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

• Letter seeking retroactive Proof of Loss deadline for 2013 Colorado flood victims
• 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)
• 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
• UP requested an extension of the proof of loss deadline for 2016 Baton Rouge Louisiana flood victims (August 24, 2017)

• 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 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
• 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 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
• 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 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