Four layers shape what a US insurer must do, and they answer different questions: the state insurance code says what is prohibited, the state administrative regulations say what the process must look like, the department bulletins say how the regulator reads both, and market conduct expectations say what an examiner will test. The layers do not line up the same way in every state. In Texas, for example, the 15-day claim acknowledgment deadline sits in the insurance code itself, while California and New York put their deadlines in regulations. Read all four layers, and for each state find out which layer holds the answer.
Reviewed and corrected on 12 October 2026. This is general information, not legal advice; check the cited statute, rule or bulletin on the official site before relying on it.
This is a working guide for a compliance or product team that operates in more than a handful of states. It covers what lives in each layer, where the departments publish their bulletins, and one worked comparison of a claim-handling deadline in four states.
TL;DR
- Statutes tell you what is prohibited. Each state's insurance code (California Insurance Code, Texas Insurance Code, New York Insurance Law and so on) sets the principle, and it sometimes also sets a number.
- Regulations tell you what the process looks like. Deadlines, notice content and filing mechanics often live in the state administrative code, though not always. Check both layers.
- Bulletins tell you how the regulator reads the first two. Every department names them differently, and they are guidance, not statute. Virginia says its administrative letters "are not law but are positions that the Bureau of Insurance has taken." Washington says its advisories "are advisories only."
- Market conduct expectations come from examinations. The NAIC publishes the Market Regulation Handbook examiners use as a reference. Since January 2025 the NAIC offers it free of charge to non-regulators.
- Similar-looking numbers can hide different clocks. California counts 15 calendar days to acknowledge a claim. New York counts 15 business days. Store each state's rule in its own words.
- Rules change on dates you can look up. Washington's claim acknowledgment rule switches from "working days" to "business days" on 18 October 2026.
Your claims team asks how many days they have to acknowledge a new first-party claim. The state insurance code only says that unfair claim practices are prohibited. Where do you look next?
The four layers
Each layer sits under the one above it and gets more specific. A regulation is adopted under a statutory grant, a bulletin interprets one or both, and an exam tests conduct against all three.
The failure mode is reading only the top. A statute that prohibits unfair claim settlement practices is real law and may answer nothing operational. The number of days, the required content of a notice and the acceptable proof of mailing may live further down, or, as in Texas, in a different part of the code.
Layer 1: the state insurance code
What it answers: who must be licensed, what conduct is prohibited, what the commissioner may do, and what the penalties are. Insurance is usually its own code or title in the state's statute book.
Examples. California's Insurance Code section 790.03 defines unfair practices in the business of insurance, and section 790.034 requires an insurer, on receiving notice of a claim, to give the insured a copy of subdivisions (h) and (i) of section 790.03 and a written notice about the Fair Claims Settlement Practices Regulations within 15 calendar days. Texas Insurance Code chapter 542, subchapter B covers prompt payment of first-party claims, and its section 542.055 sets the acknowledgment deadline discussed below.
Why you still need it: every regulation and bulletin traces back to a statutory grant. When you want to argue that a department has overreached, this is where the argument starts.
Layer 2: state administrative regulations
What it answers: the operational rules. Timeframes, required notice content, form and rate filing procedure, recordkeeping and producer conduct.
Examples. California's Fair Claims Settlement Practices Regulations are in title 10 of the California Code of Regulations, starting at section 2695.1. New York's unfair claims settlement rules are Part 216 of title 11 of the New York Codes, Rules and Regulations (Insurance Regulation 64), which sit under Insurance Law section 2601. Washington's are in chapter 284-30 of the Washington Administrative Code.
Why it matters most for product teams: if you are building claims software or a policy administration system, this is often the layer that turns into acceptance criteria. A statute says a practice is unfair. A regulation may say a first-party claim gets acknowledged within a stated number of days and what the acknowledgment must contain.
Layer 3: department bulletins
What it answers: how the commissioner applies layers one and two right now, including to things the code never anticipated.
Why teams skip it: there is no standard name for it. A search for "bulletin" misses most of these. The state names and pages below were read on 12 October 2026.
| State | What the department calls them | Where they are listed |
|---|---|---|
| New York | Insurance Circular Letters | dfs.ny.gov circular letters |
| Virginia | Administrative Letters | scc.virginia.gov administrative letters |
| Washington | Technical Assistance Advisories | insurance.wa.gov advisories and emergency orders |
| Hawaii | Commissioner's Memoranda | cca.hawaii.gov commissioner's memoranda |
| Florida | Informational Memoranda | floir.gov orders and memoranda |
| Montana | Advisory Memos | csimt.gov advisory memos |
| Puerto Rico | Cartas Normativas | ocs.pr.gov cartas normativas |
Weight differs by department, and each says so in its own words. Virginia's Bureau of Insurance page on how it administers insurance regulation states that administrative letters "are not law but are positions that the Bureau of Insurance has taken." Washington's page says its advisories are "interpretive policy statements released to advise the public of the OIC's current opinions, approaches and likely courses of action," and "are advisories only." Montana's page says its advisory memorandums distribute information about the Commissioner's "interpretation of laws or rules, state and federal law changes, administrative rule changes, or CSI's position on industry practices."
