Articles by Richard Brown and Jeffrey M. Klein

Klein is of counsel to the Washington

Things to Consider When Charging Broker Fees

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 …

Surplus Lines: Regulators Vetting of Alien Nonadmitted Insurers

The National Association of Insurance Commissioners (NAIC) acts as the trade association for state insurance commissioners. The Nonadmitted and Reinsurance Reform Act of 2010 (NRRA) delegated to the NAIC responsibility for determining whether an alien insurer (i.e., an insurer domiciled …

Surplus Lines’ Multistate Clearinghouse Numbers Don’t Work

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. This is not new information. (See …

Surplus Lines Analysis: Multistate Clearinghouse Economics Don’t Work

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. This is not new information. (See …

Good Morning NRRA! Home State Scenarios for Affiliated Groups

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 …

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 …

Commentary: 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 …

How California Bill Implements Federal NRRA Surplus Lines Reform

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) …

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

A California legislator has proposed a surplus lines bill — one effect of which will reduce California’s surplus lines premium tax revenues. On Feb. 9, 2011, California Assembly Member Solario introduced Assembly Bill No. 315 (AB 315), the California Department …

Prepareth Not and Doom Your Summer Vacation

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 …