Jon Gillum

As senior counsel in the Austin office of Locke Lord LLP, Jon Gillum represents clients in matters concerning insurance regulation, service contract (extended warranty) regulation, the Texas Public Information Act, and Texas administrative law. He regularly assists clients in compliance matters, transactions, and disputes involving the Texas Department of Insurance (TDI), the Surplus Lines Stamping Office of Texas (SLSOT), the Texas Department of Licensing and Regulation (TDLR), the Texas Real Estate Commission (TREC), and the Texas Attorney General's Office (OAG).

Jon’s insurance regulatory experience includes advising clients on a variety of transactional, licensing, compliance, regulatory, rulemaking, and enforcement issues involving a wide range of provisions of the Texas Insurance Code and TDI’s rules, including filings under and compliance with the Texas Holding Company Act; captive insurance company formation; regulatory approvals for mergers, acquisitions, and other changes of control; and licensing issues on behalf of insurance companies, agents, and third-party administrators.

Jon’s service contract experience includes advising clients on variety of licensing and compliance matters including financial security and reserve requirements; contract form requirements; seller and administrator issues; and covered risk issues. He has particular experience in advising clients on complex regulatory classification issues involving new product development under laws governing residential service contracts (home warranties), service contracts (extended warranties), identity theft protection, vehicle protection products, insurance, and express warranties. 

Jon's administrative law experience also extends to the various stages and aspects of government disputes, including preliminary investigations, civil investigative demands, hearings, notices of alleged violation, warning letters, administrative appeals, contested cases, declaratory judgment actions, motions for rehearing, cease and desist orders, consent orders, temporary and permanent injunctions, civil penalties, open records issues under the Texas Public Information Act (PIA), and confidentiality issues.

• Advised insurance companies on various holding company act filing and compliance issues, including form filings, dividend approval, bylaw amendment, and divestiture of control
• Advised clients on regulatory and formation issues arising under Texas captive insurance statute and regulations
• Represented clients in pre-suit investigations and examinations by the Texas Department of Insurance, including investigations under Sections 38.001, 101.104, and 401 of the Texas Insurance Code
• Obtained regulatory approval for changes of control of insurance agencies, changes of control of third-party administrators, and mergers of insurance companies
• Advised insurance companies on multiple compliance matters including merger, reinsurance, change of control, statutory deposit, and policy form issues
• Represented surplus lines wholesalers in dispute with the Texas Department of Insurance involving filings with the Surplus Lines Stamping Office of Texas
• Represented electronic device company in regulatory matters with the Texas Department of Insurance involving loss-damage waiver and identity-theft issues
• Advised clients on numerous service contract regulatory issues involving the Texas Department of Insurance, the Texas Department of Licensing and Regulation, and the Texas Real Estate Commission
• Represented life insurance company in connection with unclaimed property issues in Texas
• Advised insurance company on Texas regulatory and examination issues involving international insurance transactions and scope of the McCarran-Ferguson Act
• Represented service contract company in connection with captive insurance reserve issues and related regulatory approvals
• Advised clients on Texas specialty insurance licenses, including credit insurance and portable electronic vendor licenses
• Represented premium finance company in licensing and application matters involving the Texas Department of Insurance
• Represented former board member in dispute over scope of insurance receivership injunction in Texas