Relating to the use of a consumer's credit score in the underwriting or rating of certain personal lines property and casualty insurance policies.

Contracts

• Data Vendor MSAs: You must immediately renegotiate Master Service Agreements with credit data providers (e.g., LexisNexis, Verisk). Your API call volume will increase significantly due to the mandatory 36-month review and on-demand requests. Secure volume-based pricing tiers now to mitigate cost spikes.
• Agency Agreements: Update guidelines to authorize agents to submit re-rating requests on behalf of insureds during the renewal window.

Hiring/Training

• Agent Training: Front-line staff and independent agents must be trained on the new "Right to Request" protocol. They must know *when* a consumer can ask for this (at renewal) and that it is limited to once every 12 months.
• Underwriting Staff: Train staff on the new "Freshness Rule." Adverse actions cannot be taken based on credit data older than 90 days.

Reporting & Record-Keeping

• Adverse Action Notices: Revise standard notification templates immediately. You must insert language informing the applicant/insured of their statutory right to request re-underwriting and re-rating.
• Audit Trails: Implement digital logging to prove:
• 1. The credit report used for any adverse action was <90 days old.
• 2. The mandatory 36-month review was conducted.
• 3. Consumer requests for re-rating were honored.

Fees & Costs

• Data Acquisition Costs: Expect a direct increase in operational expenses due to the higher frequency of credit report pulls.
• IT Development: Budget immediately for updates to policy administration systems to automate the 36-month trigger and the 90-day "hard stop" on stale data.