In July, we reported on a California Department of Insurance directive requiring insurance companies to divest themselves of investments in Iran. Recently, the California Office of Administrative Law reviewed the DOI’s rules and determined that the challenged directive met the definition of a “regulation” pursuant to California Government Code § 11342.600. Accordingly, the directive should have been, but was not, adopted pursuant to the Administrative Procedures Act. Thus, the OAL concluded that the directive as issued was invalid. The American Council of Life Insurers, 2010 OAL Determination No. 21 (Oct. 11, 2010).