In conjunction with the Locke Lord COVID-19 task force, we are reviewing, analyzing, and compiling regulatory updates to provide clients easy access to information during this unprecedented time. If you have any questions on the subject matter below, do not hesitate to reach out. The information below relates to state and federal bulletins, emergency orders, pending/enacted legislation, and other related actions taken in response to the COVID-19 pandemic.
All Lines of Insurance
Nevada: Nevada proposed an amendment to Chapter 686A of Nevada Administrative Code, which would prohibit increasing insurance premiums or making adverse underwriting decisions based on adverse changes in consumer credit reports occurring between March 1, 2020 and two years after the cessation of the Declaration of Emergency for COVID-19.
New York: On August 6, the New York Department of Financial Services (“DFS”) issued Supplement 3 to Circular Letter 9 regarding Insurance Producer Licensing requirements during the COVID-19 pandemic.
West Virginia: According to APCIA, in a call with the West Virginia Offices of Insurance Commissioner (OIC) relating to Bulletin 20-12, the bulletin governing the use of credit-based insurance scoring, the OIC noted that insurers are required to provide an adverse action notice to consumers advising them that negative credit factors resulted in the charging of a higher premium and clarified that it is their expectation that consumers would have an opportunity to contact their insurer and ask for an exception to the consideration of those credit factors in light of COVID-19.