Advocacy and Action – Regulatory Agencies

UP Congressional Testimony 9/22/22 to US House Committee on Financial Services, Subcommittee on Housing, Community Development and Insurance.  State of Emergency: Examining the Impact of Growing Wildfire Risk on the Insurance Market. 

PDF: 9/22/22 Testimony of United Policyholders Co-Founder and Executive Director Amy R. Bach 

YouTube: 9/22/22 Testimony of United Policyholders Co-Founder and Executive Director Amy R. Bach

• UP joins other stakeholders in request to update regs for lender acceptance of private flood policies

• UP signs on to letter urging rulemaking limiting forced arbitration in consumer contracts
• UP comments in support of CFPB’s proposed rule prohibiting arbitration in consumer contracts

• Making health insurer rate filings public under the Affordable Care Act

• Sign-on to letter by Consumer Federation of America re: protecting servicemembers from abusive credit practices

• Comments on new regulations for claims handling procedure for ERISA claims
• Comments opposing a proposed delayed implementation of the Fiduciary Rule

• United Policyholders has been informing and assisting flood victims on insurance matters for decades, including post-disaster in Louisiana, New York, New Jersey, Vermont, Colorado and California. With input from partner organizations and volunteers, we prepared and submitted the following comments to FEMA on their proposed reforms to the National Flood Insurance Program.  Special thanks to Lauren Pachman, Jeffrey Major and Katie Oliver. (May 31, 2024)
• UP requested an extension of the proof of loss deadline for 2016 Baton Rouge Louisiana flood victims (August 24, 2017)
• Freedom of Information Act Request regarding National Flood Insurance Program contracts and oversight of WYOs and IAs (February 23, 2015)
• Complaint against DHS FEMA filed in Washington D.C. Federal District Court seeking compliance with September 18, 2014 FOIA request
• Freedom of Information Act Request regarding National Flood Insurance Program Appeals Process (March 12, 2014)
• Freedom of Information Act Request regarding National Flood Insurance Program Appeals Process (September 18,2014)
• Letter seeking retroactive Proof of Loss deadline for 2013 Colorado flood victims

• UP comments to Federal Insurance Office on Insurance Sector and Climate-Related Financial Risks (Dec 2022)
• UP comments to Federal Insurance Office on Insurance Sector and Climate-Related Financial Risks (Nov 2021)
• FIO publishes important report on the most pressing issues impacting insurance consumers
• UP joins CFA and other consumer groups on further comments re: Monitoring Availability and Affordability of Auto Insurance
• UP joins CFA and other consumer groups on comments re: Automobile Insurance Affordability
• Study on Natural Catastrophes and Insurance
• Wildfire Risk and Insurance Markets UP 9-29-22 Meeting Presentation

• Coalition letter supporting the adoption of best interest standard (akin to the Department of Labor “fiduciary rule”) for investment advice 

• Affordable Homeowners Insurance Commission
• UP Comments: Affordable Homeowners Insurance Commission

• • UP Comments on REG-2023-00010, Catastrophe Modeling and Ratemaking (April, 2024)
  • UP Comments before the California Department of Insurance regarding REG-2019-00025, “Complete Property and Casualty Rate Regulation” (March, 2024).
  • New rules for disaster claims in CA, CO, and OR (NAIC/Consumer Liaison Committee Summer Meeting, Portland, OR Friday, 8/12/2022
  • Comments For July 13, 2023 Workshop Examining Catastrophe Modeling and Insurance, REG-2023-00010
  • UP Comments before the California Department of Insurance re: CA Fair Plan Investigatory Hearing (July 2022)
  • UP Testimony/Comments Before the California Department of Insurance re:
    Mitigation in Rating Plans and Wildfire Risk Models: REG-2020-00015, April 12, 2022
  • UP Testimony/Comments Before the California Department of Insurance re: Mitigation in Rating Plans and Wildfire Risk Models, REG-2020-00015, November 10, 2021
  • UP joins consumer groups’ letter stating The Insurance Commissioner has the legal authority to require insurance companies to set rates and premiums that reflect a homeowner’s risk of loss and to prevent insurance companies from arbitrarily withdrawing from neighborhoods and communities across the state. (November 2021)
  • Memo Re: Scope of the Insurance Commissioner’s authority under the Insurance Code (May, 2021)
  • UP petition for investigatory hearings on insurer use of wildfire risk models
  • The Department’s official notice to insurers that their obligation under Cal. Ins. Code 2017 is to provide the full claim file
  • UP letter requesting an official notice on an insurer’s obligation to provide to the insured the full claim file upon request
  • Order granting UP’s petition to intervene in CSAA rate filing 16-934
  • UP’s Petition for Hearing, Petition to Intervene, and Notice of Intent to Seek Compensation under Proposition 103
  • Order granting UP’s Request for Finding of Eligibility to Seek Compensation as a Consumer Intervenor under Proposition 103
  • UP’s Request for Finding of Eligibility to Seek Compensation as a Consumer Intervenor under Proposition 103
  • Financial Preparedness Advisor Tony Steuer is a member of the California Department of Insurance Curriculum Board
  • Insurance Commissioner Jones Announces New Regulations to Protect Homeowners from Being Underinsured

