{"id":891637,"date":"2017-02-14T12:52:08","date_gmt":"2017-02-14T19:52:08","guid":{"rendered":"https:\/\/www.myconstructionexpert.com\/blog\/?p=891637"},"modified":"2017-02-14T12:52:08","modified_gmt":"2017-02-14T19:52:08","slug":"minnesota-discovers-limits-regulators-power-insurers","status":"publish","type":"post","link":"https:\/\/www.myconstructionexpert.com\/blog\/minnesota-discovers-limits-regulators-power-insurers\/","title":{"rendered":"Minnesota Discovers Limits To Its Regulator\u2019s Power Over Insurers"},"content":{"rendered":"

Robert D. Helfand and Barry Leigh Weissman | PropertyCasualtyFocus<\/a> | January 13, 2017<\/p>\n

In Minnesota, the Commissioner of the Department of Commerce regulates the insurance industry, and he has a statutory right to conduct investigations \u201crelated to the duties and responsibilities entrusted to\u201d him. Last month, in\u00a0Matter of the Petition of the Property Casualty Insurers Association of America, Inc.<\/em>, 41 Minn. State Register 830 (Dec. 7, 2016), the state\u2019s Office of Administrative Hearings took up the question of just what those \u201cduties and responsibilities<\/strong>\u201d are. The Commissioner\u2019s position was that licensing a company to sell insurance in Minnesota makes any <\/em>aspect of that company\u2019s business subject to his oversight. An Administrative Law Judge disagreed, ruling that the Commissioner\u2019s regulatory powers do not extend to practices beyond the sale of insurance products.<\/strong> The decision establishes an important basis for future challenges to regulatory overreach.<\/p>\n

Mind If I Ask A Few Questions?<\/h2>\n

In 2012, California\u2019s legislature imposed a requirement that certain insurers (those with over $100 million of written premiums in the state) file reports on their efforts to seek out, and contract with, vendors owned by women, disabled veterans or members of disadvantaged racial and ethnic minorities. Information contained in the reports must be made public through a link on the web site of the Insurance Department. Cal. Ins. Code \u00a7 972.2.<\/p>\n

California considered the program a success\u2014so much so that its insurance commissioner persuaded counterparts in five other jurisdictions to work together on a broader project. The result was the Multistate Insurance Diversity Survey (MIDS), <\/strong>which was announced on May 2, 2016, in a letter from the commissioners of California, Minnesota, New York, Oregon, Washington and the District of Columbia.<\/p>\n

The letter was addressed to all insurance companies that were licensed in any one <\/em>of the six participating jurisdictions, and which had written national premiums of $300 million or more. It explained that the MIDS survey would examine two different diversity issues: (i) the extent of each insurer\u2019s efforts to build relationships with businesses owned by members of disadvantaged groups (now including the LGBT community), and (ii) insurers\u2019 efforts to diversify the membership of their own governing boards and leadership. It also stated that insurers\u2019 responses would be made available to the public<\/strong> through a web \u201cportal\u201d associated with the program.<\/p>\n

The MIDS Survey itself is nearly 30 pages long. Among other things, it asks insurers to report their overall procurement spending in each of the six participating jurisdictions, broken down into 14 different categories, including \u201cAdvertising\/Marketing,\u201d \u201cClaims Services,\u201d \u201cFinancial Services,\u201d \u201cLegal Services,\u201d \u201cInformation Technology,\u201d \u201cOffice Supplies\u201d and \u201cOther.\u201d For each state, it also asks the insurer to report separately the dollar amount in each business category that was paid to each type of disadvantaged business (i.e.<\/em>, minority-owned, disabled veteran-owned, woman-owned or LGBT-owned).<\/p>\n

The Survey also calls on each insurer to report on such matters as the ethnic composition and sexual orientation of the members of its board of directors; whether the mission statement of the board and its committees includes the goal of increasing diversity (and, if so, the language in which it does so); whether the company engages in outreach efforts to diversify its board (and, if so, the nature of those efforts); and whether the company has a \u201csupplier diversity program\u201d in place (with a description of that program).<\/p>\n

