Aaron J. Aisen

All articles by Aaron J. Aisen

 

DFS Partially Clarifies Who Qualifies for an Exemption Under Cybersecurity Regulation

By the terms of 23 NYCRR 500.19(e), Covered Entities that have determined they qualify for a limited exemption from compliance under 23 NYCRR 500.19(a)-(d) of New York’s new Cybersecurity Regulation — as of August 28, 2017 — are required to file a Notice of Exemption with the New York Department of Financial Services (NYDFS) on or prior to September 28, 2017. The first compliance date of August 28, 2017 in New York’s cybersecurity regulation, and the date for Covered Entities
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Insurance Making a Summer Splash in Hot Washington, D.C. — Senate Votes to Start Healthcare Debate and Trump Signs Covered Agreement with EU

Amidst the sizzling news of investigations and conversations about North Korea and terrorism, insurance is making its own headlines in the nation’s capital this summer. Congress is debating repealing and replacing the Affordable Care Act (ACA) and the Trump Administration has signed off on the Covered Agreement with the European Union. Most of the insurance news out of Washington, D.C. is centered on Republican efforts to repeal and replace the ACA. Several packages are currently on the table. In May
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Congress Rolls Back FCC Privacy Regulations

On March 28, 2017, Congress passed legislation (S.J. Res. 34) that rolled back privacy regulations recently adopted by the Federal Communications Commission. The resolution passed the Senate by a vote of 50-48 and the House by a voted of 215 to 205. This is one of several sets of regulations Congress is rolling back under the authority of the Congressional Review Act of 1996. Under this statute, Congress can nullify administrative regulations by simply passing a joint resolution of disapproval.
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The NAIC Appeals to the Secretary of the Treasury Over the Covered Agreement

While the U.S. and EU governments are deliberating on whether to accept the negotiated Covered Agreement (Agreement), state insurance regulators in the U.S. are continuing to express concerns about the Agreement. In February 2017, the National Association of Insurance Commissioners (NAIC) testified before Congress against the Agreement. On March 15, 2017, the NAIC continued these efforts by submitting a letter to the U.S. Treasury Secretary Steven Mnuchin detailing the NAIC’s concerns. One of the NAIC’s central concerns centers on the
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ELANY Publishes Practical Tips on Applying New York’s New Cybersecurity Regulation to “Unique Situations”

There has been a lot of commentary on New York’s new regulation entitled Cybersecurity Requirements for Financial Services Companies (23 NYCRR 500) (the Regulation) which went into effect on March 1, 2017. On March 16, 2017, The Excess Line Association of New York (ELANY) released Bulletin 2017-12 which contains some practical guidance for insurance producers that will face some “unique situations” not addressed in the other commentary. Specifically, the bulletin refers to insurance producers that “may not meet the technical
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New York Issues Final Cybersecurity Regulation

On February 13, 2017, the New York Department of Financial Services (NYDFS) adopted the final version of its first-of-its-kind cybersecurity regulation, “Cybersecurity Requirements For Financial Services Companies” (23 NYCRR 500). This regulation took effect on March 1, 2017. The final regulation reflects several of the comments offered during the final comment period that concluded on January 27, 2017. For a prior list of significant changes from the initial version to the second version, please see our blog post located here.
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EU and U.S. Negotiators Reach Covered Agreement

On January 13, 2017, former U.S. Treasury Secretary Jacob Lew and former U.S Trade Representative Michael Froman notified Congressional leaders that U.S. negotiators reached a covered agreement with EU officials entitled “Bilateral Agreement between the European Union and the United States of America On Prudential Measures Regarding Insurance and Reinsurance” (Covered Agreement). The covered agreement covers three main areas of prudential insurance supervision: 1) group supervision; 2) reinsurance; and 3) exchange of information between supervisory authorities. The U.S. Treasury Department
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President Trump Takes Aim at Affordable Care Act; New York Governor Responds

Within hours of taking the Presidential oath of office, President Donald J. Trump issued his first executive order and it was directed at the Patient Protection and Affordable Care Act (ACA). The executive order formalized the Trump Administration’s policy to “seek the prompt repeal of the [“ACA”].” President Trump then directed executive department heads to “waive, defer, grant exemptions from, or delay the implementation of any provision or requirement” of the [ACA] that would impose a fiscal or regulatory burden
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NYDFS Issues Updated Cybersecurity Regulation

