Regulatory Updates

Effective April 29, 2025, Pennsylvania is removing the resident license requirement of needing pre-license education credits. Pennsylvania is also adding Ethics and Flood requirements for renewal.  For each license, at least 3 of the 24 required CE hours must be about ethics. - If you're licensed before 4/29/2025, you must complete the ethics requirement by 4/29/2026 or by the end of your current license period (whichever is later). - If you're licensed on or after 4/29/2025, you must complete the ethics requirement by the end of your first license period. For property and casualty licensees, at least 2 of the 24 CE hours must be about flood insurance. - If you're licensed before 4/29/2025, you must complete the flood insurance requirement by 4/29/2026 or by the end of your current license period (whichever is later). - If you're licensed on or after 4/29/2025, you must complete the flood insurance requirement by the end of your first license period.

Effective January 1, 2025, Colorado Department adopts setting necessary disclosure requirements for surplus lines insurance contracts around non-admitted insurers. Please see the attachment for more information. 

Effective January 1, 2025, Alabama will now require a nonresident surplus line broker to have on file a bond for $50,000 to remain in good standing for the duration of their license. Please see the attachment for more information. 

Posted November 4, 2024, North Carolina sent out an advisory memorandum reminding producers/agents that using the “NPN override” feature available on platforms violates North Carolina insurance laws and is not permitted. NPN Override is the practice that allows agents to submit applications under appointed agents' NPNs. Some insurance agencies assign certain agents to handle the necessary paperwork with Marketplace insurers. At the same time, these agencies employ other agents who are not officially appointed with the Marketplace insurers. These unappointed agents help customers apply for Marketplace plans or request changes by using the appointed agents' National Producer Numbers (NPNs). Please see the attachment for more information.

Posted November 7, 2024, Oklahoma sent out a notice about the upcoming 2024 appointment renewal process. The notice informs carriers that all appointment renewals must be done electronically. Either via: - The Uniform Certificate of Authority Application (UCAA) - Only for those specific categories listed on the form - NIPR - The notice also lists key dates for renewal, invoices will be available for payment from November 25, 2024 – January 2, 2025. The termination deadline is November 15, 2024. Please see the attachment for more information. Update: Posted November 14, 2024, The invoice payment date will be available for payment from November 25, 2024 – December 31, 2024.

Posted on November 5, 2024, FINRA posted a notice providing the due dates for:  - Annual Report - Financial and Operational Combined Uniform Single (FOCUS) - Form Custody - Supplemental FOCUS Report Filings are due in 2025 or the first quarter of 2026. FINRA reminds members that all filings they submit to FINRA must be made electronically through FINRA Gateway. Please see the link below for those dates - [Notice-110524](https://www.finra.org/rules-guidance/notices/information-notice-110524)

Posted October 31, 2024, FINRA communicated information about renewal fees of broker-dealer (BD) and investment adviser (IA) firms - **Preliminary Statements**: Starting November 11, 2024, FINRA will post preliminary statements for BD and IA firms in [E-Bill](https://ebill.finra.org/ebill-web). These statements show any renewal fees for BD and IA registrations through the CRD and IARD programs. - **Final Statement**: A final statement will be posted on January 2, 2025, to confirm and reconcile the actual renewal fees for BD and IA firms, branches, and individuals. For more information, please use the following link - [FINRA Notice](https://www.finra.org/rules-guidance/notices/24-14?utm_source=MM&utm_medium=email&utm_campaign=O%5FWeekly%5FUpdate%5F110624%5FFINAL)

Posted November 5, 2024, Ohio is seeking public comment on proposed amendments around procedures and requirements for the licensing and appointment of insurance agents in Ohio. These amendments also identify lines of authority eligibility for limited lines licenses. Comments are due on or before November 20, 2024. Please see the attachment for more information. To comment on one of these rules please visit  or send an email to [ecomment@insurance.ohio.gov](mailto:ecomment@insurance.ohio.gov). For questions regarding these rules please call 614-644-2640.

Posted November 4, 2024, The North American Securities Administrators Association (NASAA) is seeking public comment on proposed amendments to the NASAA model rule on Dishonest or Unethical Business Practices Of Broker-Dealers And Agents. Comments are due on or before December 19, 2024. Please see the attachment for the proposed amendments.  NASAA is only accepting comments by email. Please email your comments to the NASAA Comments inbox (nasaacomments@nasaa.org), cc: Amy Kopleton (KopletonA@dca.njoag.gov), and Jim Nix ([jnix@ilsos.gov](mailto:jnix@ilsos.gov)).

Effective January 1, 2025, Idaho has new expectations for reporting requirements of Pharmacy Benefit Managers (PBMs), including health insurers who perform the activities of a PBM.  - PBMs are required to report to the Idaho Department of Insurance on January 1, 2025, and then annually. - The difference in the amount paid to each pharmacy and the amount charged to health plans, aggregated by each pharmacy. - Transparently disclose why a drug was moved to a tier that results in higher costs to a consumer or lower reimbursement to a pharmacy. - A PBM that owns, controls, or is affiliated with a pharmacy must report differences paid between affiliated and nonaffiliated pharmacies. - PBMs are required to submit quarterly reports to the Department of Insurance on appeals and denial outcomes including reasons for each denial, for each specific drug for which an appeal was submitted. All required reporting should be sent via email to pbm@doi.idaho.gov. Failure to submit timely reporting may result in administrative action. Please see the attachment for more information.