If there is doubt, the Department should incorporate the above language for consistency purposes and avoid creating unnecessary civil action exposure for agents and agencies operating in Illinois.
FACC opposes the proposed regulation which we believe is unnecessary, redundant, and potentially confusing. While many states – 28 to date – have adopted the NAIC model regulation through rulemaking or legislation, none has seen the need to adopt a regulation similar to the one proposed here. The reason is
Government requests delay in briefing and argument schedule for FACC v. DOL. ELECTRONIC ORDER granting the  Joint Motion to Amend Case Schedule and modifying the current scheduling order  to set the following deadlines: November 7, 2022: Plaintiffs’ combined reply in support of their summary judgment motion and opposition