Vt. Stat. tit. 8 § 3570
In the absence of actual malice, members of the National Association of Insurance Commissioners, their duly authorized committees, subcommittees, and task forces, their delegates, National Association of Insurance Commissioners' employees, and all others charged with the responsibility of collecting, reviewing, analyzing, and disseminating the information developed from the filing of the annual statement convention blanks shall be acting as agents of the Commissioner under the authority of this act and shall not be subject to civil liability for libel, slander, or any other cause of action by virtue of their collection, review, and analysis or dissemination of the data and information collected from the filings required hereunder. The immunity conferred by this section shall not apply if the Commissioner, in his or her sole discretion, determines that the National Association of Insurance Commissioners has substantially failed to comply with the provisions of section 3551 of this title, or has imposed fees, assessments, or charges in excess of those provided in section 3552 of this title.
8 V.S.A. § 3570