Prior to the September 11, 2001, terrorist attacks, insurance covering terrorism losses was normally included in commercial insurance policies without additional cost to the policyholders. Following the attacks, this ceased to be the case as insurers and reinsurers pulled back from offering terrorism coverage. It was feared that a lack of insurance against terrorism loss would have a wider economic impact, particularly because insurance coverage can be a significant factor in lending decisions.
Congress responded to the disruption in the insurance market by passing the Terrorism Risk Insurance Act of 2002 (TRIA; P.L. 107-297). TRIA created a temporary program, expiring at the end of 2005, to calm the insurance markets through a government reinsurance backstop sharing in terrorism losses. The intent was that this would give the industry time to gather the data and create the structures and capacity necessary for private insurance to cover terrorism risk. TRIA did not require premiums to be paid for the government coverage. Instead, TRIA required private insurers to offer commercial insurance for terrorism risk with the government then recouping some or all federal payments under the act in the years following government coverage of insurer losses.
Under TRIA, terrorism insurance became widely available and largely affordable, and the insurance industry greatly expanded its financial capacity. There has been, however, little apparent success on developing a longer-term private solution, and fears have persisted about wider economic consequences if insurance were not available. Congress passed two extensions to the program, in 2005 (P.L. 109-144) and 2007 (P.L. 110-160). The 2005 extension was primarily focused on reducing the government’s upfront financial exposure under the act, whereas the 2007 extension left most of the upfront aspect of the TRIA program unchanged, while accelerating the post-event recoupment provisions. The 2007 legislation also included the only expansion of the TRIA program since initial enactment; it extended the program to cover any acts of terrorism, as opposed to only foreign acts of terrorism.
The current TRIA program expires at the end of 2014. Although insurance industry capacity has increased since 2002, terrorism is still seen by many as essentially uninsurable. Without TRIA, the insurance industry has indicated that terrorism insurance will again become unavailable or unaffordable and fears are again being expressed that lack of terrorism insurance may slow down other sectors of the economy. Several bills (H.R. 508, H.R. 1945, H.R. 2146, S. 2244, and H.R. 4871) were introduced to extend TRIA and change different aspects of the program. The House and the Senate adjourned on December 16, 2014, without passing legislation to extend TRIA.
This report briefly outlines the issues involved with terrorism insurance, summarizes extension legislation in the 113th Congress, and includes a side-by-side of TRIA law and bills that were passed by the Senate (S. 2244), reported by the House Committee on Financial Services (H.R. 4871), and passed by the House (S. 2244 with a substitute amendment). For more a more in-depth treatment of the issues surrounding TRIA, please see CRS Report R42716, Terrorism Risk Insurance: Issue Analysis and Overview of Current Program, by Baird Webel.
Prior to the September 11, 2001, terrorist attacks, insurance covering terrorism losses was normally included in commercial insurance policies without additional cost to the policyholders. Following the attacks, this ceased to be the case as insurers and reinsurers pulled back from offering terrorism coverage. It was feared that a lack of insurance against terrorism loss would have a wider economic impact, particularly because insurance coverage can be a significant factor in lending decisions.
Congress responded to the disruption in the insurance market by passing the Terrorism Risk Insurance Act of 2002 (TRIA; P.L. 107-297). TRIA created a temporary program, expiring at the end of 2005, to calm the insurance markets through a government reinsurance backstop sharing in terrorism losses. The intent was that this would give the industry time to gather the data and create the structures and capacity necessary for private insurance to cover terrorism risk. TRIA did not require premiums to be paid for the government coverage. Instead, TRIA required private insurers to offer commercial insurance for terrorism risk with the government then recouping some or all federal payments under the act in the years following government coverage of insurer losses.
Under TRIA, terrorism insurance became widely available and largely affordable, and the insurance industry greatly expanded its financial capacity. There has been, however, little apparent success on developing a longer-term private solution, and fears have persisted about wider economic consequences if insurance were not available. Congress passed two extensions to the program, in 2005 (P.L. 109-144) and 2007 (P.L. 110-160). The 2005 extension was primarily focused on reducing the government's upfront financial exposure under the act, whereas the 2007 extension left most of the upfront aspect of the TRIA program unchanged, while accelerating the post-event recoupment provisions. The 2007 legislation also included the only expansion of the TRIA program since initial enactment; it extended the program to cover any acts of terrorism, as opposed to only foreign acts of terrorism.
