Volume 42 | October 2025

Vermont Department of Financial Regulation

Industry News

Open Enrollment Starts Despite Shutdown

October 15 marked the start of Medicare Open Enrollment (also known as the Annual Election Period), which this year began during a government shutdown. Still, the Centers for Medicare & Medicaid Services (CMS) notes that its "mission-critical activities" will continue. Many Medicare services remain available; people can use 1-800-MEDICARE for enrollment assistance and Medicare.gov for researching plans. The 2025 Medicare Open Enrollment Fact Sheet contains useful informaton and identifies what's new for 2025: "All Medicare plans will include a $2,000 cap on what you pay out of pocket for covered prescription drugs. The cap only applies to drugs that are covered by your plan, so it’s more important than ever to review your plan options to make sure your drugs are covered." The CMS also announced "that average premiums, benefits, and plan choices for Medicare Advantage (MA) and the Medicare Part D prescription drug program are expected to remain stable in 2026." And while the government might be shut down, the Federal Trade Commission reminds everyone that scammers never take a day off and warns consumers about the uptick in Medicare scams during this period (October 15-December 7) and ways to protect themselves against them.

Vermont Again Among Int'l Domicile Nominees

Vermont ranks among the six nominees recently announced in the 2025 shortlist just released by The Captive Review European Awards committee. The other nominees for International Domicile

include Bermuda, Hong Kong, Cayman Islands, Oklahoma and the State of Hawaii. Held annually as the counterpart to The Captive Review United States Awards, the Captive Review European Awards "recognize the top providers and professionals of captive insurance products and services in the European captive insurance market." Market industry "innovators, creative minds and customer service pros who have outperformed their competitors and demonstrated the highest levels of excellence over the past 12 months" are nominated by peers for the awards. Nominations closed September 5, and the shortlist was announced on September 16. Winners are announced at an evening awards ceremony on the evening before the European Captive Forum on November 5-6 in Luxembourg. The captive insurance market has seen significant growth, with a projected increase in market value from $150.41 billion in 2023 to $159.15 billion in 2024. "This growth is expected to continue, reaching $250 billion by 2032, representing a compound annual growth rate (CAGR) of 5.81%. The market's expansion is driven by factors such as rising insurance costs, the need for more control over insurance coverage, and the increasing role of captives in modern risk management and insurance cost control strategies for large and mid-sized enterprises.

Two October Campaigns That Focus on Safety


October and America's "Longest Running Public Health & Safety Observance" | More than a century of promoting fire safety, the National Fire Protection Association® continues to sponsor National Fire Prevention Week™ with this year's campaign focused on the hazards posed by lithium-ion batteries. With the theme “Charge into Fire Safety™: Lithium-Ion Batteries in Your Home”, NFPW™ this year promoted three key safety actions: Buy, Charge and Recycle. The NFPA® has been the official sponsor of Fire Prevention Week™ since 1922, when it began commemorating the Great Chicago Fire of 1871. The conflagration started on the evening of October 8 and was finally snuffed out by rain 24-plus hours later. More than 250 lost their lives; nearly 3.3 square miles of the city including over 17,000 structures were destroyed, and greater than 100,000 residents were left homeless. The week became a national observance in 1925 when President Calvin Coolidge signed Proclamation 1746—National Fire Prevention Week, 1925, which noted costs of fires and the need to study preventative measures. The first observance was October 4-10, 1925. This year's NFPW™ was October 5th through the 11th; however, the week expanded into a month-long effort to educate the public on fire safety. The NFPA provides various resources including videos for kids, tip sheets like what's shown above and more.


Cybersecurity Awareness Month is 21 years old. Launched October 2004 by the National Cyber Security Alliance and the U.S. Department of Homeland Security, CSAM raises awareness about the importance of online safety, the perils of cybercrime and the importance of preventative measures to safeguard against cyberattacks. This year’s official theme "Building a Cyber Strong America" highlights the need to strengthen the country's infrastructure against cyber threats to ensure resilience and security. The campaign goal: To educate people about online risks and threats and encourage actions to improve cybersecurity. Now promoted annually by Cybersecurity & Infrastructure Security Agency, the nation's cyber defense agency, CSAM2025 focuses on "empowering individuals and organizations to take proactive steps to protect against cyber threats. Key actions include using strong passwords, enabling multi-factor authentication, recognizing scams and keeping software updated." These safeguards also help safeguard against identity theft, extra important given the rise in cybercrime and cyberattacks, which are evolving faster than the defenses.

