Industry Issues | Surplus Lines Reform


APCIA Advocacy Takes Strategic Approach Regarding Nonadmitted and Reinsurance Reform Act (NRRA)

The "Dodd-Frank Wall Street Reform and Consumer Protection Act" (DFA), incorporated significant changes for surplus lines regulation through the Nonadmitted and Reinsurance Reform Act (NRRA). Read summary.

The enactment of the long-awaited Nonadmitted and Reinsurance Reform Act will bring about the APCIA-supported streamlining of the compliance aspects of the surplus lines insurance market and the resolution of conflicting state laws governing the placement, tax payment and allocation of premium for multistate surplus lines risks.

APCIA is taking a strategic approach to this issue and will continue to work closely with state legislatures, insurance departments and the NAIC to achieve uniform standards consistent with both the spirit and the letter of the act.

For questions about surplus lines or the NRRA, please contact David Kodama, assistant vice president, research.

Latest News

Rhode Island DOI Files Notice of Final Rulemaking Related to Service of Process
RI regulation to be amended to remove the requirement of appointment of a resident service of process agent.

Oklahoma DOI Clarifies OK Market Assistance Program Membership Requirement
Membership requirement of the OK-MAP and corresponding invoice should NOT apply to surplus lines companies. 

Alaska DOI Clarifies Deposit Requirement for Surplus Lines Carriers
Department responds that surplus lines carriers in Alaska are not required to have a deposit.

Oregon Corporate Activity Tax to Apply to Surplus Lines Premiums
OR HB 2164 modifies corporate activity tax provision to impose on any entity receiving the commercial activity, including surplus lines insurers. 

State Implementation: Legislation & Regulation

NAIC Surplus Lines (C) Task Force at the 2019 summer national meeting – RECAP
The task force met to discuss 2020 charges; IID Plan of Operation; flood insurance coverage reporting; Schedule T proposal; Producer Licensing (D) Task Force referral; and, surplus lines industry financials. 

AM Best Webinar: State of the Surplus Lines Market
A panel of industry leaders in the surplus lines sector of the U.S. insurance market will review the market and highlights of a new report on that sector.

Autonomous Vehicles: August 2019 Update
Summary of legislative and regulatory activity on Autonomous Vehicles at the state and federal levels as well as a "news and notes" section containing links to studies and articles related to self-driving technology.

Surplus Lines Insurance Conference: 2019, September 17-18 
The APCIA will host its inaugural Surplus Lines Insurance Conference for APCIA members on September 17-18 at the APCIA Chicago headquarters building.

ELANY Bulletin Addresses Restrictions on New York Group Insurance Policies
Bulletin No. 2019-19 details New York’s substantial restrictions on group property and casualty insurance policies. See also related legal article, HERE.

Federal Updates & Legislation  | View all

Cannabis and Banking Hearing Held by Senate Banking Committee - SUMMARY
“Challenges for Cannabis and Banking: Outside Perspectives” focused on the cannabis industry's lack of access to financial institutions and the risks faced by businesses that interact with the cannabis industry.

Federal Insurance Office Release 2019 TRIA Small Insurer Report
Mandatory study of small insurers participating in the Terrorism Risk Insurance Program identifies competitive challenges in the terrorism  risk insurance marketplace.

Congressional Letter to President Seeks Board Nominations for NARAB Board
Members from both chambers of Congress collectively submitted a letter to President Trump asking for board nominations for the NARAB Board.

U.S. Treasury Request for Comment - TRIA Small Insurer Study
Treasury seeks to study the challenges faced by small insurers in the terrorism insurance market.

FDA Updates Guidance for Cannabis Products, New Warning Letters, and Announcement of Public Hearing
Press release reinforces FDA position that it is unlawful to introduce food with added CBD or THC into interstate commerce, or to market CBD and THC dietary supplements.

Background & Resources | View all

APCIA Cancellation and Nonrenewal Compliance Guide
A collection of recently updated charts on cancellation/nonrenewal laws in each state. Topics include cancellation/nonrenewal for personal and commercial lines, surplus lines requirements and exemptions, renewal notification and premium increase notice requirements.

APCIA Releases 2019 State Tax Guide
The APCIA guide includes a brief summary of significant state tax and fee-related developments in 2018 affecting property/casualty insurers, including surplus lines insurance.

APCIA: Surplus Lines Insurance Primer

A.M. Best Special Report - U.S. Surplus Lines
APCIA distributes this report to APCIA members with special permission from A.M. Best and the WSIA Education Foundation. A.M. Best retains the copyright to the report, and no part of this report may be distributed by any means, in whole or part, without prior written permission from A.M. Best.

Locke Lord LLP - 2019 Excess and Surplus Lines Law Manual
The Excess and Surplus Lines Law Manual is compiled and provided by: Locke Lord LLP ( For future updates to this publication, or any inquiries concerning this publication, contact John Dearie of Locke Lord LLP at