Due to the volume of state insurance regulatory activity during the COVID-19 outbreak, the first section of this Legal Update now includes a topical overview that summarizes the major categories of actions taken by each state (e.g., all states that have taken action regarding recommended or mandated property/casualty premium refunds), with hyperlinks to the fuller descriptions of each of those actions in the detailed chart that follows.

Since March of this year, there has been significant state insurance regulatory activity related to the novel coronavirus (“COVID-19”) pandemic. State insurance regulatory authorities have issued emergency rules and regulations, notices and bulletins, containing both directives and guidance, as well as requesting information related to the COVID-19 outbreak. These regulatory actions vary from state to state, for example:

  • Some relate only to specific lines of insurance - such as health insurance, travel insurance and commercial property/casualty insurance - while some are broadly directed at all regulated insurance entities. 
  • Some require an affirmative response to a state insurance regulator before a specified date, while others simply provide guidance or clarify the insurance department’s position on issues related to the COVID-19 outbreak. 

This Legal Update provides a chart that summarizes the regulatory actions of US insurance regulatory authorities with respect to the COVID-19 outbreak, noting items that have been added since our last Update. In recent weeks it appears that US insurance regulatory authorities have been increasingly “moving on” from the COVID-19 outbreak and have been extending preexisting guidance but otherwise beginning to resume business as usual. This chart will continue to provide updates on any further actions from US insurance regulatory authorities, including whether there are any suspensions or terminations of existing COVID-19 guidance.

Any questions or comments with respect to the information contained in this survey should be directed to Kara Baysinger at kbaysinger@mayerbrown.com or (415) 874-4256, Stephanie Duchene at sduchene@mayerbrown.com or (213) 229-5176, Matthew Gaul at mgaul@mayerbrown.com or (212) 506-2237, Larry Hamilton at lhamilton@mayerbrown.com or (312) 701-7055, Sanjiv Tata at stata@mayerbrown.com or (212) 506-2205 or Philip Goldstein at pgoldstein@mayerbrown.com or (212) 506-2693.

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