Another Win for World Investor Week - Oct 6-12


IOSCO reports another successful World Investor Week with more than 100 jurisdictions participating in the week-long public education and awareness campaign. Created in 1983, the International Organization of Securities Commission has promoted WIW since 2017 as part of its core mission to enhance investor protections, educate investors and safeguard the integrity of securities markets. This year's campaign focused on technology and digital finance, artificial intelligence and fraud and scam prevention; it also addressed crypto assets and the basics of investing, all of which are invaluable throughout the year. "As the global standard-setter for financial market regulation, IOSCO views investor education as a critical component of safeguarding the integrity of securities markets. [Its] membership regulates more than 95% of the world's securities markets in more than 130 jurisdictions."

DFR Orders, Regulations and Bulletins

ORDERS


Docket No. 25-018-S

10/09/2025

Stipulation and Consent Order In re: Edward D. Jones & Co., L.P. (CRD #250)


Docket No. 25-015-I

10/09/2025

Stipulation and Consent Order In re: Progressive Direct Insurance Company NAIC #16322


Docket No. 19-045-S

10/06/2025

Second Amendment to Order: Clearwater Investment Trust


Docket No. 25-014-I

09/24/2025

Order Approving the Proposed Acquisition of ProAssurance et al by The Doctors Company


View all orders.

REGULATIONS


Reg. I-1971-02 (Revised)

09/20/2025

Rule I-1971-02 Insurance Holding Company Systems


View all regulations.


BULLETINS


Insurance Bulletin #239

10/07/2025

Firefighters’ Workers’ Compensation Data Call


Insurance Bulletin #238 

10/072025

Coverage for Vaccines


Insurance Bulletin #237

10/03/2025

Application of Act 55 of 2025


View all bulletins.

Lots of Interest in DFR Intership Program Uncovered at UVM Fall Job & Internship Fair

DFR Executive Director Mary Richter (l) and Captive Insurance Division Examiner Amber Walsh stop for a photo while participating in the October 8 University of Vermont Fall Job & Internship Fair held at the Davis Center. It was open to all majors and timed to accommodate class schedules.

Industry News Digest

Crypto Crime Scene: How the Companies Behind Crypto ATMs Profit as Americans Lose Million to Scams - CNN 10.14.25

"The victims were led to the Arizona convenience store by an increasingly familiar scam: Crooks had tricked them into believing they were in legal trouble, their bank accounts were hacked or that they had to pay off debts. To fix the "crisis," they were told to feed cash into the crypto ATM – where it was promptly routed to scammers' accounts. This crime wave was no secret. Local police knew all about it. But they were all but powerless to stop the scammers. And what truly frustrates investigators is that US companies, which own and operate crypto ATMs around the country, profit from the fraud while doing too little to help stop it. Prosecutors have likened the machines to a 'getaway vehicle' exploited by thieves to quickly escape with the money. A CNN investigation, which included a review of more than 700 criminal cases and complaints, has found that crypto ATM companies make money by often marking up the price of cryptocurrency by 20% to 30% or more on transactions, including the illicit ones. Despite public claims, they often fail to refund money to victims and aggressively fight police to claw back scam money seized from machines."

Vermont's Medicare Advantage Market Has Collapsed. Here's What You Need to Know. - Vermont Compass 10.14.25

"The collapse was caused by two forces colliding: the financial instability of Vermont’s largest insurer and a shifting national landscape that is making Medicare Advantage less profitable everywhere. | For more than 33,800 Vermont seniors, the healthcare landscape is about to change dramatically. In a move that effectively ends the individual Medicare Advantage (MA) market in the state, Blue Cross Blue Shield of Vermont and UnitedHealthcare are withdrawing nearly all their plans for 2026. This decision leaves thousands of Vermonters scrambling to understand their options and facing the prospect of significantly higher costs. This isn’t just a corporate decision; it’s the result of a perfect storm of local financial crisis and national regulatory pressure. The core issue is that the two main providers of individual Medicare Advantage plans are leaving the market."