The New York Department of Financial Services (NYDFS) recently issued an updated version of its proposed cybersecurity regulation, “Cybersecurity Requirements For Financial Services Companies” (23 NYCRR 500). The updated proposed regulation reflects several of the comments offered during the initial public notice and comment period that concluded on November 14, 2016. Some of the most noteworthy changes in the revision are as follows: Section 500.04 — NYDFS clarified that while a Covered Entity must designate a qualified individual to perform
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Death of Carrie Fisher Likely Triggers Largest Contractual Performance Indemnity Policy

On December 27, 2016, Carrie Fisher, who was perhaps best known as Princess/General Leia Organa in the Star Wars Universe, passed away after a heart attack. As Star Wars fans and the world mourn Ms. Fisher’s passing, questions are swirling about how the Star Wars franchise will handle her death and the future of Princess Leia. Ms. Fisher finished shooting Episode VIII prior to her passing and was expected to have a part in Episode IX. What is clear now
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What Would the Insurance Provisions of Dodd-Frank Look Like Under the Trump Administration?

The incoming Trump Administration has already signaled its intent to repeal, or at the very least reform, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). To date, President-elect Trump has not signaled what changes he would make with respect to the insurance provisions of Dodd-Frank.  However, there is a bill in Congress that provides at least some insight as to what these changes might look like. In September 2016, Congressman Jed Hensarling (R-TX), Chairman of the House Financial
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Comments on NYSDFS Cybersecurity Regulation Begin Pouring In

On September 28, 2016, the New York State Department of Financial Services (DFS) released for comment a proposed new regulation entitled Cybersecurity Requirements for Financial Services Companies (23 N.Y.C.R.R. Part 500). Various industry groups have offered comments and expressed concerns about some of its requirements. These concerns include the costs of compliance and the scope of entities regulated by the proposed rule. Among the organizations offering comments are the Excess Lines Association of New York (ELANY) and the American Association
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Just Down the Hall — D.C. Appeals Court Hears Appeal Over MetLife’s SIFI Status

On March 30, 2016, Judge Rosemary M. Collyer of the U.S. District Court for the District of Columbia stripped MetLife of its designation as a nonbank systemically important financial institution (nonbank SIFI). She held that the designation was arbitrary and capricious as the Financial Stability Oversight Council (FSOC) failed to follow proper administrative procedures during the evaluation process. Just over a week later, FSOC walked down the hall of the U.S. Courthouse at 333 Constitution Avenue, NW and filed its
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U.S. Court of Appeals Issues Major Ruling Against CFPB

The U.S. Court of Appeals for the District of Columbia Circuit recently issued a decision in PHH v. CFPB that fundamentally transforms the power of one of the newest and most powerful agencies in the federal government, the Consumer Financial Protection Bureau (CFPB). First, the court held that the structure of the CFPB was unconstitutional and struck down a provision that only allows the president to dismiss the director of the CFPB for cause. After this decision, the director now
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Leaders of Major House Committee Wade into Equivalency Discussions

On August 17, 2016, the Chairman and Ranking Member of the House Ways and Means Committee waded into the ongoing discussions between U.S. and EU leaders regarding equivalency with the EU’s Solvency II and negotiation of a covered agreement. Chairman Kevin Brady and Ranking Member Sander Levin sent a letter to U.S. Treasury Secretary Jacob Lew and United States Trade Representative (USTR) Michael Froman expressing concern that Solvency II “unfairly discriminates against U.S. insurance and reinsurance (“(re)insurance”) business.” EU regulators
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Insurance Companies Narrowing Role in ACA Exchanges

In recent months, several major health insurance companies, including Aetna, Humana, and UnitedHealth Group, have announced their intention to reduce their footprints in the ACA healthcare exchanges. Aetna recently announced that it sustained a $200 million loss in the second-quarter of 2016 and over $430 million since January 2014 with respect to individual products. As a result, it “will reduce its individual public exchange participation from 778 to 242 counties for the 2017 plan year, maintaining an on-exchange presence in
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Change in Court Rules Could Increase Legal Costs of Connecticut-Licensed Insurers Appearing Before Commissioner