The current TRIA program expires at the end of 2014. Although insurance industry capacity has increased since 2002, terrorism is still seen by many as essentially uninsurable. Without TRIA, the insurance industry has indicated that terrorism insurance will again become unavailable or unaffordable and fears are again being expressed that lack of terrorism insurance may slow down other sectors of the economy. Several bills (H.R. 508, H.R. 1945, H.R. 2146, S. 2244, and H.R. 4871) were introduced to extend TRIA and change different aspects of the program. The House and the Senate adjourned on December 16, 2014, without passing legislation to extend TRIA.
This report briefly outlines the issues involved with terrorism insurance, summarizes extension legislation in the 113th Congress, and includes a side-by-side of TRIA law and bills that were passed by the Senate (S. 2244), reported by the House Committee on Financial Services (H.R. 4871), and passed by the House (S. 2244 with a substitute amendment). For more a more in-depth treatment of the issues surrounding TRIA, please see CRS Report R42716, Terrorism Risk Insurance: Issue Analysis and Overview of Current Program, by [author name scrubbed].
Prior to the September 11, 2001, terrorist attacks, insurance covering terrorism losses was normally included in general insurance policies without additional cost to the policyholders. Following the attacks, both primary insurers and reinsurers pulled back from offering terrorism coverage. Because insurance is required for a variety of economic transactions, particularly borrowing for commercial development, it was feared that a lack of insurance against terrorism loss would have a wider economic impact.
Congress responded to the disruption in the insurance market by passing the Terrorism Risk Insurance Act of 2002 (TRIA).1 TRIA created a temporary three-year Terrorism Insurance Program to calm the insurance markets through a government reinsurance backstop sharing in terrorism losses. The idea was to give the private industry time to gather the data and create the structures and capacity necessary for private insurance to cover terrorism risk. TRIA requires insurers to offer terrorism coverage, but does not require commercial policyholders to purchase the coverage. This program was extended in 20052 and 2007.3 In 2005, the extension legislation focused on reducing the government's exposure from TRIA by increasing the minimum covered event size, increasing the insurer deductible, reducing the government share of losses, and increasing the post-event mandatory recoupment. In 2007, the primary change was to accelerate the after-the-fact recoupment. While the prospective government share of losses has been reduced over time, the 2007 reauthorization also expanded the program to cover losses from acts of domestic terrorism. The TRIA program expired at the end of 2014, as provided for in the 2007 extension.
The initial thresholds of the current program are as follows:
Once these thresholds are passed, the government covers 85% of insured losses due to terrorism with the private insurers retaining 15% of the losses. No premiums are charged by the government for this coverage. Instead, if the insured losses are under $27.5 billion, the Secretary of the Treasury is required to recoup 133% of government outlays through a surcharge on commercial property/casualty insurance policies. As insured losses rise above $27.5 billion, the Secretary is required to recoup a reduced amount of the outlays. At some high insured loss level, which will depend on the exact distribution of losses, the Secretary would no longer be required to recoup outlays, but would retain the discretionary authority to do so. Under current law, all mandatory recoupment must be completed by the end of FY2017.
Since TRIA's passage, private industry's willingness and ability to cover terrorism risk have increased. According to industry surveys, prices for terrorism coverage have generally trended downward, and approximately 60% of commercial policyholders have purchased coverage over the past few years.4 This relative market calm has been under the umbrella of TRIA coverage, and it is unclear how the insurance market may react to the expiration of the federal program.
Representative Michael Grimm along with nine cosponsors introduced H.R. 508 on February 5, 2013. The bill is a reauthorization of the existing TRIA program that would extend the program five years, until the end of 2019. It would also extend the deadline for mandatory recoupment seven years, until September 30, 2024. The bill has been referred to the House Committee on Financial Services.
Representative Bennie Thompson along with one cosponsor introduced H.R. 1945 on May 9, 2013. The bill would extend the expiration date of the program 10 years, until the end of 2024, and would extend the deadline for mandatory recoupment seven years, until September 30, 2024. It would also add the Secretary of Homeland Security as the lead authority responsible for certifying an act of terrorism and require the Secretary to provide information and reports on terrorism risks and best practices to foster resilience in the face of terrorism. The Secretary of the Treasury would remain in the certification process but as a concurring party, not the lead authority; the program in general would remain under the authority of the Treasury. H.R. 1945 has been referred to the House Committee on Financial Services and the House Committee on Homeland Security.
