In a Special Focus article posted on May 2, 2016, we addressed the uncertain future of the multi-state allocation of non-admitted premium tax revenue. The Non-admitted and Reinsurance Reform Act (NRRA) provides for individual states to determine the allocation of premium taxes collected for risks outside of the home state of the insured; only the insured’s home state may regulate and tax non-admitted insurance. Two groups (NIMA and SLIMPACT) were then established to address how states should allocate the tax revenue. We previously addressed how both groups have proven to be ineffective at engaging enough state membership and have failed to address the allocation concerns. Earlier this year, the Board of Directors of NIMA decided to discontinue its operations and dissolve the organization after seeing its membership dwindle from 12 members to five. On June 30, 2016, the Surplus Lines Clearinghouse, a division of the Florida Surplus Lines Service Office, issued a bulletin providing the following instructions: (1) no multistate new business, renewal or reinstatement transactions effective on or after October 1, 2016 will be accepted through the Surplus Lines Clearinghouse multistate reporting platform (after that date, relevant exposures in more than one jurisdiction should be reported directly to the home state); (2) additional premium, return premium and cancellation endorsements on multistate policies effective prior to October 1, 2016 should be filed through the Surplus Lines Clearinghouse multistate reporting platform through September 30, 2017; and (3) the Surplus Lines Clearinghouse will continue to accept surplus lines filings and payments for South Dakota and Wyoming policies effective October 1, 2016 and after, but at that time all new and renewal multistate policies will be reported as single state policies with 100% of the premium being reported to and taxed by the respective home state.
This post written by Joshua S. Wirth.
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