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 Robert Woody, vice president, reinsurance & counsel.

Latest News

Arkansas DOI Re-issues Bulletin to Correct Notice on Mandatory use of OPTins for Surplus Lines Taxes
Bulletin No. 15-2019 notifies that surplus lines brokers are subject to the promulgated mandatory use of OPTins for filing and paying surplus lines insurance premium taxes.

 Maine Issues Bulletin 439 Regarding Placement of Insurance in Surplus Lines
The Bulletin explains the conditions under which a risk may be placed in the surplus lines market and addresses a 2019 change which allows disability insurance to be placed in the surplus lines market.

New York Excess Line Association Addresses Insurer Compliance Matters
The ELANY Compliance Advisor addresses the applicability of certain New York laws, regulations and court interpretations.

California Commissioner Issues Notice Related to Enacted Law Effecting Residential Property Insurance Policies
APCIA obtains CDI position on how the Notice applies to surplus lines policies. 

State Implementation: Legislation & Regulation

Bulletins & News Releases  | View all 

NAIC Surplus Lines (C) Task Force at the 2019 fall national meeting – RECAP
The task force met to consider comments filed in response to a Schedule T proposal; hear an update on its Producer Licensing (D) Task Force referral; and, receive suggested adjustments to ECP minimum qualification thresholds. 

Marijuana/Cannabis: ISO Revises Policy Forms to Address Cannabis
Cannabis-related endorsements developed for the business owner form, including changes to property and liability coverage.

NAIC Surplus Lines Task Force to Address Schedule T Proposal
The Task Force will additionally meet to discuss matters related to adjustments to ECP Minimum Qualifications and a referral to the Producer Licensing (D) Task Force.

Autonomous Vehicles - Autonomous Vehicle Outlook report
Society of Actuaries and a project oversight group that included APCIA release a report on the state of play in AV.

Autonomous Vehicles: October 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. 

Marijuana/Cannabis: APCIA White Paper and other updates
"Hemp: The Legal Landscape," provides a history of hemp in the United States, its federal regulation, and the impact of the 2018 Farm Bill implementation.

Federal Updates & Legislation  | View all

U.S. Commerce Department Advisory Committee Adopts Proposal on DIC/DIL Insurance
Trade Finance Advisory Council adopts APCIA proposal that the U.S. government negotiate trade agreement commitments to facilitate difference-in-conditions, difference-in-limits insurance.

APCIA Files Joint Trades Letter in Support of the SAFE Banking Act
HR 1595 would provide safe harbor for insurers engaging in insurance transactions related to cannabis that are otherwise permissible under state law.

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.

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

AM Best Special Report - U.S. Surplus Lines (2019)
© AM Best – used with permission. This report is distributed to APCIA members with special permission from AM Best and the WSIA Education Foundation. AM 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 AM 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