Representative Michael Capuano along with 20 cosponsors introduced H.R. 2146 on May 23, 2013. The bill is a reauthorization of the existing TRIA program that would extend the program 10 years, until the end of 2024, as well as extend the deadline for mandatory recoupment by 10 years, until September 30, 2027. In addition, the President's Working Group on Financial Markets is to continue filing reports on market conditions for terrorism risk insurance, with reports required in 2017, 2020, and 2023. The bill has been referred to the House Committee on Financial Services.
Senator Charles Schumer along with eight cosponsors introduced S. 2244 on April 10, 2014. The bill would extend the current TRIA program seven years, until December 31, 2021, while also decreasing the federal loss sharing amount and increasing the amount to be retained by the industry and recouped by the government. Specifically, S. 2244 as introduced would
Under these extended dates, if an act of terrorism occurs prior to 2018, all mandatory recoupment premiums must be collected by September 30, 2019. If an act occurs in 2018, 35% of the mandatory recoupment premiums would be collected by September 30, 2019, with the rest by September 30, 2024. If the terrorist act occurs after 2018, all of the mandatory recoupment premiums would be collected by September 30, 2024.
The Senate Committee on Banking, Housing, and Urban Affairs marked up S. 2244 on June 3, 2014. A number of amendments were adopted en bloc, including
One amendment was rejected on a recorded vote in committee. Senator Tom Coburn offered an amendment that would have changed the timing of the mandatory recoupment, giving more time for the recoupment in the case of larger attacks. This amendment failed on a vote of 7-15. The bill as amended was ordered reported favorably on a vote of 22-0. The written report (S.Rept. 113-99) was filed on June 26, 2014.
S. 2244 was considered by the full Senate by unanimous consent on July 17, 2014, with three amendments adopted.
Senator Coburn offered S.Amdt. 3549 extending the timing of the recoupment provisions in the case of a large terrorist attack. A point of order on budgetary grounds was raised against this amendment and a motion to waive this point of order was rejected on a vote of 48-49. The amended version of S. 2244 was passed by the full Senate on a vote of 93-4.
The Office of Management and Budget (OMB) released a Statement of Administration Policy (SAP) on July 17, 2014. This SAP endorsed extension of the TRIA program along with reforms to "further reduce taxpayer exposure, increase private sector contributions, and better position the Program for future transition to the private sector." It also specifically supported Senate passage of S. 2244.5
The House Committee on Rules met on December 9, 2014, and reported a rule (H.Res. 775) making in order the House floor consideration of S. 2244 with an amendment in the nature of a substitute.6 This substitute amendment would
The substitute amendment also includes the NARAB title relating to insurance agent licensing and the section relating to the makeup of Federal Reserve Board of Governors, which were added in Senate floor consideration. In addition, the substitute amendment adds a Title III, the "'Business Risk Mitigation and Price Stabilization Act of 2014.'' Title III would amend statutory provisions originating in the 2010 Dodd-Frank Act7 relating to derivatives and margin requirements for end users.8 Similar provisions to Title III passed the House as H.R. 634 on June 12, 2013, by a vote of 411-12.
The House took up S. 2244 as amended under H.Res. 775 on December 10, 2014, and passed the bill on a vote of 417-7. The House and the Senate adjourned on December 16, 2014, without further action on S. 2244 or other legislation to extend TRIA.
H.R. 4871 was introduced by Representative Randy Neugebauer and one cosponsor on June 17, 2014. The bill would extend the TRIA program five years while generally reducing the government's exposure to future TRIA losses, increasing post-event recoupment, and making several other changes to the program. The provisions include
The House Committee on Financial Services marked up H.R. 4871 beginning June 19, 2014, and ordered the bill favorably reported on June 20, 2014, by a vote of 32-27. During the markup, a second title was added containing the text of the National Association of Registered Agents and Brokers Reform Act of 2013 (H.R. 1155), which previously passed both the committee and the full House of Representatives.10 The committee rejected a substitute amendment by Representative Maxine Waters, which would have replaced the text with a 10-year reauthorization of the current program, on a vote of 27-31. The bill was reported (H.Rept. 113-523) on July 16, 2014.
