FACC Oregon Comment Letter 3-14-24

While in general FACC applauds the Division’s present efforts to adopt permanent rules implementing SB 536, and we appreciate the Division is proposing for the most part to adopt disclosure forms specified in the NAIC model regulation, we must take exception to the Division’s latest proposal to deviate from NAIC model forms by inclusion of non-conforming and confusing questions concerning duty of care. For reasons explained herein, we oppose such deviations from NAIC model forms and respectfully ask the Division to reconsider and remove those questions from the proposed forms.