​​Bulletin Proposed August 10, 2026

National Association of Mutual Insurance Companies (NAMIC)

September 9, 2026

Mary Kwei, Associate Commissioner – Market Regulation & Professional Licensing
Maryland Insurance Administration
200 St. Paul Street, #2700
Baltimore, MD 21202

Re:  Draft “Bulletin 26-XX | Mandatory Statutory Vehicle Liability Coverage and Insurer Obligations upon Suspension or Termination of Liability Coverage”

Dear Associate Commissioner Kwei,

On behalf of the National Association of Mutual Insurance Companies (NAMIC), thank you for the opportunity to provide comments on proposed bulletin 26-XX “Mandatory Statutory Vehicle Liability Coverage and Insurer Obligations upon Suspension or Termination of Liability Coverage” (proposed bulletin).

NAMIC is the foremost trade association representing the property/casualty insurance industry. Serving more than 1,300 member companies, including local and regional insurers as well as some of the nation’s largest carriers, NAMIC members collectively write $492 billion in annual premiums, representing 62 percent of the homeowners and 56 percent of the automobile insurance markets. For more than 130 years, NAMIC has been the leading voice advancing public policy solutions and regulatory frameworks that promote a strong, competitive market and protect member companies and their policyholders.

NAMIC shares the Maryland Insurance Administration’s (MIA) goal of reducing the number of uninsured motorists operating on Maryland roads. Uninsured driving can result in serious consequences for accident victims, policyholders, insurers, and the state. Consumers have both a legal and personal responsibility to maintain required liability coverage and refrain from operating an uninsured vehicle. While insurers can provide notice and accurately report coverage information, they cannot control a policyholder’s conduct after coverage is removed. Accordingly, NAMIC respectfully questions whether the additional requirements contemplated by the proposed bulletin will materially reduce the uninsured-motorist rate.

The proposed bulletin appears to impose new or expanded obligations by requiring insurers to provide notice before processing a policyholder’s request to suspend or terminate liability coverage. Although these transactions may arise infrequently, compliance could require insurers to undertake significant, systemwide administrative and operational changes. These may include revising consumer forms, reprogramming policy administration systems, modifying MVA reporting files, developing new transaction codes, coordinating with third-party vendors, establishing procedures across all consumer and agent communication channels, and training employees and agents. The resources required to implement these changes could be considerable when compared to the limited number of transactions affected and the uncertain impact on uninsured driving.

The additional step could also delay or complicate a consumer’s requested coverage change. NAMIC therefore asks the MIA to recognize the role of licensed agents in advising policyholders and to confirm that an insurer may satisfy the notification requirement through an authorized agent when reasonable procedures and documentation are in place. The final bulletin should also permit notice to be provided contemporaneously with the transaction rather than requiring insurers to delay processing.

The proposed bulletin also raises questions about the reporting of a “suspension” of liability coverage. Existing MVA reporting processes generally address cancellation, termination, nonrenewal, and expiration, and “suspension” does not appear to correspond to a distinct transaction within the current reporting framework. If the MIA intends to require reporting specific to suspensions, insurers may need to modify forms, reporting files, and transaction codes, as well as coordinate with third-party vendors and the MVA. NAMIC requests that the MIA define “suspension,” explain how it differs from cancellation or termination, and clarify whether the bulletin establishes a new reporting obligation or merely applies existing requirements. Before creating a new transaction type or reporting process, the MIA should also evaluate whether existing reporting already provides the MVA with the information needed to identify vehicles without liability coverage.

If the MIA proceeds with the proposed bulletin, insurers will need sufficient time to implement any required changes. NAMIC respectfully requests that the final bulletin:

• Determine whether a separate “suspension” category is necessary and, if so, clearly define the term and its associated notification and reporting requirements.
• Recognize the role of licensed agents in communicating with policyholders;
• Provide insurers and vendors with a reasonable period to develop, test, and implement necessary changes; and

• Establish a regulatory grace period during which insurers will not be cited in market conduct examinations or other regulatory reviews for conduct based solely on the bulletin’s new or clarified requirements.
  

​​NAMIC supports clear consumer communication and accurate reporting of liability coverage. However, any new requirements should be carefully tailored to actions insurers can reasonably perform and should reflect the limited ability of insurers to influence a vehicle owner’s conduct after coverage has been removed. We respectfully ask the MIA to revise the proposed bulletin accordingly and provide appropriate implementation flexibility.

Thank you for your consideration of NAMIC’s comments. We welcome the opportunity to work with the MIA and the MVA to develop a clear and practical approach that informs consumers without imposing unnecessary operational burdens. Please do not hesitate to contact me if NAMIC can provide additional information or assistance.

Sincerely,

George McNab
Regional Vice President, Ohio Valley 

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

American Property Casualty Insurance Association

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