I. The Amendment

On October 1, 2026, the Missouri Department of Commerce and Insurance (the Department) announced an amendment to a state administrative rule, 20 CSR 200-9.800 (the Rule), that “provides targeted regulatory relief for small and emerging third-party administrators (TPAs) operating in Missouri.” Effective September 30, the amended Rule “creates an exemption from mandatory independent audits by CPAs for qualifying small and newly established TPAs.” According to the Department, the amendment is intended to “significantly reduc[e] regulatory costs and administrative burden while fostering business growth across the state.”

Read More Missouri Eases Audit Burden for Small and Emerging Third-Party Administrators: Amendment to 20 CSR 200-9.800

On September 10, 2026, Senator Elizabeth Warren, ranking member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to the National Association of Insurance Commissioners (NAIC) that included an extensive list of questions targeted toward assessing state insurance regulators’ efforts to address risks arising from the growing ties between private investment firms and insurance companies. The stated goal of the letter was to obtain information to assess what actions both state and federal regulators must take to ensure that American families are protected. On September 24, 2026, the NAIC responded with a comprehensive 22-page letter defending the state-based regulatory framework and surveying the various efforts underway to strengthen oversight of complex investments and asset structures.

Read More Senator Warren Scrutinizes NAIC Oversight of Private Equity and Credit in Insurance — and the NAIC Responds

On September 21, 2026, Michigan signed into law Senate Bill 1013 (the Bill), which amends the Michigan Insurance Code by adding Section 2027a to prohibit the use of price optimization in property and casualty insurance ratemaking. The Bill took immediate effect upon signing.

Read More Michigan Enacts Statutory Prohibition on Price Optimization: Senate Bill 1013

NEW YORK – Yuliya Feldman has joined Troutman Pepper Locke as a partner in the firm’s Insurance Transactional and Regulatory Practice Group in New York. She brings deep experience in strategic transactions, regulatory compliance, and reinsurance to one of the nation’s most recognized insurance practices.

Read More Troutman Pepper Locke Continues Insurance Transactional and Regulatory Practice Growth With Addition of New York Partner Yuliya Feldman

On September 2, 2026, the Texas Department of Insurance (TDI) issued Commissioner’s Bulletin # B-0007-26 (the Bulletin), addressed to all insurance companies and their agents and representatives, regarding the use of price optimization in ratemaking and pricing. The Bulletin defines price optimization, identifies the statutory provisions it implicates, and states TDI’s position that any use of price optimization in the ratemaking or pricing process is unfairly discriminatory and violates the Texas Insurance Code.  

Read More Texas Takes Aim at Price Optimization in Insurance Ratemaking

CHICAGO – Baird Allis, former vice president and associate general counsel at Kemper Corporation, has rejoined Troutman Pepper Locke as a partner in the firm’s Insurance Transactional and Regulatory Practice Group in Chicago.

Read More Former Kemper Vice President and Associate General Counsel Baird Allis Rejoins Troutman Pepper Locke as Partner in Insurance Transactional and Regulatory Practice

On August 12, 2026, New Hampshire Insurance Commissioner David J. Bettencourt issued Bulletin Docket No. INS 26-052-AB (the Bulletin), directed to all “personal lines automobile insurers” operating in the state. The Bulletin addresses the New Hamshire Insurance Department’s (the NHID) interpretation and enforcement of N.H. Rev. Stat. Ann. § 417-A:5 as it relates to policy termination notices issued following an insured’s failure to make a renewal premium payment by its due date.

Read More New Hampshire Scrutinizes Personal Lines Auto Cancellations

On July 16, 2026, the U.S. Securities and Exchange Commission (SEC) proposed Regulation E-Delivery, a new rule that would expand the ability of issuers, broker-dealers, investment advisers, and others to use electronic delivery to satisfy information delivery requirements under the federal securities laws. The proposal would establish requirements and conditions under which required regulatory information could be delivered electronically without first obtaining the recipient’s affirmative consent, superseding the SEC’s decades-old, guidance-based e-delivery framework while preserving investors’ ability to receive paper delivery upon request.

Read More FUNDamental QuickStudy: SEC Proposes New E-Delivery Approach to Modernize Delivery of Regulatory Information

Please join us on our next InsurTech Legal Academy webinar for key topics addressing what InsurTechs need to know about U.S. payment laws in the everchanging payment systems environment. This webinar will include an overview of federal and state laws governing payment systems and insurance-related transactions – including real-time payment rails, Regulation E, Regulation Z, Nacha, OFAC, anti-money laundering, insurance premium trust accounts, insurance premium financing, credit/debit card convenience fees or surcharges, and state money transmitter licensing requirements. Speakers will include members of Troutman Pepper Locke’s consumer finance and insurance regulatory teams.

Read More Join Us for Our Next InsurTech Legal Academy Webinar: Regulation of Payments for InsurTechs