TRIA Update

President Obama recently signed the reauthorization of TRIA. You’ve, more than likely been receiving a lot of information around this announcement. We see the main take-aways as:

  • Most insurance experts interpret the bill as retroactive, which means there should be no gap in the program’s coverage.

  • The U.S. Treasury Department will most likely issue some guidance regarding the reauthorization of TRIA, as they have done in the past. For prior reauthorizations, this guidance focused on disclosure notice obligations. So, get those disclosures signed!

NAPSLO-LegNews-Header

President Obama has signed H.R. 26, bringing the reauthorization of TRIA and the creation of NARAB to fruition as we first reported last week. NAPSLO continues to gather details and information on the impact of both the reauthorization of TRIA and implementation of NARAB. Below are a few things that we know at this time that are important for members to understand:

TRIA

  • NAPSLO, as well as other trade associations, continue to interpret the bill as retroactive, which means there should be no gap in the program’s coverage. We will continue to monitor for specific interpretation and provide updates as necessary.
  • We believe the U.S. Treasury Department will issue some guidance regarding the reauthorization of TRIA, as they have done so in the past. For prior reauthorizations, this guidance focused on disclosure notice obligations.
  • The NAIC is expected to issue a model bulletin, but it will focus on rate and form filings and use of the SERFF filing system.
  • A side-by-side analysis of the new TRIA program and the expired program is available on the NAPSLO website here.
  • We will continue to gather information and provide updates to you as appropriate.

NARAB

  • The language in NARAB calls for the President to appoint the governing Board within 90 days of enactment of the law and for the Board to meet within 45 days of being formed. The Board will be comprised of 13 members, appointed by the President and with the advice and consent of the Senate. We are hopeful it will be possible for the Board to be formed that quickly.
  • Although the Board may be appointed in near term, we still expect it to take up to one to two years before the first national license is issued. This time will be spent establishing rules, requirements and procedures, as well as establishing the licensing clearinghouse.
  • We will provide updated information and resources on the implementation as it develops and will be sure to represent our industry’s interests during the process.

Any members with questions about TRIA or NARAB should contact Keri Kish at keri@napslo.org.