Wirelessly posted (BlackBerry: BlackBerry8530/5.0.0.1030 Profile/MIDP-2.1 Configuration/CLDC-1.1 VendorID/417)

"Credit card CDW is not (AFAIK) a regulated product and is subject to the whim and goodwill of the carrier, and they're of course incentivized to pay out as little as possible, whereas there are laws and/or case law in many states obligating traditional auto insurance providers to cover rental cars."

I think you've got this backwards: When you buy the LDW from a car-rental company, you are buying an un-regulated product. The car-rental companies make it very clear that LDW is not insurance.

On the other hand, the car-rental insurance coverage provided by credit cards is insurance, issued through a policy purchased by the credit-card company. So that policy should be subject to regulation by the state where the policy was issued.

With respect to the car-rental coverage provided by non-owned auto policies issued in New York State, I believe that New York State requires that all auto-liability policies cover loss or damage to cars rented by the policyholder. I'm not sure if any other state has such a requirement.