The survey was released on June 1, 2016, and responses were due on September 1.<\/p>\n

Mind If I Ask You One First?<\/h2>\n

On June 14, 2016, four trade associations, led by the Property Casualty Insurers Association of America, Inc. (PCI),\u00a0sent a letter to the commissioners, asking them to identify the legal basis<\/strong> for the requests contained in the survey. [Full disclosure: The authors represent PCI, but not in connection with this matter.] <\/strong>The commissioners responded jointly on August 10. Among other things, the commissioners identified two Minnesota statutes, which, they claimed, gave the state\u2019s commissioner authority to \u201crequire insurers to respond to the survey.\u201d<\/p>\n

Minnesota law also gives aggrieved parties the right to petition the state\u2019s Office of Administrative Hearings (OAH) for an order by an administrative law judge, determining that a state agency<\/p>\n

is enforcing or attempting to enforce a policy, guideline, bulletin, criterion, manual standard, or similar pronouncement as though it were a duly adopted rule<\/strong>.<\/p><\/blockquote>\n

If the petition is successful, the agency must \u201ccease enforcement of the unadopted rule.\u201d Minn. Stat. \u00a7 14.381.<\/p>\n

PCI filed a petition under the statute on September 2, 2016. The petition asserted that the demand for responses to the MIDS survey constituted a \u201crule,\u201d within the meaning of the Minnesota Administrative Procedure Act (MAPA); that the rule had not been properly adopted; and that the Commissioner lacked statutory authority to adopt such a rule. PCI also complained that public access to survey responses would result in disclosure of confidential business information to competitors of the reporting companies.<\/p>\n

On November 21, counsel for the Minnesota Commissioner advised that his Department would not take any action against insurers that failed to respond to the 2016 survey. The Commissioner later argued that this letter mooted PCI\u2019s petition, but the OAH rejected that argument, finding that the issues raised by the petition were likely to come up again.<\/p>\n

There Are Limits<\/h2>\n

MAPA\u2019s definition of a \u201crule\u201d includes \u201cevery agency statement of general applicability and future effect.\u201d Minn. Stat. \u00a7 14.02. In his ruling on PCI\u2019s petition, an administrative law judge of the OAH quoted a statement from the commissioners\u2019 joint letter of August 10, 2016, to the effect that they have \u201cdiscretion to require any licensed insurer \u2026 to complete the [MIDS] survey.\u201d The ALJ found that this constituted a \u201cstatement of general applicability.\u201d The ALJ also held that the commissioners\u2019 announcement of a deadline for responses (which was contained in their original letter of May 2) constituted a \u201cstatement of \u2026 future effect.\u201d<\/p>\n

Even if a rule has not <\/em>been properly adopted, however, it may still be valid under Minnesota law \u201cif the agency\u2019s interpretation of a [statute] corresponds with its plain meaning.\u201d Cable Communications Bd. v. Nor-West Cable Communications Partnership<\/em>, 356 N.W.2d 658 (Minn. 1984). Thus, the Commissioner\u2019s claim that he could compel responses to the MIDS survey turned on his contention that he was authorized to do so by the plain meaning of two statutes. And the language of the statutes on which he chose to rely turned out to raise a fundamental question about the scope of his power to regulate insurers.<\/p>\n

The Commissioner cited Subdivision 1a of Minn. Stat. \u00a7 45.027, which states, in part:<\/p>\n

A[] \u2026 licensee \u2026 or other person subject to the jurisdiction of the commissioner shall comply with requests for information, documents, or other requests from the department within the time specified in the request \u2026 .<\/p><\/blockquote>\n

As PCI pointed out, however, that provision follows Subdivision 1, which establishes the authority of the Commissioner to issue such requests, and which does so in the following language:<\/p>\n

In connection with the duties and responsibilities entrusted to the commissioner \u2026, the commissioner of commerce may \u2026 conduct investigations<\/strong> \u2026 for the purpose of compiling<\/strong> information related to the duties and responsibilities entrusted to the commissioner<\/strong> \u2026 .<\/p><\/blockquote>\n