Table 1 below presents a side-by-side comparison of the current law and legislation that has seen committee or floor action, or both.
|
Provision |
15 U.S.C. §6701 note |
S. 2244 |
H.R. 4871 |
S. 2244 |
|
Title |
Terrorism Insurance Program |
Terrorism Risk Insurance Program Reauthorization Act of 2014 |
TRIA Reform Act of 2014 |
Terrorism Risk Insurance Program Reauthorization Act of 2014 |
|
Termination Date |
December 31, 2014 (§108(a)) |
December 31, 2021 (§2) |
December 31, 2019 (§102) |
December 31, 2020 (§101) |
|
Certification of an Act of Terrorism |
Terrorist act is to be certified by the Secretary of the Treasury (hereafter "the Secretary") in concurrence with the Attorney General and Secretary of State. Terrorist act must cause $5 million in insured losses to be certified. |
Requires the Secretary to study and report on the certification process. After the study is completed, the Secretary is to issue rules governing the process, including a timeline as to whether an act is considered an act of terrorism. (§6) |
Beginning in 2015, removes the Secretary of State from certification process. Adds "consultation" with the Secretary of Homeland Security. Removes the $5 million minimum size for certification. Beginning in 2015, adds a deadline of 15 days for "preliminary certification" and 90 days for "final certification." If no certification is made within 90 days, no certification is possible. (§103) Beginning in 2016, certification is to include whether or not terrorist act is an act of Nuclear, Biological, Chemical, or Radiological (NBCR) terrorism according to the definition added by the legislation. (§104(a)) |
Beginning in 2015, removes the Secretary of State from certification process. Adds "consultation" with the Secretary of Homeland Security. (§105) Requires the Secretary to study and report on the certification process. After the study is completed, the Secretary is to issue rules governing the process, including a timeline as to whether an act is considered an act of terrorism. (§107) |
|
Insured Loss Shared Compensation |
Federal share of losses will be 85% for insured losses that exceed the applicable insurer deductible. (§103(e)) |
Starting in 2016, the federal share of losses will decrease one percentage point per calendar year until equal to 80%. (§3) |
Federal share of losses will be 85% in 2015, 84% in 2016, 83% in 2017, 82% in 2018, and 80% in 2019 except in the case of an NBCR terrorist event. For an NBCR attack, the federal share of losses will remain at 85%. (§104(b)) |
Starting in 2016, the federal share of losses will decrease one percentage point per calendar year until equal to 80%. (§102) |
|
Program Trigger |
No compensation shall be paid unless the aggregate industry insured losses resulting from such certified act of terrorism exceed $100 million. (§103(e)(1)(B)) |
No Change |
Increases program trigger to $200 million in 2016, $300 million in 2017, $400 million in 2018, and $500 million in 2019. Applies program trigger to the aggregate losses from multiple acts of terrorism in a calendar year if the insured losses from each act exceed $50 million. Program trigger for NBCR attacks remains at $100 million. (§104(c)) |
Beginning in 2015, program trigger increases $20 million per year until it reaches $200 million. Applies program trigger to the aggregate losses from multiple acts of terrorism in a calendar year. (§103) |
|
Treatment of NBCR Terrorism |
No Similar Provisions |
No Similar Provisions |
Beginning in 2016, certification is to include whether or not terrorist act is an act of NCBR terrorism according to the definition added by the legislation. (§104(a)) Federal share of losses will be 85% in 2015, 84% in 2016, 83% in 2017, 82% in 2018, and 80% in 2019 except in the case of an NBCR terrorist event. For an NBCR attack, the federal share of losses will remain at 85%. (§104(b)) Program trigger for NBCR attacks remains at $100 million. (§104(c)) |
No Similar Provisions |
|
Mandatory Availability |
Insurers are required to make terrorism coverage available to insureds. (§103(c)) |
No Change |
Small insurers, as defined by the Secretary, may be exempted from mandatory availability upon request. This exemption applies if meeting the make available requirement is determined by the insurer's domiciliary state insurance to cause financial hardship or be financially infeasible. This determination would be based on criteria set by the Secretary. (§105) |
No Change |
|
Aggregate Retention Amount |
The aggregate retention amount is the lesser of (1) the total of all insured losses or (2) $27.5 billion. |
Beginning in the calendar year after enactment, the retention amount would be the lesser of (1) the total of all insured losses or (2) $29.5 billion with this amount further increased by $2 billion per year until reaching $37.5 billion. (§4(1)) |
Beginning in 2016, the retention amount would be the lesser of (1) the total of all insurer deductibles in the previous year or (2) the total of all insured losses. (§107) |
Beginning in the calendar year after enactment, the retention amount would be the lesser of (1) the total of all insured losses or (2) $29.5 billion with this amount further increased by $2 billion per year until reaching $37.5 billion. Once it reaches $37.5 billion, it shall be set by the Secretary to equal the annual average of the sum of insurer deductibles for the previous three years. (§104(1)) |