Why it is worth monitoring: a bulletin can be issued on any date and change what compliant behavior looks like without a word of statutory text changing. Florida's February 20, 2025 informational memorandum on concurrent causation, for example, is posted on the department's GovDelivery bulletin page.
Layer 4: market conduct expectations
What it answers: what an examiner samples, how a finding is written, and what remediation the department will accept.
Where it lives: in each department's exam practice, and in the NAIC's Market Regulation Handbook, which the NAIC describes as helping "market regulators conduct uniform, standardized market analysis and market conduct examinations." The NAIC's own access page for the 2025 edition says that "As of January 2025, the Market Regulation Handbook is provided free of charge to non-regulators" at content.naic.org/publications. The handbook is an NAIC publication, not a state statute or rule, and individual states run their own examinations.
How layers three and four connect: departments sometimes say in a bulletin what they will examine. Florida's February 2025 informational memorandum told residential property insurers that its examinations for the 2024 Atlantic hurricane season "will include a review of all three storms' claims and the accuracy of the insurers' claim determinations related to claim denials." Reading layer three carefully can show you layer four ahead of time.
A short history: a model act that "almost all states" adopted
The claims rules in layer one have a traceable family tree. The NAIC's own chronology for its Unfair Claims Settlement Practices Act (Model #900) says claims settlement practices were added to the model Unfair Trade Practices Act in December 1971, and that in June 1990 the NAIC "separated issues regarding unfair claims settlement practices into a free-standing act." Two lawyers who wrote a practitioner roadmap to the 50 states, Shea Backus and Lindsey Woodrow, put the outcome this way: "Almost all states have statutory or regulatory provisions governing fair claims handling. These laws are mostly a product of the model legislation drafted by the National Association of Insurance Commissioners."
So far, so uniform. Then they add the catch. The model act "was not drafted to be construed to create a private cause of action," and "there is a split between the states as to whether a particular state's laws permit a private cause of action as opposed to simply implementing administrative penalties." Same model, different consequences. That is why this post keeps telling you to read the state's own text. A model law gets states started. It does not tell you what any one of them ended up with.
A worked example: claim acknowledgment in four states
Take a question a multi-state carrier asks constantly: how fast must we acknowledge a first-party claim? Here is what four states' own texts say. The California and New York wording is from Cornell's Legal Information Institute copies, so check the current official text before you rely on either. The Texas text is from the Texas Legislature's site and the Washington text is from the Washington Legislature's site.
| State | Source | What it says | The clock |
|---|---|---|---|
| California | 10 CCR § 2695.5(e) | Upon receiving notice of claim, the insurer shall "immediately, but in no event more than fifteen (15) calendar days later" acknowledge receipt to the claimant, unless payment is made within that period | 15 calendar days |
| New York | 11 NYCRR § 216.4(a) | "Every insurer, upon notification of a claim, shall, within 15 business days, acknowledge the receipt of such notice." | 15 business days |
| Texas | Tex. Ins. Code § 542.055(a) | "Not later than the 15th day or, if the insurer is an eligible surplus lines insurer, the 30th business day after the date an insurer receives notice of a claim," the insurer shall acknowledge receipt, commence any investigation and request the items it needs from the claimant | The 15th day (the statute defines "business day" separately, in § 542.051) |
| Washington | WAC 284-30-360(1) | Within ten working days after notification of a claim under an individual policy, or fifteen working days for group contracts, the insurer must acknowledge receipt. From 18 October 2026 the same section says "10 business days" and "15 business days" | 10 working days until 18 October 2026; 10 business days from that date (WSR 26-17-089) |
Read across the rows. California's number is 15 and counts weekends. New York's number is 15 and does not. Texas also says 15, but in the insurance code and not in a regulation. Washington says 10 for an individual policy, and the wording of its clock changes on 18 October 2026. A playbook that says "15 days" will be fine in one of these states and late in another. That is the kind of thing a matrix of citations, with each state's own wording and a check date behind it, exists to prevent.
