What Is an NRRA Exempt Commercial Purchaser?

Posted by on Feb 27, 2019 in Uncategorized | No Comments

NRRA Exemption from Diligent Search: Some larger commercial insurance brokers appear to be uncertain about how the Exempt Commercial Purchaser (ECP) feature of the Nonadmitted and Reinsurance Reform Act of 2010 (NRRA), part of the Dodd Frank Act, effective July 21, 2011, works.

Things to Consider When Charging Broker Fees

Posted by on Feb 18, 2019 in Uncategorized | No Comments

A broker fee is a fee in addition to premium and commission that is charged by retail and wholesale insurance brokers and that ultimately is paid by
the insurance buyer. Such fees are subject to two overriding rules: (1) they must be fully disclosed to the insurance buyer and (2) they must be reasonable.

To Fee or Not to Fee… That is the Question!

Posted by on Apr 26, 2018 in Uncategorized | No Comments

Presentation On Broker Fee Considerations

Rebating Laws Should Not Apply to Broker Fee Agreements

Posted by on Nov 20, 2017 in Uncategorized | No Comments

Broker Fee Agreements: A negotiated retail broker agreement is a contract between a retail producer and an insuranace buyer whereby the parties agree to a total package of services for a fee that takes account of the broker’s commission compensation for procuring insurance — as well as for other “value-added” services that may extend beyond the specified terms of the various insurance policies.

Why Regulators Should Dump Anti-Rebating Laws

Posted by on Sep 17, 2017 in Uncategorized | No Comments

Anti-Rebating Laws are Anti-Competitive: For the commercial property and casualty, and employee benefits segments of the insurance industry, anti-rebating laws are both nonsense and anti-consumer. Competition is intended to protect competitiveness in the marketplace, not to protect competitors.

Surplus Lines Regulatory Picture for 2013

Posted by on Jan 10, 2013 in Uncategorized | No Comments

Emerging Surplus Lines Market Risks: State implementation of the Nonadmitted and Reinsurance Reform Act (NRRA), effective July 21, 2011, proceeded relatively smoothly during 2012, albeit with a few hiccups as industry and regulators navigated the transition to home state taxation and regulation of surplus lines transactions.

Surplus Lines: Regulators Vetting of Alien Nonadmitted Insurers

Posted by on Oct 2, 2012 in Uncategorized | No Comments

The NAIC as Gatekeeper for Alien Surplus Lines Insurers: The National Association of Insurance Commissioners (NAIC) is a non-profit entity that acts as the trade association for state insurance commissioners.

Surplus Lines Analysis: Multistate Clearinghouse Economics Don’t Work

Posted by on Feb 27, 2012 in Uncategorized | No Comments

Multistate Clearinghouses for Surplus Lines Premium are Destined for Failure: Recent data from Florida indicate that the economics for a multistate surplus lines tax allocation clearinghouse are unworkable. There simply is not enough multistate surplus lines tax to support the cost of a clearinghouse.

Good Morning NRRA! Home State Scenarios for Affiliated Groups

Posted by on Jul 21, 2011 in Uncategorized | No Comments

Gaming the NRRA to Reduce Surplus Lines Tax: Welcome to the magical mystery tour of Home State taxation and regulation under Nonadmitted Insurance and Reinsurance Reform Act of 2010 (NRRA). The NRRA went live at 12:01 a.m., July 21, 2011, in all time zones. You may have been sleeping.

Surplus Lines Sea Change: Calif.’s AB 315

Posted by on Jun 17, 2011 in Uncategorized | No Comments

NRRA Transition Rules: California is expected to pass surplus lines regulations before July 21, 2011. On that date, the Nonadmitted and Reinsurance Reform Act of 2010 (NRRA) becomes effective, and only the “insured’s home state” may tax surplus lines premium and regulate surplus lines transactions.

Pending State Legislation to Implement NRRA Is Fly in the Ointment

Posted by on May 2, 2011 in Uncategorized | No Comments

California Tries to End-Run NRRA Home State and Other Definitions: Pending state legislative proposals, such as California’s AB 315, that would implement the Nonadmitted and Reinsurance Reform Act of 2010 (NRRA) are akin to the fly in the ointment.

How the California Bill Implements Federal NRRA Surplus Lines Reform

Posted by on Mar 21, 2011 in Uncategorized | No Comments

California Tries to Retain Pre-NRRA Taxing System: The Nonadmitted and Reinsurance Reform Act (NRRA), Subtitle B, Part I, Dodd-Frank Wall Street Reform and Consumer Protection Act, reaches out and touches California on July 21, 2011. In anticipation of its effective date, the California Department of Insurance (CDI) has crafted Assembly Bill No. 315 (AB 315).

NRRA Surplus Lines Requirements: The Devil is in the Details

Posted by on Mar 7, 2011 in Uncategorized | No Comments

Ground Rules for NRRA Compliance: When the Nonadmitted and Reinsurance Reform Act (NRRA), Subtitle B, Part I, Dodd-Frank Wall Street Reform and Consumer Protection Act, takes effect on July 21, 2011, it will represent a sea change for taxation and regulation of surplus lines insurance.

NRRA Compliance Checklist: Prepare Now for Surplus Line Tax Changes and Enjoy Your Summer Vacation

Posted by on Mar 1, 2011 in Uncategorized | No Comments

Initial Compliance with NRRA: The Nonadmitted and Reinsurance Reform Act (NRRA), Subtitle B, Part I, Dodd-Frank Wall Street Reform and Consumer Protection Act, will usher in a new era of premium taxation and regulation for surplus lines insurance.

California Proposes to Disable Itself From Taxing 100% of Surplus Lines Premium

Posted by on Mar 1, 2011 in Uncategorized | No Comments

State Reformulations of NRRA Principal Place of Business Produce Bizarre Results: A California legislator has proposed a surplus lines bill — one effect of which will reduce California’s surplus lines premium tax revenues.

Prepareth Not and Doom Your Summer Vacation

Posted by on Feb 10, 2011 in Uncategorized | No Comments

Initial NRRA Compliance and Related Issues: The Nonadmitted and Reinsurance Reform Act (NRRA), Subtitle B, Part I, Dodd-Frank Wall Street Reform and Consumer Protection Act, will usher in a new era of premium taxation and regulation for surplus lines insurance on July 21, 2011, a convenient Thursday shortly after the Fourth of July.

Much State Regulatory Ado About Little

Posted by on Jan 24, 2011 in Uncategorized | No Comments

Economic Fallacy of Multistate Taxation: As of July 21, 2011, the Nonadmitted and Reinsurance Reform Act (NRRA), also known as Subtitle B of the Dodd-Frank Wall Street Reform and Consumer Protection Act, reshapes the landscape for state taxation of surplus lines insurance premium.

Multi-State Surplus Lines Tax

Posted by on Jan 10, 2011 in Uncategorized | No Comments

The States Drop the Ball: The States appear poised, through inaction, to leave untold millions of dollars in premium tax revenue “on the table” when the Nonadmitted Insurance and Reinsurance Reform Act (NRRA) becomes the law of the land on July 21, 2011.