Articles by Richard A. Brown and Jeffrey M. Klein

Brown is an insurance regulatory attorney who regularly represents surplus lines insurers, surplus lines brokers, and industry organizations in a variety of regulatory and other surplus lines matters. He has authored multiple articles about the NRRA and its implementation. E-mail: RAB@InsuRegulatory.com. Copies of his other NRRA articles are available at: www.InsuRegulatory.com.
Klein is of counsel to the Washington

What Is an NRRA Exempt Commercial Purchaser?

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. For sales …

Rebating Laws Should Not Apply to 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 …

Why States Should Drop Insurance Anti-Rebating Laws: Viewpoint

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. Producers need to be able to …

Why Regulators Should Dump Anti-Rebating Laws

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. Producers need to be able to …

Surplus Lines Regulatory Picture for 2013

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 …

Surplus Lines Regulatory Picture for 2013

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 …

Surplus Lines: Regulators Vetting of Alien Nonadmitted Insurers

The National Association of Insurance Commissioners (NAIC) is a non-profit entity that acts as the trade association for state insurance commissioners. Although the NAIC may play a central role in regulation of the insurance industry, it nonetheless is a private …

Surplus Lines Sea Change: Calif.’s AB 315

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 …

Pending State Legislation to Implement NRRA Is Fly in the Ointment

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. The NRRA becomes effective on July 21, 2011, which also is …

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

Editor’s Note: This is the first of a two-part article on compliance with the Nonadmitted and Reinsurance Reform Act. The Nonadmitted and Reinsurance Reform Act (NRRA), Subtitle B, Part I, Dodd-Frank Wall Street Reform and Consumer Protection Act, will usher …