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 2020, 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 a bi-weekly basis of any further actions from US insurance regulatory authorities, including whether there are any suspensions or terminations of existing COVID-19 guidance.

Legal Update - Download PDF

Visit us at mayerbrown.com

Mayer Brown is a global legal services provider comprising legal practices that are separate entities (the "Mayer Brown Practices"). The Mayer Brown Practices are: Mayer Brown LLP and Mayer Brown Europe – Brussels LLP, both limited liability partnerships established in Illinois USA; Mayer Brown International LLP, a limited liability partnership incorporated in England and Wales (authorized and regulated by the Solicitors Regulation Authority and registered in England and Wales number OC 303359); Mayer Brown, a SELAS established in France; Mayer Brown JSM, a Hong Kong partnership and its associated entities in Asia; and Tauil & Chequer Advogados, a Brazilian law partnership with which Mayer Brown is associated. "Mayer Brown" and the Mayer Brown logo are the trademarks of the Mayer Brown Practices in their respective jurisdictions.

© Copyright 2020. The Mayer Brown Practices. All rights reserved.

This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.