightening of Annuity Illustration PracticesBill to Limit Classification of Insurers as ‘Systemically Important’ Receives Bipartisan Approval by the House
By William Barnard on
On February 9, 2026, the House of Representatives, in a bipartisan vote, approved H.R. 3682. This bill would place additional guardrails on the Financial Stability Oversight Council (FSOC) in designating insurance companies as systemically important financial institutions (SIFI). The FSOC was established in the aftermath of the 2008 financial crisis, to identify risks to financial stability, promote market discipline, and respond to emerging threats to financial stability. A key authority of the FSOC is its ability to designate nonbank financial institutions as SIFIs.
Read More Bill to Limit Classification of Insurers as ‘Systemically Important’ Receives Bipartisan Approval by the HouseJoin Us for Our Next InsurTech Legal Academy Webinar: Captive Insurance Companies for InsurTechs
By Brian Casey & Benjamin Sykes on
We are pleased to invite you to our next edition of the InsurTech Legal Academy to address the use of captive insurance and reinsurance companies by InsurTechs. We are pleased to have Brady Young, Chief Executive Officer, Strategic Risk Solutions, the world’s largest independent captive manager with offices in multiple countries, joining us on this panel discussion. Captive insurance financing is important yet involves complex issues and careful consideration of those.
We hope you can join us.
Read More Join Us for Our Next InsurTech Legal Academy Webinar: Captive Insurance Companies for InsurTechsHouse Passes HR 7148, Advancing New PBM Transparency and Compensation Rules
By Laura Ferguson, Denise Hanna & Grace Elliott on
Posted in Healthcare, Regulatory
On January 22, the U.S. House of Representatives passed on a bipartisan basis HR 7148, the Consolidated Appropriations Act, 2026 (HR 7148). If it also wins passage in the Senate, the bill would, among other Trump administration priorities, impose new rules and requirements for pharmacy benefit managers (PBMs) and pharmacy benefit administration more generally. As with prior federal legislative proposals, HR 7148 attempts to bring more transparency to the administration of pharmacy benefits for both fully insured and self-funded groups and would impose enhanced transparency requirements for PBMs contracting with Medicare Part D prescription drug plans PDP sponsors. Specifically, among other requirements, HR 7148 proposes the following new rules and regulations impacting PBM arrangements:
Read More House Passes HR 7148, Advancing New PBM Transparency and Compensation RulesTexas Will Have a New Insurance Commissioner
By Jon Gillum on
Current Texas Insurance Commissioner Cassie Brown announced this week that she will be retiring on February 2. Brown has led the Texas Department of Insurance (TDI) for the past four years, and her tenure with TDI has spanned many more. Before serving as commissioner, Brown was the commissioner of TDI’s…
Read More Texas Will Have a New Insurance CommissionerWhen Surplus Lines Brokers Are Off the Hook: Connecticut Department Issues Bulletin on New Diligent Effort Exception
By Matt Cossu & John Emmanuel on
On October 10, 2025, the Connecticut Department of Insurance (the Department) issued Bulletin SL-6 (the Bulletin) to restate the requirements generally applicable to surplus lines placements, and to advise that the diligent effort exception established by Public Act 25-87, effective October 1, 2025, only applies to surplus lines brokers when they procure insurance coverage through an unaffiliated wholesale broker. The Bulletin additionally supersedes and rescinds Connecticut Bulletins SL-3 and SL-5.
Read More When Surplus Lines Brokers Are Off the Hook: Connecticut Department Issues Bulletin on New Diligent Effort Exception