The State of Connecticut recently revised Section 2-16 of the Connecticut Superior Court Rules to require that an attorney not admitted in the State of Connecticut be admitted pro hac vice prior to appearing on behalf of a client before the Connecticut Insurance Department or any other state or municipal government agency. As with any pro hac vice admission in Connecticut, out-of-state attorneys will also be required to retain local counsel as a condition of any appearance. This represents a
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And Then There Were Two — GE Capital No Longer a Nonbank SIFI

GE Capital is no longer a nonbank SIFI. The Financial Stability Oversight Council (FSOC) formally announced on June 29, 2016 that it voted unanimously on June 28, 2016 to rescind the designation. In conjunction with the vote, FSOC released a 23-page opinion outlining the basis for its decision. In short, FSOC determined that GE “executed significant divestitures, transformed its funding model, and implemented a corporate reorganization.” It determined that “these and other changes at GE . . . have significantly
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Principle Based Reserving Coming January 1, 2017

In recent years, life insurance companies have expressed concern that the current approach to product reserves does not take into account the increasingly complex, non-static, nature of current life insurance products. In response to these concerns, the National Association of Insurance Commissioners (NAIC) conducted “an extensive analysis of amended Standard Valuation Laws passed by 45 states, representing nearly 80 percent of the U.S. life insurance market.” The end result happened on June 10, 2016, when the National Association of Insurance
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Federal Reserve Takes Steps on Capital Standards for Nonbank SIFIs

The passage of the Dodd-Frank Act led to an increased role for federal financial regulators in regulating insurance companies. While insurance companies are still primarily regulated at the state level, certain insurance companies also qualify for federal regulation. For example, Dodd-Frank explicitly requires that the Federal Reserve Board (FRB) regulate all financial institutions designated as systemically important financial institutions (nonbank SIFIs) by the Financial Stability Oversight Council (FSOC). Currently, FSOC has designated two insurance companies as nonbank SIFIs: Prudential and
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SCOTUS Orders Parties to Brief on Possible Compromise in ACA Case

On March 23, 2016, the U.S. Supreme Court heard oral arguments in Zubik, et al. v. Burwell, the case in which religious not-for-profits are challenging the process in which they can claim a religious exemption to the contraception requirement in the Affordable Care Act (ACA). On Tuesday, March 29, 2016, the court issued an unusual order hinting the court might be looking for some kind of compromise to deal with this highly controversial case. The court’s order requests supplemental briefing
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Federal Judge Overturns MetLife’s SIFI Designation

In a first-of-its-kind decision, U.S. District Judge Rosemary M. Collyer of the U.S. District Court for the District of Columbia granted MetLife’s motion to remove the non-bank SIFI designation imposed by the Financial Stability Oversight Council (FSOC). This is a highly significant case, as it represents the first time a SIFI-designated company has challenged the designation. However, the order and opinion are currently under seal, possibly due to the inclusion of confidential and proprietary information on both sides. The parties
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GAO’s Update on ACA Enrollment Process: CMS Encouraged to Take Steps to Monitor Program Cost, Risk, and Performance

The issue of fraud is still alive and well with respect to the health care exchanges established by the Affordable Care Act (ACA). The Government Accountability Office (GAO) recently issued a new update with respect to fraud in the federal exchanges. In that report, the GAO recommended that the Center for Medicaid and Medicare Services (CMS) strengthen enrollment controls and manage Fraud Risk. The report notes that implementation of the new eligibility and enrollment provisions for the first year was
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Supreme Court in Transition: What Happens to the ACA Case?

On Saturday, February 13, 2016, United States Supreme Court Justice Antonin Scalia, the longest serving justice on the Supreme Court, died in his sleep while on a hunting trip in Texas. One of the big questions now is what happens to the cases currently before the Court, especially those cases that were largely expected to be decided 5-4 while Justice Scalia was alive. Among those high profile cases is another one on the Affordable Care Act (ACA), Geneva College v.
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U.S. District Judge Explores the SIFI Designation Process

For the first time since the passage of Dodd-Frank, a U.S. District Judge is exploring the process by which the Financial Stability Oversight Council (FSOC) designates non-bank financial institutions as systemically important financial institutions (nonbank SIFIs). On February 10, 2016, U.S. District Judge Rosemary Collyer of the U.S. District Court for the District of Columbia heard arguments in the matter of MetLife v. FSOC. In January 2015, MetLife filed a lawsuit challenging the FSOC’s designation of MetLife as a nonbank
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Ohio Brings Certificates of Insurance Closer to Home

