Insurance Legislative and Regulatory Activity in the US and EU in Response to COVID-19: Insurance Legislative and Regulatory Activity in Response to COVID-19—U.S. and EU Developments

Sullivan & Cromwell LLP - April 9, 2020
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Significant legislative and regulatory activity has occurred at both the U.S. federal and state levels, as well as in the EU and UK, in response to COVID-19 and its impact on the insurance industry and insurance consumers.  In this memorandum, we summarize certain key COVID-19-related insurance legislative and regulatory developments to date, including:  U.S. state bills to require insurers to retroactively cover business interruption claims relating to COVID-19; U.S. Congressional activity and legislative proposals involving business interruption insurance, federal pandemic loss-sharing programs and other insurance matters; New York Department of Financial Services circular letters, industry guidance and emergency regulations relating to COVID-19; COVID-19-related actions, guidance and directives from other state insurance regulators, the NAIC and NCOIL; and certain actions taken by the IAIS and by regulators in the UK and EU.