COVID-19 Daily Insurance Regulatory Updates to Keep You Informed During the Lockdown (April 17th, 2020)
April 17, 2020

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

Arizona: On April 14, the Arizona Department of Insurance issued Regulatory Bulletin 2020-03 advising Arizona authorized insurers regarding compliance with regulatory requirements during the COVID-19 pandemic. The Bulletin reminds companies that they are still required to make all mandated electronic filings with the NAIC, as well as those that are not filed with the NAIC but filed with the Department. The Department is willing to allow insurers an additional 30 days to complete most filings (and 60 days for some). If an insurer needs an extension, they are asked to request a late filing extension. Additionally, the hard copy and notary requirements for filings have been temporarily waived. The Department will accept electronic fillings and signatures. The Department will not conduct any on-site examination work during the COVID-19 public health emergency.

D.C.: On April 15, Mayor Muriel Bowser issued Mayor’s Order 2020-063, extending the state of emergency and public health emergency through May 15, 2020. Among other things, the Order requires individuals living, working, and visiting D.C. to stay at their residence unless performing essential functions/business/travel, wear face masks, and continue social distancing at essential businesses.

Illinois: On April 16, Illinois released Company Bulletin #2020-10, which concerns Corporate Governance Annual Disclosure (“CGAD”) filing requirements. The Bulletin states that companies that cannot make the existing June 1 CGAD filing deadline will not be charged the late fee, so long as the filing is made by August 1. Insurers or insurance groups who can meet the deadline of June 1 are encouraged to file by that date. However, any delays in filing up to August 1 caused by the COVID-19 emergency do not require prior approval from the Director, though the filing should note that the delay was caused by the COVID-19 emergency.

Louisiana: Louisiana released Emergency Rule 44, which became effective on April 17. The Rule applies to insurance producer and adjuster licensees with an expiration date of April 30, 2020. Under the Rule, every insurance producer and adjuster license with a renewal date of April 30, 2020 is extended until May 12, 2020. Insurance producers and adjusters are directed to complete all continuing education requirements and submit a renewal application and payment on or before May 12, 2020.

Nebraska: On April 17, the Nebraska Department of Insurance issued a Notice to all Producers licensed to sell insurance in the state of Nebraska regarding remotely proctored exams available to candidates. Effective April 17, 2020, candidates have the option to take remotely-proctored exams called ProProctor. Candidates should visit if they are interested in learning more.

New Hampshire: On April 16, Commissioner Christopher Nicolopoulos issued Bulletin No. 20-26-AB to all Domestic and Foreign companies regarding compliance with financial regulation filing requirements and finance examinations during the COVID-19 pandemic. The Department is providing flexibility for its licensees by adjusting financial regulatory requirements due to the current state of emergency with the understanding that (1) the Department may request additional information to gather more details from companies and (2) insurance companies shall timely respond to said requests. At this time, companies are still required to make all required electronic filings with NAIC. The Department may allow insurers an additional 30 days, for specific filings, to complete financial filing requirements. However, the Department must receive an extension request from an insurance company and reserves the right to reject any company request based upon the financial condition and unique circumstances of that company.

North Carolina: On April 17, the North Carolina Department of Insurance, Agent Services Division issued a Notice regarding virtual testing options through its third-party vendor Pearson Vue. The Notice outlines the steps interested parties would need to take in order to obtain a temporary license virtually through Pearson Vue. If there are any questions or comments regarding testing, the Notice directs readers to contact the Agents Services Division at

Rhode Island: On April 17, the Rhode Island Insurance Division issued Insurance Bulletin Number 2020-6, allowing for the temporary licensing of insurance producers during the COVID-19 pandemic subject to certain stipulations.

South Dakota: On April 17, the South Dakota Department of Labor & Regulation issued Bulletin 20-03, providing for the issuance of temporary insurance producer licenses subject to certain stipulations.

Texas: On April 16th, the Texas Department of Insurance released modified financial filing charts, extending filing deadlines. According to the updated filing chart, companies may submit filings electronically until April 30, 2020 without compliance with the sworn statement, affidavit, and notarization requirements. Please see the financial filings chart to see the deadlines for various filings.

Utah: On April 16, Utah passed H.B. 3007, amending Utah Workers’ Compensation Act to allow for the presumption that first responders performing their duties during the pandemic and test positive or are diagnosed with COVID-19 acquired the virus during the course and scope of their work.

Wisconsin: On April 16, Wisconsin issued Emergency Order #28 extending the Safer at Home Emergency Order #12 until May 26, 2020. Additionally, the Order includes new safe business practices for essential businesses, including insurers and financial service businesses.

Property and Casualty Insurance

Kentucky: On April 15, the Kentucky Department of Insurance issued guidance to all insurers offering mine subsidence insurance in the state, reinsurers, insurance agents and administrators participating in the mine subsidence insurance funds operations, extending the deadline for insurers who have reinsurance agreements for mine subsidence to submit the premium for the first quarter from May 15, 2020 to August 15, 2020.

Visit our COVID-19 Resource Center often for up-to-date information to help you stay informed of the legal issues related to COVID-19.

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