Terrorism Risk Insurance Rule Sent to OMB

Yesterday the Treasury Department sent a notice of proposed rulemaking (NPRM) to the OMB’s Office of Information and Regulatory Affairs (OIRA) concerning revisions to the existing Terrorism Risk Insurance program. While this rulemaking was not listed in the latest Unified Agenda, it almost certainly includes revisions to the program required by Terrorism

Risk Insurance Program Reauthorization Act of 2015 (PL 114-1) that was passed early last year.

Changes should include:

• Program trigger amounts;

• Provisions for the recoupment of the Federal share of compensation;

• Changes to the process of certification of acts of terrorism;

• Establishment of the Advisory Committee on Risk-Sharing Mechanisms;

• Changes to insurer reporting requirements;

At this point there is no way to predict how long it will take OIRA to approve this NPRM.