​​Bulletin Proposed August 10, 2026

Insurance Agents and Brokers (IA&B)

650 Wilson Lane, Suite 200
Mechanicsburg, PA 17055

September 3, 2026

Mary Kwei
Maryland Insurance Administration
200 St Paul St #2700
Baltimore, MD  21202

SENT VIA EMAIL TO [email protected]

Dear Ms. Kwei:

RE: PROPOSED BULLETIN ON INSURER OBLIGATIONS ON SUSPENSION OR TERMINATION OF AUTO LIABILITY COVERAGE

On behalf of the Insurance Agents & Brokers of Maryland (IA&B), thank you for the opportunity to provide comments on the draft bulletin referenced above. IA&B is a professional trade association for independent insurance agents in Maryland, representing nearly 200 member agencies and their 1,800-plus employees, most of whom are licensed insurance producers.

Upon reviewing the draft, we have the following comment. Under “1. Consumer Notification,” we would like to suggest replacing “Prior to processing” with “Upon processing.” Prior to implies that notification is given before they start. Programming, however, will require that the request first be initiated before a message or a notice can be printed.

We believe this request is in keeping with COMAR 11.18.04.03 E., which requires “timely notification to the insured of the penalties that may be imposed… when the security will terminate.” A notification embedded in the processing of a “Comp-only” policy would accomplish this goal. For example, the notice could be attached to the policy-change documents to sign, or a pop-up window warning the customer could be displayed during the workflow process.

Again, we appreciate the opportunity to provide comments on this proposed bulletin. Please do not hesitate to contact me if you have any questions on the above comments.

Sincerely,

Claire Pantaloni
VP Advocacy

c: Jason Ernest, Esq., President & CEO
Olivia Helms, Government Affairs Assistant
Bryson Popham, P.A. & Sarah Joan Smith