Model Law
A template statute the NAIC drafts for states to adopt as binding law. Unlike a Model Bulletin, it has the force of law once a state legislature adopts it.
A Model Law is a draft statute developed by the NAIC for state legislatures to adopt as state law. Once a state passes it, the Model Law has the full force of law in that state, including penalties for non-compliance. Common insurance Model Laws cover topics such as unfair trade practices, insurance holding companies, and market conduct.
A Model Bulletin travels a different route. The NAIC does not issue it to regulators. It adopts a template, and a state insurance department issues that template under its own letterhead: the AI bulletin’s header reads “TO: All Insurers Licensed to Do Business In (Insert Name of Jurisdiction)” and “FROM: [Department/Commissioner].” The obligations it describes fall on the insurer, under insurance law that already applies, unfair trade practices and unfair discrimination included. Nothing in it is a statute, and a state can put it in force without going to the legislature.
The distinction matters for carriers. A Model Law, once adopted, is a statute that must be followed. A Model Bulletin, while influential, is guidance that may be adopted, modified, or simply used as an examination framework by state regulators. See our guides to the NAIC and the NAIC Model Bulletin.