The Commissioner contended that insurers\u2019 diversity practices clearly fall within his \u201cduties and responsibilities.\u201d Although he acknowledged that some<\/em> categories of information are probably outside the scope of his investigatory powers, his counsel could not name any of those categories during a conference in September. Thus, the ALJ took the Commissioner\u2019s position to be that every <\/em>aspect of an insurer\u2019s business is subject to regulation by the Department of Commerce. And the ALJ rejected that position:<\/p>\n

The dispute in this case centers on the meaning of the phrase \u2018related to the duties and responsibilities entrusted to the commissioner\u2019 \u2026 .The Department \u2026 asserts that to the extent a company holds an insurance license, any activity that the company later engages in is \u2018related to the duties and responsibilities entrusted to the commissioner.\u2019<\/p>\n

In the view of the Administrative Law Judge, the suggestion that an insurance company does not undertake any activity that is beyond the reach of the Commissioner<\/strong> to inquire upon, as much as the Commissioner wishes, and as often as he wishes, is very troubling<\/strong>. It inverts the entire statutory scheme. Particular duties <\/em>are entrusted to the Commissioner; not particular companies<\/strong>.<\/p><\/blockquote>\n

The Commissioner also cited Minn. Stat. \u00a7 60A.03, which grants him \u201cpower to enforce all the laws of this state relating to insurance<\/strong>.\u201d But the ALJ found that this grant \u201cdoes not permit the Commissioner to make any demand he wishes from those who sell insurance.\u201d In particular,<\/p>\n

[T]he Department does not point to any requirement in state law requiring insurers to pursue particular diversity or contracting goals. Undertaking such programs, or reporting on their progress, is not required by \u2018the laws of this state relating to insurance \u2026 .\u2019<\/strong><\/p><\/blockquote>\n

<\/h2>\n

Did We Win?<\/h2>\n

The OAH determined that Minnesota\u2019s Commerce Commissioner was attempting to enforce a policy \u201cas though it were a duly adopted rule.\u201d That order prevents one state\u2019s insurance regulator from enforcing his demand for responses to the MIDS survey (a demand which had already been withdrawn), and it is subject to potential judicial review.<\/p>\n

That doesn\u2019t mean the order isn\u2019t important. The business of insurance has many unique features, but, in many other respects, insurance companies are just businesses. In general, there is no justification in public policy for permitting insurance regulators to govern the ordinary<\/em> aspects of insurance company operations in ways that do not apply to businesses in other industries.\u00a0(To be sure, solvency concerns are a valid basis for some level of intrusive oversight, but only within limits. For example, the commissioners who promulgated the MIDS survey expressly stated that they were \u201cnot <\/em>collecting data that is central to an insurer\u2019s level of solvency.\u201d) The OAH decision clearly supports that simple proposition.<\/p>\n

In the near future, this concept is likely to be tested repeatedly\u2014not just by regulators who wish to enforce their own ideas about corporate governance.\u00a0 It is likely to arise, for example, in connection with such basic business functions as data-based marketing<\/strong>, which some regulators seem to be confusing with data-based underwriting <\/em>or \u201cprice optimization.\u201d\u00a0 When that happens, PCI\u2019s victory in Minnesota will represent a significant precedent.<\/p>\n","protected":false},"excerpt":{"rendered":"

Robert D. Helfand and Barry Leigh Weissman | PropertyCasualtyFocus | January 13, 2017 In Minnesota, the Commissioner of the Department of Commerce regulates the insurance industry, and he has a statutory right to conduct investigations \u201crelated to the duties and responsibilities entrusted to\u201d him. Last month, in\u00a0Matter of the Petition of the Property Casualty Insurers… Continue reading Minnesota Discovers Limits To Its Regulator\u2019s Power Over Insurers<\/span><\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","enabled":false},"version":2}},"categories":[3],"tags":[9895,9904,542,9903],"class_list":["post-891637","post","type-post","status-publish","format-standard","hentry","category-insurance-claims","tag-advise-consult","tag-insurance-industry","tag-minnesota","tag-regulators-power","entry"],"jetpack_publicize_connections":[],"yoast_head":"\nMinnesota Discovers Limits To Its Regulator\u2019s Power Over Insurers - 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