Regulatory Updates

Effective January 6, 2025, NASAA rolled out updates to the Electronic Filing Depository (EFD) system. The updates to EFD include:  - Migration to the commercial cloud - [New system URL](https://nasaaefd.org/) - New system support Please use the link as follows for more information. [NASAA Headlines](https://www.nasaa.org/74333/nasaa-updates-efd-guidance-dec-31-2024/?qoid=current-headlines)

Effective January 1, 2025, through June 29, 2025, Oregon issued temporary rules for pharmacy benefit managers (PBMs). The changes made are as follows:  - Changing that PBM's need to  register with the Department of Consumer and Business Services (DCBS) to now being a licensure requirement - Language needs to be updated from "registration" to "licensure" language - Expanded transparency requirements on PBMs, and new language is needed to reflect the addition of new data elements. - Language around PBM rules to provide additional clarity on existing requirements related to “maximum allowable cost” (MAC) lists, and adding new language reflecting market conduct requirements for PBMs The  Rulemaking Advisory Committee's (RAC), reasoning for the temporary rule is that the language contained in this temporary filling is almost identical to the final rules. The committee plans to have the final effective wording before June 29, 2025. Please see the attachment for more information.

Effective January 10, 2025, Nebraska will update the retaliatory fees list for initial appointments for the following states: - Connecticut - Old Fee: $10 New Fee: $20  - Georgia - Old Fee: $14 New Fee: $20  - Guam - Old Fee: $0 New Fee: $25  - North Carolina - Old Fee: $10 New Fee: $11  - Vermont - Old Fee: $30 New Fee: $80 - Virginia - Old Fee: $10 New Fee: $8 

Posted January 7, 2025, Alaska hosted a public hearing to solicit public testimony regarding the types of insurance for which insureds generally cannot secure coverage from admitted insurers. In doing so, the director issued an order that updated the surplus lines placement list. The results from that public hearing were posted. The Surplus Lines List will be amended, adding the following: - Hotels/Motels - pre-1990 - Non-owned and Hired Trailer 100k or more coverage.  Please see the attachment for the full list. 

Effective February 14, 2025, Utah will add a Non-Uniform Question (NUQ) for the Resident Licensing application for individuals. 

Effective April 1, 2025, New Mexico is clarifying the language regarding Producer, Adjuster, and other license classes for resident and nonresident, for individuals and business entity licenses. - Resident and nonresident Pharmacy Benefit Managers business entities will need to designate a Designated responsible licensed producers (DRLPs) - Resident and nonresident Staff adjusters must be terminated within 30 calendar days and no longer within 10 calendar days. Nonresident New Mexico updated language involving requirements of getting a license as a nonresident agent or broker if convicted of a felony involving dishonesty or breach of trust if that person has written consent from the Superintendent.  The individual must - Have the written consent of the home state;  - And provide acceptable verification to the Superintendent by an OSI-prescribed method. Resident The requirement for when a license needs to be reinstated has been updated to remove the option to retake the qualifying examination. A licensee must complete all required CE before submitting an application. For a resident adjuster license, if the applicant is a citizen of a foreign country, then the application must include proof the applicant is eligible to reside and work in the U.S.  Resident adjuster licensing made a change that each public adjuster must obtain separate proof of financial responsibility and may not rely on the bond of any other adjuster.

Effective January 3, 2025, New York will turn off the ability to renew business entities electronically. New York is making an update on the renewal window from 180 days before the license expiration date to 120 days before the license expiration date. Update January 23, 2025, New York business electronic renewal applications have been turned back on. The renewal will be available 120 days before the license expiration date.

Posted January 2, 2025, FINRA posted a reminder 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. The deadline to remit payment for any additional amounts owed and to report any discrepancies to FINRA is January 24, 2025. For more information, please use the following link - [FINRA Notice](https://www.finra.org/rules-guidance/notices/25-01)

Effective January 1, 2025, South Carolina requires the director or his designee to examine the conduct and business practices of pharmacy benefits managers (PBMs) and pharmacy services administrative organizations (PSAOs).  As often as the director deems appropriate, but not less than once every five years, the director may examine or audit the books and records of a PBM / PSAO providing claims processing services or other prescription drug or device services for a health benefit plan in compliance with this act. Please see the attachment for more information.

Effective January 1, 2025, New Jersey posted a bulletin guiding: carriers, pharmacy benefits managers (“PBMs”), and pharmacy services administrative organizations (“PSAOs”) concerning licensing requirements. Please see the attachment for more information.