Ohio recently passed House Bill 259, a law that aims to ensure that certificates of insurance accurately reflect the policies they represent. In the past, certificates that did not accurately reflect the insurance policy caused coverage disputes. The new measure attempts to cure this defect and gives the Ohio insurance regulator more jurisdiction to ensure that the certificate accurately reflects the policy — with one stated aim to protect agents and policyholders against insurance fraud. In passing this law, Ohio joins 24
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New York Governor Andrew Cuomo Nominates New DFS Superintendent

Governor Andrew Cuomo has nominated Maria T. Vullo as the new Superintendent of the Department of Financial Services. If confirmed by the New York State Senate, she would replace Benjamin Lawsky who resigned as Superintendent in June 2015. Ms. Vullo, an experienced litigator, is currently of counsel at Paul Weiss in its New York City office. She has over 25 years of litigation experience at the trial and appellate levels including at the United States Supreme Court and in U.S.
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NYDFS Has New Acting Superintendent

New York State Governor Andrew Cuomo recently named Shirin Emami as Acting Superintendent of the New York Department of Financial Services (NYDFS). She is the second acting superintendent since the resignation of Benjamin Lawsky, who left NYDFS in June 2015 for a private-sector position specializing in cyber security research and consulting. Ms. Emami replaces Anthony Albanese, who also left for the private sector. Prior to her appointment, Ms. Emami served as both the Executive Deputy Superintendent and the General Counsel
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NYDFS Notifies Federal Regulators of New Potential Cyber Security Regulations

On November 9, 2015, the New York State Department of Financial Services (NYDFS) sent a memorandum entitled Potential New NYDFS Cyber Security Regulation Requirements to several federal and state financial services regulators, including banking, securities and insurance regulatory, administrative and supervisory  bodies. These potential regulations are based on results of two sets of surveys of financial entities about their “cyber security programs, costs and future plans.” NYDFS surveyed 150 banks and 43 insurance companies. The results of the May 2014 banking
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Controversial Cybersecurity Information Sharing Act Passes Senate, Will Likely Become Law

This post originally appeared on Goldberg Segalla’s Data Privacy and Security blog.  On October 27, 2015, the United States Senate passed S.754, the Cybersecurity Information Sharing Act (CISA or the Act) 74-21. Without requiring such information sharing, CISA would create a system for federal agencies to receive threat information from private companies in real time. However, the bill is not without controversy. As we discussed in August the Department of Homeland Security raised concerns in July and August that the
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Recent Court Decisions Show Fight Over ACA is Alive and Well

The battle over the Affordable Care Act (ACA) is heating up again with two recent high-profile decisions. In the first case, the U.S. House of Representatives as an institution sued the executive branch over actions taken by the executive during the implementation of the ACA. This case is unique because it addresses the broader question of whether the legislative branch has the authority to sue the executive branch over how the executive implements statutes. In U.S. House of Representatives v.
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Reminder to Eligible Excess Line Insurers with Policyholders in the State of New York — Minimum Surplus Requirement Increases for Excess Line Insurers

A Twelfth Amendment to New York’s Insurance Regulation 41 was promulgated by the Department of Financial Services after the President signed the Nonadmitted and Reinsurance Reform Act (NRRA), which was Title V, Section I in the Dodd-Frank Wall Street Reform and Consumer Protection Act, 15 U.SC. 8201. This amendment adopted most of the provisions of the NRRA on or about April 18, 2011. Like New York, most states incorporated, as amendments to their statutes or regulations, the provision in the
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NAIC and CSIS Host Cyber Risk Conference

This post first appeared on Goldberg Segalla’s Data Privacy & Security blog. On September 10, 2015, the National Association of Insurance Commissioners (NAIC) and the Center for Strategic and International Studies (CSIS) hosted a conference entitled “Managing Cyber Risk and the Role of Insurance.” Over three hundred individuals attended, including more than 30 insurance regulators, senior representatives from the U.S. Departments of Treasury and Homeland Security, and representatives from the private sector. The primary focus of the conference was to explore
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Not If, But When: Another Health Insurer Hacked

