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December 27, 2016

YELLOW ALERT: Treasury Department Updates Terrorism Risk Insurance Program Regulations

The Treasury Department recently issued the following regulatory items related to the Terrorism Risk Insurance Program (“TRIP” or “Program”):
  1. Final rules to implement the Terrorism Risk Insurance Program Reauthorization Act of 2015, which contain a new subpart on data collection (e.g., annual insurer reporting and small insurer data calls), final netting rules and commutation processes under which the Department will close claims operations for insured losses for a calendar year, imposition of civil penalties on insurers who violate TRIP laws and/or regulations, and changes to the advance settlement approval process;
  2. Proposed forms for use in the mandatory 2017 data collection process (including different forms for small insurers, captive insurers, and alien surplus lines insurers) and a request for public comment on small insurer participation in TRIP; and
  3. Guidance on stand-alone cyber policies under TRIP, which clarifies that policies reported under the “Cyber Liability” line for state regulatory purposes are included in the definition of “property and casualty insurance” under TRIA and are subject to disclosure and other requirements under the Program.

A full explanation of each of these releases can be found here.

Please contact John Fielding at or Joel Wood at with any questions.