Insurance Privacy Legislation Seeks to Layer Additional Privacy Obligations on Title Insurers

Senate Bill 354 (Limon), the Insurance Consumer Privacy Protection Act of 2025 (ICPPA) has passed the Senate Judiciary Committee and is pending in the Senate Appropriations Committee where it has been placed on the commmittee’s “suspense” file, which acts as an additional review for legislation expected to impose costs to the state above a certain threshold.

The CLTA is opposed to the measure unless it is amended to continue the exemption for title insurance under the existing Insurance Information and Privacy Protection Act, given that the title industry’s use of personal and publicly available information differs substantially from that of other lines of insurance, and the title industry is already subject to extensive privacy laws and regulations. The proposed CLTA amendment would exempt a title company provided that it does not sell a consumer’s personal information.