AI Policy Already Exists, We Just Don’t Call It That: Generally Applicable Law and New Technology - Cato Institute 10.13.25

"Recent debates around a potential moratorium on state-level artificial intelligence (AI) laws have raised questions about what might happen without federal action on AI. Opponents of the moratorium often express concerns about what might happen if there is a gap between such a moratorium and the establishment of a federal AI framework. However, many concerns about discrimination, fraud, or other abuses have existing legal frameworks, which means the legal and regulatory environment in which a new technology like AI operates is far from the Wild West, particularly in many already regulated industries. How might generally applicable law play out when it comes to AI, and what does this mean both for laws that might be preempted and for the concerns that might already be resolved? ... Generative AI has been around for only a few years, but it has already impacted nearly every aspect of our lives. Its role as an evolutionary technology augmenting the productivity of our work means that even industry-specific laws can be generally applicable when it comes to AI. A prime example of this is in FINRA’s (Financial Industry Regulatory Authority) Regulatory Notice 24–0[CG1] 9. This notice did not introduce any new regulatory obligations but simply referred member firms back to the tech-neutral, industry-specific regulations that govern its member firms’ behavior in a highly competitive environment."

Vermont Blue Advantage Will Not Sell Plans at All in 2026 - VTDigger 10.13.25

"The Medicare Advantage plans sold by Blue Cross Blue Shield of Vermont will not be available for employers who provide retiree benefits or on the individual market. | Vermont Blue Advantage will no longer offer any Medicare Advantage plans in the state for 2026. On October 1, Blue Cross Blue Shield of Vermont announced Vermont Blue Advantage would not continue coverage for the 26,000 people in the state on its individual Medicare Advantage plans for next year. The company is also ending all existing employer-sponsored retiree plans. Whether the company will return to Vermont’s insurance landscape in the future, 'depends on whether market conditions improve, or new opportunities open that would enable Vermont Blue Advantage to offer sustainable and competitive plans,' Andrew Garland, a vice president and spokesperson for the insurer, told VTDigger. Vermont Blue Advantage has provided Medicare Advantage coverage for the state’s 7,000 retired teachers, but that contract was not renewed for 2026, the Office of the State Treasurer announced in September. The shift was unplanned but necessary after Vermont Blue Advantage proposed a 50% premium increase in July, according to Treasurer Mike Pieciak. Two other smaller employers also coordinated coverage for their retirees through Vermont Blue Advantage plans, Kaj Samsom, the state’s commissioner of the Department of Financial Regulation, confirmed. Those employers are also losing that option in 2026."

AARP Joins Suit Against TIAA Alleging Mismanagement of Retirement Funds - Plan Sponsor 09.04.25

"The amended complaint adds additional claims and names two more former TIAA employees as plaintiffs. wo former TIAA employees yesterday filed an amended complaint claiming the company violated the Employee Retirement Income Security Act by investing more than 28,000 plan participants’ retirement funds in a proprietary in-house fund that has failed to meet its market benchmark since 2009. Attorneys from the AARP Foundation joined the complaint as co-counsel on behalf of older adults enrolled in retirement plans offered by TIAA to its plan participants, according to a statement from AARP. The original complaint, filed on May 20 by former TIAA employee Bryan Byrne, alleged TIAA breached its fiduciary duties under ERISA by opting for high-cost investment options in the plan’s investment menu, despite cheaper alternatives, and by not removing its underperforming College Retirement Equities Growth Fund from the plan. The complaint and the amended complaint are pending in U.S. District Court for the Southern District of New York."


FTC Consumer Alerts: Charity and Medicare Scams

Kars-R-Us.com and its operators raised millions but only a fraction of donations went to fund breast cancer screenings, FTC and states alleges. The Federal Trade Commission, along with 22 agencies from 19 states, stopped a deceptive charity fundraising scheme and its operators who made false or deceptive claims to U.S. donors. Kars-R-Us.com, Inc. (Kars) and its operators, Michael Irwin and Lisa Frank, solicited charitable donations nationwide on behalf of United Breast Cancer Foundation, Inc. (UBCF), a charity that claims to assist individuals affected by breast cancer, according to a complaint filed by the FTC and states.


This Medicare Open Enrollment Season, Learn How to Protect Yourself From Scams

Every year, scammers get more active around Medicare Open Enrollment Period, trying to get your money, information, or both. As you consider your health coverage and prescription options during this period (October 15-December 7), learn to spot the scams.


Who’s Eligible for a Refund from Amazon?

You might have heard that, last week, Amazon agreed to pay $2.5 billion to settle the FTC’s charges that it enrolled millions of people in Prime subscriptions without their consent – and then made it hard for those unwilling Prime subscribers to cancel. Since $1.5 billion of that amount goes back to consumers, you might be wondering: who gets it? How? And what do I need to do?

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