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Proposed Rules and Public Comment

Proposed Rule Filings


Update | Approved January 4, 2024, by the Legislative Committee on Administrative Rules

Title of Rule | Suitability in Annuity Transactions (Reg. I-2023-01) 

Brief Summary of Rule | The Department is proposing a new rule that requires producers, as defined in the rule, to act in the best interest of the consumer when making a recommendation of an annuity and to require insurers to establish and maintain a system to supervise recommendations so that the insurance needs and financial objectives of consumers at the time of the transaction are effectively addressed.

Public Comment Period Ended | November 14, 2023

  • Final Filing
    • Adopted Filing - Coversheet
    • Adopting Page
    • Clean text of the new rule
    • A letter addressing changes to the final proposed rule (which were discussed at the LCAR meeting)
    • LCAR Approval letter of January 4, 2024

Public Meeting Notices


Public Hearing Notice | Plan of Conversion of Granite Mutual Insurance Company

Brief Summary | The Department has scheduled a virtual public meeting to consider the Plan of Conversion for the demutualization of Granite Mutual Insurance Company pursuant to 8 V.S.A. § 3423. 

Date | Tuesday, November 28, 2023

Time | 11 a.m.

Access | The meeting is being held virtually; please use the below information to attend by mobile device, laptop, computer, another device or phone.

Microsoft Teams Meeting

  • Call In (audio only)
    • +1 802-828-7667, 341643909#
    • United States | Montpelier, VT

Public Meeting Update | Uniform Prior Authorization Form Held October 10, 2023

Brief Summary | In 2013, the Vermont legislature passed Act 171 that amended 18 V.S.A. § 9418b to include requirements for the development of a uniform prior authorization (PA) form to standardize prior authorization requests for prescription drugs, medical procedures (to include both physical and mental health conditions), and medical tests required by Vermont health insurers and Medicaid (Department of Health Access). The uniform prior authorization form for medical service requests was finalized by September 1, 2013, as required. Now, after having conferred with all stakeholders, the Department is scheduling a public meeting to obtain input on the proposed form revisions. 

  • Public Hearing Was Held: 1 pm on Tuesday, October 10, 2023
  • Recording of Public Hearing: View on DFR YouTube Channel

Contact for Public Comments, Questions | DFR Assistant General Counsel E. Sebastian Arduengo (

BCBSVT & BCBSM Proposed Affiliation Approved

Commissioner Gaffney signs orders.

On October 9, 2023, Commissioner Kevin Gaffney signed two orders regarding the proposed affiliation. On October 10, the Department issued both orders.
Questions? Write to DFR Assistant General Counsel Hillary Borcherding at Vermont Department of Financial Regulation, 89 Main Street, Montpelier, VT 05620-3101 or email her at


Background, Filings and Supporting Documentation

Background on Proposed Affiliation Between Blue Cross and Blue Shield of Vermont and Blue Cross Blue Shield of Michigan Mutual Insurance Company

Blue Cross and Blue Shield of Vermont (BCBSVT) and Blue Cross and Blue Shield of Michigan Mutual Insurance Company (BCBSM) have applied to the Department of Financial Regulation for Department approval of their proposed affiliation. The proposed affiliation is pursuant to the terms of a Principal Transaction Agreement, dated as of April 28, 2023 (the Agreement), by and between BCBSM and BCBSVT. If the proposed transaction is approved and successfully completed, BCBSM will become the sole member of BCBSVT with the right to approve all members of the Board of Directors of BCBSVT. 

Specifically, in connection with the proposed affiliation, the BCBSVT Board will be reconstituted to consist of a total of twelve (12) directors, comprised of: 

  • five (5) individuals appointed by the applicant; and 
  • seven (7) individuals nominated by the BCBSVT Board.

As a result of the proposed affiliation, BCBSM may be deemed to be the ultimate controlling person of BCBSVT and the Vermont Health Plan, LLC.

The proposed affiliation is subject to multiple sections of the Insurance Laws and Regulation of the State of Vermont. These include the following chapters and subchapters of Title 8: Subchapter 13 of Chapter 101 (Holding Companies and Subsidiaries), Chapters 123 (Nonprofit Hospital Service Corporations), 125 (Nonprofit Medical Service Corporations) and Chapter 139 (Health Maintenance Organization).

Filings and Documentation