Over the past few years some risk retention groups have run into issues registering in nondomiciliary states. As a result, the National Risk Retention Association (NRRA) has made education regarding the language of the Liability Risk Retention Act as it pertains to the registration process a priority.
The Iowa Insurance Division (the Iowa Division) currently requires risk retention groups to pay an initial registration fee of $100 and an annual renewal fee of $100. In August 2021, Iowa issued a Notice of Intended Action that it was planning to make March 1 the deadline for risk retention group renewals.
In addition, risk retention groups that missed the deadline would have an additional fee of $500 imposed. The revision would have also given the Iowa Insurance commissioner the power to suspend an RRG’s authority to do business in the state for failing to comply with the revised renewal requirements.
On September 14, 2021, NRRA Executive Director Joe Deems wrote a letter to the Iowa division that argued that the proposed revisions for risk retention group renewals were not allowed under the LRRA. “As you will hopefully be able to see, the Division’s proposed legislative revisions are not legally supported, or supportable, under federal law,” wrote Deems.
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