NAPSLO NRRA Compliance Resources

 

   

 

  

(click on maps for larger PDF copy)

 

NIMA - NIMA was intended to provide a mechanism to report, collect, allocate and distribute surplus lines tax revenues consistent with the Nonadmitted and Reinsurance Reform Act (NRRA). The NRRA is part of the Dodd-Frank Wall Street Reform legislation passed in 2010 that allows only the home state of the insured to require premium tax payments for non-admitted insurance in the absence of an agreement among states. NIMA will allow participating states to continue to collect surplus lines premium taxes according to state laws consistent with the agreement.

 

In 2011, 11 states and Puerto Rico joined NIMA; however in early 2012 Nebraska withdrew from NIMA. The original NIMA agreement is available to download.

 

SLIMPACT - The Surplus Lines Insurance Multistate Compliance Compact was intended to clarify the law and ease the regulatory burdens on E&S brokers when placing multistate risks, and allow each compacting state to collect taxes on all nonadmitted risks where risk exposures are present in the compacting state(s). SLIMPACT could begin establishing operations once 10 states had agreed to be compacting or contracting states. As of early 2012 nine states had joined SLIMPACT. The original agreement is available to view.

 

NAIC Report on Implementation- In December 2010, the NAIC released a report on compact implementation to states considering joining the Nonadmitted Insurance Multi-State Agreement and updating laws and regulations to conform to the Nonadmitted and Reinsurance Reform Act of 2010.

 

NIMA Access Agreement - The NAIC released the Nonadmitted Insurance Premium Tax Clearing House Access Agreement.

 

Kentucky Allocation Proposal - A proposal by the Kentucky Department of Insurance on how to allocate surplus lines premium taxes. In October 2011 NAPSLO joined nine other industry trade groups in writing representatives of states who are part of the Nonadmitted Insurance Multi-State Agreement ("NIMA States") to recommend their adoption of the allocation methodology proposed by the Kentucky Department of Insurance ("Kentucky compromise").

 

Emergency Amendment to NIMA - On December 20, 2011, the participating states in the Nonadmitted Insurance Multistate Agreement (NIMA) adopted an emergency amendment, deferring the effective date of the multi-state premium-tax allocation pursuant to NIMA until the calendar quarter beginning on July 1, 2012. A number of states have issued state specific guidance to handle the change and new notices are posted on NAPSLO's blog.

 

NIMA Website - The Florida Office of Insurance Regulation is hosting the NIMA website, which provides information on agreement and the states involved in NIMA.

 

Broker Protocol - At the request of NAPSLO, in 2011 the law firm of Dewey & LeBoeuf LLP developed a general "Broker Protocol" on regulatory compliance around the United States once the reforms outlined in the Nonadmitted and Reinsurance Reform Act (NRRA) are in place.

 

California Webinar - Webinar produced by the Surplus Lines Association of California - Changes to State Regulation: The Effect on Brokers and Their Surplus Lines Filings with the Surplus Lines Association of California.

 

Florida Webinar - Webinar by the Florida Surplus Lines Service Office - Understanding the NRRA: What Agents Should Know and How to Be Prepared.

 

Florida FAQ - The Florida Surplus Lines Lines Service Office's NRRA page has a series of FAQs dealing with Home State, filing, and compliance.

Florida OIR Report - The Florida Office of Insurance Regulation released a report on Dec. 30, 2011 on the state's cooperative reciprocal agreement. The report reviewed the state's involvement in NIMA and various financial and administrative information.

NAIC Quarterly Listing of Alien Insurers - Because the Quarterly Listing of Alien Insurers has become the authoritative regulatory source for the eligibility of non-U.S. insurers pursuant to the Nonadmitted Insurance title of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the National Association of Insurance Commissioners (NAIC) is now making this list of insurers available to the public. The listing provides brokers, exempt commercial purchasers, and insureds with assurance as to the eligibility of non-U.S. insurers with which excess and surplus lines insurance business is being quoted or placed. The public Quarterly Listing of Alien Insurers is now available for download on the NAIC website.