Two cautions. First, these rules are about acknowledging a claim. Other deadlines (investigation, accept or deny, payment) sit in other sections and differ again. Second, line-of-business matters. The Washington rule has separate periods for individual and group contracts, and the Texas statute carves out eligible surplus lines insurers.
What the output looks like as a compliance artifact
The deliverable is a small table your team can maintain, with one row per state and one column per layer, holding citations and links rather than prose:
| State | Statute | Regulation | Bulletin | Last checked |
|---|---|---|---|---|
| CA | Ins. Code § 790.03, § 790.034 | 10 CCR § 2695.5 | (none found, or the bulletin number) | date |
| NY | Ins. Law § 2601 | 11 NYCRR § 216.4 | Circular letter number, if any | date |
| TX | Ins. Code § 542.055 | (none found, or the rule) | (none found, or the memo) | date |
| WA | Title 48 RCW (cite the section you rely on) | WAC 284-30-360 | Advisory number, if any | date |
Storing citations and links rather than pasted text is the whole trick. Pasted text goes stale silently. A citation can be re-read, compared with what you stored and watched.
One more public source: the filings
Insurers also file rates and forms with state regulators, and in many states those filings are public records you can read. Practitioners point to it often, and they are candid about how it feels to use. In a March 2024 thread, one commenter wrote that "It's all publically available. Filings are done through the SERFF system," and described finding an actuary's report, the justification for a price change and the correspondence between the company and the regulator (phonon, Hacker News, March 2024). Another, in 2020, wrote that how insurers determine your rate "is generally available online," and added the catch: "some of the documents are almost unreadable." (kevindong, Hacker News, February 2020).
Both are right, and the lesson carries to every layer in this post. Public does not mean easy. The text exists, and the work is finding the right piece of it and keeping track of which version you read.
Keeping up with change
Statutes turn over on a legislative calendar, and regulations change through each state's rulemaking process, which publishes effective dates. Washington's acknowledgment rule above is an example: the official page shows the current version, "Effective until October 18, 2026," and a second version that is effective on that date. Bulletins follow no calendar. A workable routine is to list the department pages above for each state you operate in, check them on a set schedule, record the date of each check, and re-read the statute and regulation behind any bulletin that touches a rule you rely on.
For the US statutes, regulations and court rules these laws sit in, see the US primary law API.
FAQ
What are the layers of insurance regulation in the US?
Four: the state insurance code (statutes), the state administrative regulations adopted under it, the department bulletins interpreting both, and the market conduct expectations an examiner applies. Specificity generally increases as you move down, and operational answers are often in layers two and three, though a state may put a number in the statute.
Which layer answers an operational question like a claim deadline?
It depends on the state. California and New York set their acknowledgment deadlines in regulations. Texas sets its deadline in the Insurance Code. Washington sets its deadline in an administrative rule. Check the statute and the regulation in each state, then look for a bulletin that narrows either.
Why do insurance bulletins get skipped so often?
Because there is no shared name for them. New York issues Insurance Circular Letters, Virginia issues Administrative Letters, Washington issues Technical Assistance Advisories, Hawaii issues Commissioner's Memoranda, Florida issues Informational Memoranda, Montana issues Advisory Memos, and Puerto Rico issues Cartas Normativas. A search tuned to the word "bulletin" misses most of them.
Are bulletins binding?
Not by their own terms. Virginia says its administrative letters are not law and Washington says its advisories are advisories only. They show how the department reads the law, which is why examiners and regulators rely on them. How much weight a given state's courts give them is a question of that state's administrative law.
Are NAIC model laws the law?
No. A model law is a template that the NAIC adopts and each state's legislature may or may not enact, in whole or in part. Only a state's enacted statutes and adopted regulations, and the bulletins it issues under its own authority, apply in that state.
Is the NAIC Market Regulation Handbook available to the public?
Yes. According to the NAIC's 2025 access page, the handbook is provided free of charge to non-regulators as a digital download at content.naic.org/publications, as of January 2025. The 2025 edition was released in June 2025. Check that page for the current edition.
How should a compliance team store the results of this research?
Store the citation, the official source link and the date you last read it, not only quoted text. A citation can be re-read and compared on a schedule. Quoted text in a spreadsheet goes stale without telling anyone, which is how a compliance matrix ends up confidently wrong two amendments later.
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Co-Founder & CTO
Priyansh leads engineering and AI at Vaquill AI: the pipelines that pull statutes, regulations and court rules from every US jurisdiction's official publisher, and the REST API, MCP server and open dataset that serve them.