|
Mandatory Recoupment of Federal Share |
If aggregate insured losses are under the aggregate retention amount, a mandatory recoupment of 133% of the federal share of the loss will be imposed. If aggregate insured losses are over the aggregate retention amount, but uncompensated insurer losses do not exceed the aggregate retention amount, the mandatory recoupment amount is reduced by this amount. If uncompensated insurer losses are over the aggregate retention amount, there is no mandatory recoupment, but Secretary of the Treasury retains discretionary recoupment authority. |
The gradual increase in the aggregate retention amount to $37.5 billion (§4(1)) effectively increases the level of mandatory recoupment. Increases the mandatory recoupment to 135.5% of the federal share of losses. (§4(2)) |
Mandatory recoupment increases to 150% of the federal share of losses beginning in 2016 and all years thereafter. (§106) Beginning in 2016, mandatory recoupment amount is equal to the lesser of (1) the aggregate amount of federal compensation received by insurers or (2) the aggregate retention amount. (§107) |
The gradual increase in the aggregate retention (§104(1)) effectively increases the level of mandatory recoupment. Increases the mandatory recoupment to 140% of the federal share of losses. (§104(2)) |
|
Timing of Mandatory Recoupment |
Requires expedited collection of recoupment amounts: (1) for a terrorist attack before 2011, all required recoupment amounts must be collected by September 30, 2012; (2) for a terrorist attack in 2011, 35% of required recoupment amounts must be collected by September 30, 2012, and the balance must be collected by September 30, 2017; and (3) for a terrorist attack after 2011, all required recoupment amounts must be collected by September 30, 2017. |
Requires expedited collection of recoupment amounts: (1) for a terrorist attack before 2018, all required recoupment amounts must be collected by September 30, 2019; (2) for a terrorist attack in 2018, 35% of required recoupment amounts must be collected by September 30, 2019, and the balance must be collected by September 30, 2024; and (3) for a terrorist attack after 2018, all required recoupment amounts must be collected by September 30, 2024. |
Beginning in 2016, requires that recoupment commence within 18 months of an attack. (§108) |
Requires expedited collection of recoupment amounts: (1) for a terrorist attack before 2018, all required recoupment amounts must be collected by September 30, 2019; (2) for a terrorist attack in 2018, 35% of required recoupment amounts must be collected by September 30, 2019, and the balance must be collected by September 30, 2024; and (3) for a terrorist attack after 2018, all required recoupment amounts must be collected by September 30, 2024. |
|
Risk Sharing Mechanisms |
No Similar Provisions |
Establishes an advisory committee to encourage the creation and development of private risk-sharing mechanisms. (§9) |
Establishes an advisory committee to encourage the creation and development of private risk-sharing mechanisms. (§109) |
Establishes an advisory committee to encourage the creation and development of private risk-sharing mechanisms. (§110) |
|
Reporting of Terrorism Insurance Data |
Requires Secretary to annually compile information on terrorism insurance premiums. To the extent that such data are not otherwise available, the Secretary may require insurers to submit the information to the NAIC, which shall make it available to the Secretary. (§108(e)) |
No Change |
Beginning in 2016, requires Secretary to collect data from insurers on terrorism insurance coverage, including: lines of insurance with terrorism exposure, premiums earned from terrorism coverage, location of exposure, pricing of coverage, take-up rates, and amount of private reinsurance purchased. If such data are available from the states or another source, the Secretary shall collect the data from this source. The Secretary shall issue a report to Congress based on these data. (§110) |
Beginning in 2016, requires Secretary to collect data from insurers on terrorism insurance coverage, including: lines of insurance with terrorism exposure, premiums earned from terrorism coverage, location of exposure, pricing of coverage, take-up rates, and amount of private reinsurance purchased. If such data are available from the states or another source, the Secretary shall collect the data from this source. The Secretary shall issue a report to Congress based on these data. (§111) |
|
Definition of Control |
An entity is considered to have control over another entity if the entity has the power to vote 25% of the voting securities; controls the election of the majority of the directors; or the Secretary determines that the entity exercises control after notice and hearing. (§102(3)) |
Adds the proviso that an entity is not considered to have control if, on the date of enactment, the entity is "acting as an attorney-in-fact ... for the other entity and such other entity is a reciprocal insurer." This, however, does not apply if the entity is defined as having control for reasons other than the attorney-in-fact relationship. (§5(1)) |