In mid-September, it was reported that hackers hit another set of health insurance companies. In this case, the hackers hit The Lifetime Healthcare Companies and its affiliates including Excellus BlueCross BlueShield, Univera Healthcare, and The MedAmerica Companies. A full list of plans affected can be found on the press release outlining the details of the attack. Hackers took information on approximately 10 millions customers including seven million from Excellus and three million from associated entities. Company IT officials first discovered the intrusion
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Let the (Employee) Beware: New Shift in DOJ Policy Places Emphasis on Individual Accountability

On September 9, 2015, the Deputy Attorney General (DAG), Sally Quillian Yates, issued a memo to senior leadership at the U.S. Department of Justice (DOJ) entitled “Individual Accountability for Corporate Wrongdoing.” In this memo, the DAG highlighted a new emphasis on not just holding corporations/entities responsible for corporate wrong-doing but also holding individual employees/officers responsible for any illegal activities. This new emphasis applies in both civil and criminal matters. The memo notes: One of the most effective ways to combat
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Money Trouble: Some Health Insurance CO-OPs in Financial Trouble

Much of the focus on health insurers under the Affordable Care Act (ACA) has centered on larger health insurance companies. In an effort to expand the number of health plans available to the public, the ACA also created the Consumer Operated and Oriented Plan (CO-OP) Program. The program is administered by the Centers for Medicare and Medicaid Services (CMS) at the Department of Health and Human Services (HHS). The ACA further directed HHS to make loans to these CO-OPs to
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NAIC Tackles Cybersecurity Including Proposed Consumer Cybersecurity Bill of Rights

In the wake of recent cyber breaches against major health insurance companies, the NAIC is undertaking three initiatives designed to “protect consumer information and educate the public about cyber risks.” First, on July 28, 2015, the NAIC’s Cybersecurity Task Force issued a proposed Consumer Cybersecurity Bill of Rights. This Bill of Rights contains 12 specific rights for consumers including: Know what type of personally identifiable information is being collected by the insurer and how long that information is being kept
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GAO Statement Highlights Deficiencies in Federal Exchange Enrollment Process

On July 16, 2015, the Government Accountability Office issued a written statement entitled “Patient Protection and Affordable Care Act: Observations of 18 Undercover Tests of Enrollment Controls for Health-Care Coverage and Consumer Subsidies Provided under the Act.” This statement contained the findings of “undercover testing of the [Exchange] application, enrollment, and eligibility verification controls using 18 fictitious identities” that GAO submitted or attempted to submit through the Exchange in several states in a variety of ways. Testing began in January
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Federal Cyber Legislation – Hurry Up and Wait

In recent months, two more companies in the healthcare industry have been hacked. UCLA Health announced on July 17, 2015 that it was the victim of a “criminal cyber attack” and “as many as 4.5 million individual potentially may have bene involved in the attack.”  This comes on the heels of another attack in May 2015 against Medical Informatics Engineering whose subsidiary is NoMoreClipboard, an online medical information sharing service used by patient and physicians alike.  Both of these episodes
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Accommodations for Contraception Coverage Exemptions Replace Subsidies As The ACA Story of the Week

In recent months, the main event in the challenges against the Affordable Care Act centered on the subsidies provisions in the ACA. The Supreme Court decided this matter in King v. Burwell. In July 2015, there were two additional key developments related to the provision requiring employers to provide contraception coverage. On July 14, 2015, the 10th Circuit Court of Appeals in Little Sisters of the Poor Home v. Burwell held that the self-certifying procedure in place for religious not-for-profits
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NY Unfair Claims Settlement Practices Bill Dies With Close of Legislative Session

The 2015 Legislative Session in New York came to a close in the wee hours of June 26. Among the bills introduced this session was S-4049/A-0257 amending the New York Insurance Law with respect to unfair claims settlement practices. Specifically, the bill, if enacted, would have established “a civil private cause of action by a policyholder who has suffered unfair claim settlement practices by an insurer.” Current law allows policy holders with these grievances against their insurers to file a
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Court Issues Decision in “20 Percent of Something is Better Than 100 Percent of Nothing” Case

Judge Thomas C. Wheeler of the U.S. Federal Court of Claims has issued a decision in one of the most watched cases directly tied with the government response to the 2008 financial crisis.  In Starr International Company, Inc. v. The United States, Starr International challenged the bailout of AIG in which the federal government took shareholder equity and management control. Prior to the crisis, Starr (whose controlling shareholder is former AIG executive Hank Greenberg) was a major shareholder in AIG.
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SCOTUS: Affordable Care Act Subsidies Apply to Federal Exchanges

