Dodd Frank Financial Reform Information

The Nonadmitted and Reinsurance Reform Act of 2010

This section of the Vermont Captive Insurance web site is dedicated to information about The Nonadmitted and Reinsurance Reform Act (NRRA) of 2010.  Sometimes this act is more commonly referred to as the Dodd Frank Act or the Dodd Frank Reform. We intend to provide up to date information, white papers and industry articles on the subject as it relates to captive insurance companies.

If you have further questions about your captive insurance company and the applicability of the Dodd Frank Act, you should seek the advice of your tax accountant, tax attorney and captive manager on tax related issues.

If you have relevant information to share regarding the Dodd Frank legislation that may be a good fit for this section of the Vermont Captive insurance website, please forward it to dan.towle@state.vt.us.

 

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Industry White Papers:

February 27, 2013: One of the premier insurance recovery law firms, Anderson Kill & Olick (AKO), has published a white paper on the federal Nonadmitted and Reinsurance Reform Act (NRRA), a sub-section of the Dodd-Frank Act, concluding that the legislation was not intended to apply to captive insurance companies. It further stated that the ambiguity in the NRRA’s wording, if not clarified, likely will result in unnecessary litigation, inconsistent rulings, and waste of both private and public resources.  The independent white paper recently was published in the Bloomberg BNA Daily Tax Report.

November 8, 2011 – The McIntyre White Paper Report on the new federal Nonadmitted and Reinsurance Reform Act (NRRA), part of the recently passed Dodd Frank Act, continues to garner agreement among captive insurance industry experts concluding that the law has no applicability to captive insurance. The white paper was prepared by the law firm of McIntyre and Lemon, PLLC of Washington, DC.

 

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Support from US Rep. Garret:

February 6, 2013: New Jersey Congressman and Co-Author of NRRA, U.S. Congressman Scott Garrett (R-NJ) addressed the U.S. Speaker of the House of Representatives stating unequivocally that Dodd-Frank is not applicable to captive insurance.

 

 

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Support from US Rep. Biggert:

December 18, 2012: A letter from the U.S. House Subcommittee Chair, Judy Biggert, affirms that Dodd-Frank is not applicable to captive insurance. Biggert is the outgoing chairperson of the subcommittee on insurance of the Committee on Financial Services in the House of Representatives. In a letter to the new Chairman and Ranking Member, Biggert reaffirmed that the Nonadmitted and Reinsurance Reform Act (NRRA) was never intended to apply to captive insurance.

Representative Judy Biggert wrote, “As a supporter of NRRA and an advocate for its inclusion and passage as part of Dodd-Frank, I can tell you unequivocally that the NRRA was never intended to include the captive insurance industry.”

 

NRRA, a subsection of the Dodd-Frank legislation, has caused some confusion over whether it is applicable to captive insurance.  This newly formed coalition, called the Coalition for Captive Insurance Clarity (CCIC) is seeking legislative language that will clarify that captive insurance companies are not part of NRRA.

 

 

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Coalition for Captive Insurance Clarity (CCIC):

The Coalition for Captive Insurance Clarity (CCIC), was formed in November 2012, under the leadership of the Vermont Captive Insurance Association (VCIA) to push for legislative language that would clarify that the intent of the new federal NRRA was never intended to apply to captive insurance.

The Coalition for Captive Insurance Clarity (CCIC) received a letter of support from the Captive Insurance Companies Association (CICA). In the letter from CICA President Dennis P. Harwick, he states: "CICA is proud to join the new coalition of the captive insurance industry formed to push for legislative language that would clarify that the intent of the new federal Nonadmitted and Reinsurance Reform Act (NRRA 2010), which was never intended to apply to captive insurance."

NRRA, a subsection of the Dodd-Frank legislation, has caused some confusion over whether it is applicable to captive insurance. This newly formed coalition, called the Coalition for Captive Insurance Clarity (CCIC) is seeking legislative language that will clarify that captive insurance companies are not part of NRRA.

 

 

 

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