Adds the proviso that an entity is not considered to have control if, on the date of enactment, the entity is "acting as an attorney-in-fact ... for the other entity and such other entity is a reciprocal insurer." This, however, does not apply if the entity is defined as having control for reasons other than the attorney-in-fact relationship. (§112) |
Adds the proviso that an entity is not considered to have control if, on the date of enactment, the entity is "acting as an attorney-in-fact ... for the other entity and such other entity is a reciprocal insurer." This, however, does not apply if the entity is defined as having control for reasons other than the attorney-in-fact relationship. (§106(1)) |
|
Studies and Reports |
The Secretary shall conduct an expedited study of the availability and affordability of group life insurance coverage. (§103(h)) The Secretary shall conduct study and issue a report on the potential effect of terrorism on life insurance and other personal lines by October 2003. (§103(i)) The Secretary shall conduct a study and issue a report no later than June 30, 2005 on the effectiveness of the program and the capacity of private insurers to offer terrorism coverage after the expiration of the program. (§104(d)) President's Working Group on Financial Markets is to report on the market conditions for terrorism risk insurance in 2006, 2010, and 2013. (§104(e)) GAO shall conduct a study and issue a report on the availability and affordability of NBCR coverage and the outlook for future coverage by December 2008. (§104(f)) GAO shall conduct a study and issue a report on the availability and affordability of terrorism insurance in specific markets by June 2008. (§104(g)) |
GAO shall conduct a study and issue a report on the viability of the government collecting upfront terrorism insurance premiums on insurers within two years from the date of enactment. (§7) |
The Secretary shall issue a report to Congress based on the terrorism insurance data collected under Section 11 to be completed by June 30, 2017 and annually thereafter. (§110) The Secretary shall conduct an annual study of small insurer competitiveness and issue an annual report on this study with the first report not later than June 30, 2016. (§113) CBO and OMB shall each conduct a study and issue a report regarding the application of accrual accounting concepts to TRIA and other federal insurance programs not later than 12 months after the date of enactment. (§114) GAO shall conduct a study and issue a report on the viability of (1) the government collecting upfront terrorism insurance premiums on insurers and (2) the creation of a mandatory capital reserve fund to dedicate capital for terrorism losses before such losses occur within two years from the date of enactment. (§115) |
GAO shall conduct a study and issue a report on the viability of (1) the government collecting upfront terrorism insurance premiums on insurers including international practices and (2) the creation of a mandatory capital reserve fund to dedicate capital for terrorism losses before such losses occur within two years from the date of enactment. (§108) The Secretary shall issue a report to Congress based on the terrorism insurance data collected under Section 11 to be completed by June 30, 2017 and annually thereafter. (§111) The Secretary shall conduct an annual study of small insurer competitiveness and issue an annual report on this study with the first report not later than June 30, 2016. (§112) |
Source: CRS; using material from the U.S. Treasury, http://www.congress.gov, and the House Committee on Rules.
Notes: Section numbers for the initial TRIA law are as codified in 15 U.S.C. §6701 note. Section numbers for current legislation are from the legislation as amended. S. 2244 as passed by the Senate and the House substitute amendment to S. 2244 also include technical corrections that delete outdated language from several sections of the TRIA statute (Section 5(2) and Section 106, respectively), a section relating to the composition of the Federal Reserve Board of Governors (Section 8 and Section 109, respectively), and a second title in both bills relating to insurance agent licensing. The substitute amendment also adds a Title III related to derivatives. These sections and titles are not included in the chart.
| 1. |
P.L. 107-297, codified at 15 U.S.C. §6701 note. |
| 2. | |
| 3. | |
| 4. |
See, for example, Marsh, Inc. 2014 Terrorism Risk Insurance Report, April 2014. |
| 5. |
Office of Management and Budget, Statement of Administration Policy: S. 2244, July 17, 2014, available at http://www.whitehouse.gov/sites/default/files/omb/legislative/sap/113/saps2244s_20140717.pdf. |
| 6. |
Text of the substitute amendment is available at http://rules.house.gov/bill/113/s-2244. |
| 7. | |
| 8. |
For more information see "Margin for Non-Financial Entities or 'Commercial End Users'" in CRS Report R43117, The Commodity Futures Trading Commission: Background and Current Issues, by [author name scrubbed]. |
| 9. |
Small insurers could request to opt out from their domiciliary state regulator using criteria set by the Secretary of the Treasury. |
| 10. |
For more information, see CRS Report R43095, Insurance Agent Licensing: Overview and Background on Federal NARAB Legislation, by [author name scrubbed]. |