[brief] Bulletin No. 22-11 reminds the regulated industry that, among other regulatory requirements, the Holding Company Act and SSAP No. 25 apply to reciprocal exchanges.  [...] also misstates the Department’s history of interpreting all three sources of law.  The Holding Company Act is a comprehensive law that regulates an insurance company system, defined as two or more affiliated persons, one or more of which is an insurer.  SSAP No. 25 is a Statutory Accounting Principle that requires related-party transactions to be arm’s-length and fair and reasonable to the regulated entity, which is foundational to the protection of insurance consumers.  [...] clearly admits that it is a related party to the Exchange, as it exercises control over and makes decisions on behalf of the Exchange.  However, for what appears to be its own direct financial gain, [...] objects to regulatory supervision of changes in control because it is displeased with being required to conduct related-party transactions at arm’s length and in a manner that is fair and reasonable to the Exchange’s policyholders.  [...] characterizes Bulletin No. 22-11 as rulemaking subject to the notice-and-comment procedure of the Administrative Procedure Act.  Its characterization is wrong for two reasons.  First, the applicability of both the Holding Company Act and SSAP No. 25 to reciprocal exchanges is clearly inferable from both the statute and the SSAP.  Second, Bulletin No. 22-11 does not represent a change in law or practice by the Department.  The Department has applied the Holding Company Act in prior changes of control, including the Acquisition of Control of [...] [“[...]”] and [...] [“[...]”], which were related parties to [...].  In fact, [...] and [...] were both owned by [...] and [...].  Further, SSAP No. 25 has applied to reciprocal exchanges since its inception in 2001.  [...]’s reliance on proposed legislation that would amend the Reciprocal Exchange Act to provide the result it seeks is misplaced.  Proposed legislation is not an expression of legislative intent and carries no weight under law; in this instance, it simply reflects the intent of two members of the Legislature who introduced an identical bill in the Senate and the General Assembly.  To say that introduction of a bill by two legislators represents the will of the Legislature as a whole turns the concept of legislative intent on its head.  Additionally, the proposed legislation was introduced shortly after this appeal was filed, and it has not progressed past introduction in either the Senate or General Assembly.  And finally, Bulletin No. 22-11 does not impair any right to contract, retroactively or otherwise.  The terms of the Power of Attorney that subscribers sign will be unaffected by the outcome of this appeal.  In fact, reminding reciprocal exchanges and attorneys-in-fact that SSAP No. 25 requires that transactions involving services between related parties must be on an arm’s-length basis and meet fair and reasonable standards only reinforces the terms of the Power of Attorney: in that the payment by the Exchange is not automatically 12.5%, and instead is an amount not to exceed 12.5%.  Therefore, there is no impairment of contract.  For these reasons, this court should affirm the Department’s issuance of Bulletin No. 22-11.  PROCEDURAL HISTORY AND COUNTERSTATEMENT OF FACTS