No.

J. Richard Barnes, C.L.U. Commissioner of Insurance 106 State Office Building Denver, CO 80203

Dear Commissioner Barnes:

On behalf of the Insurance Board (the "board"), you ask whether the board can legally amend Insurance Division regulation 72-3 (relative to the business of title insurance) to prohibit title insurance producers (generally, real estate developers or lenders or their representatives) from having virtually any financial interest in title entities (title insurers or agents) in certain situations.

The text of the board's proposed amendment to the title insurance regulation is…