On June 25, 2015, in a 6-3 opinion written by Chief Justice John Roberts, the United States Supreme Court held that the subsidies available in the Affordable Care Act apply to participants in both state and federal healthcare exchanges. A key component of the Affordable Care Act (i.e., the part that helps make this insurance affordable) is tax subsidies for those who qualify under the income requirements stated in the Act. Language in this provision, according to the petitioners and
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D.C. Circuit Appeals Court to IRS: Hands Off Wholly Foreign Retrocession Agreements

In Validus Reinsurance Ltd. v. United States of America, the D.C. Circuit Court of Appeals decided whether 26 U.S.C. § 4371, which taxes premiums on certain reinsurance policies issued by foreign reinsurers, applies where the reinsurance contract is between two wholly foreign entities. Validus Reinsurance is a Bermuda-domiciled company located in Bermuda that provides reinsurance for companies either incorporated in the United States or doing business in the U.S. It also purchases retrocession contracts from wholly foreign entities to cover
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Tracking the Uncertainty of the 2016 ACA Health Insurance Rates

Health insurers have begun submitting their proposals for approval of next year’s health insurance rates. For hundreds of Affordable Care Act (ACA) plans, the proposed rates are up by more than 10 percent with insurers seeking increases of upwards of 49 percent for some products. Insurers have cited to increases in drug costs and the receipt of more accurate data on their insureds in support of the proposed rates. Between now and October 2015, when the final rates are published,
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FSOC Replies to MetLife Lawsuit Challenging Nonbank SIFI Status

In early 2015, MetLife filed a lawsuit challenging its designation as a nonbank systemically important financial institution (nonbank SIFI). On May 11, 2015, the Financial Stability Oversight Council (FSOC) filed a redacted motion to dismiss (or in the alternative a motion for summary judgment) in response to MetLife’s lawsuit. One of MetLife’s key arguments in its complaint is that FSOC’s designation was arbitrary and capricious. FSOC argues in its motion to dismiss, dated May 11, 2015, that its decision to
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Senate Panel to Probe Eligibility Verification Process for ACA Subsidies

The Senate’s Permanent Subcommittee on Investigations (PSI) has launched an inquiry into government subsidies under the Affordable Care Act available primarily in the form of advance premium tax credits. According to PSI’s letter to Secretary Burwell, the premium subsidies for last year were approximately $15 billion and are expected to reach $849 billion over the next ten years. Prompting the inquiry are concerns of improper over-payments with the goal of preventing government waste. According to the letter, “to ensure proper oversight,
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Inquiry Signals Further Federal Regulation of Annuity Product Sales Likely

Late last week, Senator Elizabeth Warren, Ranking Member of the U.S. Senate Subcommittee on Economic Policy, sent a letter to 15 of the top writers of annuity products, including AIG Companies, Allianz Life Insurance Company of North America, AXA, Lincoln Financial Group, New York Life Insurance Company, and MetLife, seeking information about the manner in which these companies compensate their insurance agents for the sale of these products. Warren emphasized that sales made to those close to retirement were of
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New York Department of Financial Services Superintendent Continues Criticism of “Shadow Insurance” Transactions in Letter to U.S. Senate Committee

New York Department of Financial Services (DFS) Superintendent Benjamin Lawsky continued his attack against the use of so-called “shadow insurance” in an April 27, 2015 letter to the Honorable Sherrod Brown, Ranking Member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs. In the letter, Lawsky called on regulators to initiate measures to address this “textbook example of regulatory arbitrage in order to protect the efficacy of our state-based system of regulation” and hopes to stimulate a national
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NAIC Adopts Cybersecurity Regulatory Guidance

On Thursday, April 16, 2015, the Cybersecurity Task Force of the National Association of Insurance Commissioners (NAIC) adopted the “Principles for Effective Cybersecurity Insurance Regulatory Guidance.” Monica J. Lindeen, the NAIC President and Montana Commissioner of Securities and Insurance noted that these 12 principles “will serve as the foundation for protection of sensitive consumer information held by insurers as well as insurance producers and guide regulators who oversee the insurance industry.” The press release announcing the adoption notes: The document
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