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
American Property Casualty Insurance Association
September 10, 2026
Good Afternoon-
APCIA appreciates the opportunity to provide feedback on the draft bulletin on Mandatory Statutory Liability Coverage. Review of the document by our members resulted in the following comments.
One concern expressed is that the proposal would create costly changes to an insurer’s system that would be required in order to accommodate an extremely small percentage of policyholders that would actually be impacted.
In addition, the following questions were noted:
- How would this requirement apply within a Commercial Lines distribution model where policy servicing and coverage change requests may be initiated through agents or brokers?
- What constitutes an "extended period" ?
- May the required consumer notification be provided verbally?
- What documentation would the MIA consider sufficient to demonstrate compliance with the notification requirement?
Thank you for consideration of these comments. Please let us know if you have any questions.
Paul Tetrault, JD, CPCU, ARM, AIM, MCM
Senior Director, Personal Lines & Counsel
American Property Casualty Insurance Association (APCIA)
