Archived NAPSLO NRRA Guiding Principles, Position Papers, Articles, and Letters
NAPSLO Compact Position Paper - NAPSLO issued a paper in February 2011 stating its opposition to any tax compact that reduces uniformity or that increases the reporting burden on purchasers of non-admitted insurance or the brokers that serve them.
NAPSLO Allocation Methodology Paper - NAPSLO issued a paper outlining the reason that it opposes allocating multi-state casualty premium tax and its position on tax allocation methods in general.
Coalition Letter to SLIMPACT States Supporting Kentucky Allocation Formula - In August 2011 NAPSLO joined five other industry trade groups in writing representatives of the Surplus Lines Multistate Compliance Compact Commission to recommend that they adopt an allocation methodology proposed by the Kentucky Department of Insurance.
Coalition Letter to NIMA States Supporting Kentucky Compromise - 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").
NAPSLO Talking Points for NIMA States Meeting - NAPSLO representatives met with representatives of the NIMA states on November 4, 2011 to provide comments on state approaches to tax allocation.
NAPSLO Comment Letter to Federal Insurance Office - NAPSLO submitted a response on December 16, 2011 to the Federal Insurance Office (FIO) request for comment for "Public Input on the Report to Congress on How to Modernize and Improve the System of Insurance Regulation in the United States."
Article on Allocation - Surplus Lines lawyer Richard Brown wrote in the Insurance Journal that Multi-State Surplus Lines Tax State Inaction Risks Loss of Premium Tax Revenue.
NIMA Agreement Analysis - Surplus Lines lawyer Richard Brown wrote a paper on NIMA stating that NIMA and the Clearinghouse would impose intolerable compliance costs on surplus lines brokers and increase the cost of insurance with no benefit to surplus lines insurance buyers or measurable benefit to Participating States treasuries.
NCOIL - NCSL - CSG Letters - The National Conference of Insurance Legislators (NCOIL), the Council of State Governments (CSG) and the National Conference of State Legislatures (NCSL) sent an open letter to Congress asking that implementation of the surplus lines section of the Nonadmitted and Reinsurance Reform Act be delayed one year until July 21, 2012.
Video of NAPSLO Testimony - NAPSLO representatives testified before the Senate Banking Committee in July 2008 on the NRRA and in 2011 before the House Committee on Financial Services on the implementation of the NRRA.
CSG Rick Masters' Memo on NIMA - In January 2011, Rick Masters, Special Counsel for Interstate Compact at the Council of State Governments released a memorandum questioning the Nonadmitted Insurance Multistate Agreement (NIMA) tax compact, saying that "NIMA fails to provide any substantial or enforceable mechanism for achieving uniformity because it fails to provide a binding agreement which pre-empts other state laws in conflict with its requirements.
Congressman Moore's Clarifying Statement on NRRA - On July 22, 2010, Rep. Dennis Moore (D-Kan.) the main sponsor of the Nonadmitted Reinsurance and Reform Act (NRRA), which was included in the financial services reform legislation recently signed into law, clarified the intent and meaning of the legislation through remarks entered into the Congressional Record.
NRRA Myths vs. Facts - NAPSLO produced a paper on the Myths vs. Facts on the Nonadmitted and Reinsurance Reform Act (NRRA) implementation legislation.
Other Legislative/Regulatory Positions
.NAPSLO Legislative Updates