• UP Comments on the Proposed Amendments to Reg 2-4-1 Concerning Surplus Lines Insurance Issued By Nonadmitted Insurers (October, 2024)
• UP Comments on Proposed Regulation 5-1-XX Concerning Homeowner Coverage Disclosure Requirements, 3 CCR 702-5 (April, 2024)

• UP Presentation: Keeping your home insured despite more limited and expensive options in the CO marketplace at CO Division of Insurance Stakeholder Meeting on Homeowners / HOA Insurance Issues, March 26th, 2024
• Colorado Division of Insurance Public Hearing on Potential Solutions to Affordability Challenges – Traditional to Innovative Solutions, November 13, 2023 (Virtual)
• UP Comments November 2023 – Colorado Division of Insurance Workshop
• Comments for July 18, 2023 Hearing Workshop on HR 22-1111, Concerning Streamlined Inventory Process and Consumer Disclosures, 3 CCR 702-5, 7/18/23
• New rules for disaster claims in CA, CO, and OR (NAIC/Consumer Liaison Committee Summer Meeting, Portland, OR Friday, 8/12/2022
• Letter in support of Proposed Emergency Regulation 22-E-XX, 8/1/2022
• Letter in support of proposed regulations extending benefit time limits after disasters (Nov 2021)
• Letter regarding changes to bulletin B5.28 – Equitable Payment of Claims Resulting from Natural Disasters
• Colorado Homeowners Insurance Reform Act of 2013 – Summary
• Colorado Homeowners Insurance Reform Act of 2013 – Full Text
• FAQ’s about the Colorado Insurance Reform Act of 2013

• Letter Regarding Board Certification in Insurance Law

• UP Comments on homeowners insurance required disclosures
• UP Comments on Proposed Regulations for Auto Insurance Claims

• CHA and UP comments on Long Term Care Insurance and Annuities
• Letter re: old roof surcharge and illusory discount in homeowners policies

• Bach Insurance and Wildfire Mitigation presentation to Nevada DOI 12-1-22
• Nevada Personal-Lines Property Insurance Wildfire Mitigation Incentive Program
  Product Compliance Section – Nevada Division of Insurance – August 3, 2022

• New rules for disaster claims in CA, CO, and OR (NAIC/Consumer Liaison Committee Summer Meeting, Portland, OR Friday, 8/12/2022

• Comments re: Proposed Insurance Regulation 110 – Property Insurance and Weather Related Claims, Section 11 – Mediation Program

• Letter opposing the approval of any filed first-party property insurance policies containing arbitration provisions

• Letter opposing changes to law that would allow the use of mandatory arbitration clauses in insurance policies (co-signed by Birny Birnbaum, Executive Director, Center for Economic Justice)
• Virginia’s notice that it will not change it’s position prohibiting the use of arbitration clauses in insurance policies

UP Comments on (R-2021-04) Regulation Prohibiting the Depreciation of Labor (July 2021)

• • Regulation Language Prohibiting Depreciation of Labor
  • Summary of Regulation – Effective Jan 1, 2022 
  • Concise Explanatory Statement from Insurance Commissioner Kreidler