National Association of Mutual Insurance Companies Issues Public Comment to Treasury Department
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To:
RE: 2022 Report on the Effectiveness of the Terrorism Risk Insurance Program, Document Number: 2022-06681
Dear Mr. Ifft,
On
NAMIC is the largest property/casualty insurance trade group with a diverse membership of more than 1,500 local, regional, and national member companies, including seven of the top 10 property/casualty insurers in
Terrorism is an ongoing threat to the people of
NAMIC supports TRIP as a risk-sharing model between insurers, policyholders, and the federal government that - in addition to providing an immediate stabilizing effect in the short-term following a terrorist attack - has acted to create space for a robust private market for terrorism insurance to form where it would not have otherwise. NAMIC supports a long-term private/public terrorism insurance program because terrorism is fundamentally an uninsurable risk due to the inability of insurers to predict when events will occur and because of the potentially catastrophic costs of an attack. Indeed, in the absence of the federal program's backstop, such losses would exceed capacity for insurers as well as affordability for policyholders.
Since there is no expectation that terrorism risk and exposure is diminishing, as it will continue to expose the public for an indefinite period, NAMIC has supported numerous long-term reauthorizations of the TRIA program. Most recently, the TRIA program was signed into law on
In considering some of the questions posed in the request for comment, NAMIC shares several high-level remarks. NAMIC does not believe that there are any lines of insurance or coverages within certain lines of insurance currently subject to the Program that no longer require the support of TRIP to ensure the availability and affordability of terrorism risk insurance. Similarly, NAMIC does not presently see any lines of insurance or coverages within certain lines of insurance currently not subject to the Program that should be included within TRIP to promote the availability and affordability of terrorism risk insurance. Also, NAMIC is not aware of any significant insurance market changes associated with the impact of the COVID-19 pandemic that have also affected the market for terrorism risk insurance. Finally, with respect to questions about the cyber insurance market, the
Thank you for the opportunity to comment on this program that is essential to protecting the ability of the
Sincerely,
General Counsel - Federal
TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact
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