Vermont lawmakers are considering legislation that would revise captive insurance regulations for risk retention groups and protected cells, while a companion bill addresses broader financial services requirements.
House Bill 649 would bar risk retention groups from making loans to or investing in their parent companies, members or affiliates of those parents. The restriction would not apply to loans or investments already in place as of Jan. 1.
The measure also updates reporting obligations for risk retention groups, requiring them to file annual statement convention blanks, signed jurat pages and actuarial certifications with the National Association of Insurance Commissioners. Risk retention groups would additionally need to submit quarterly statements to the NAIC.
Under the bill, protected cells would be required to certify they have sufficient funding to begin operations. Those certifications would need to be filed with the Vermont insurance commissioner within 30 days of a protected cell starting business.
The bill's provisions would take effect July 1 if passed. The commissioner would have authority to determine what additional filings are required from risk retention groups.
A separate measure, House Bill 648, covers a range of financial services and banking provisions. The legislation includes a cybersecurity requirement for investment advisers and technical changes to licensing rules.
H 648 would permit stock insurers that are subsidiaries of mutual insurance holding companies to include the word "mutual" in their names, provided the name also contains an "SI" designation for stock insurer. The bill also shifts reporting processes to electronic systems maintained by the NAIC.
Vermont's captive insurance sector has drawn legislative attention as regulators work to align state rules with industry standards and reporting frameworks.
The new bills also follow earlier regulatory updates approved in 2025. Governor Phil Scott signed H.137 into law last year as the Department of Financial Regulation's housekeeping bill, developed with input from the Vermont Captive Insurance Association.
