Starting in 2019, the National Association of Insurance Commissioners (NAIC) RRG Task Force responded to a request from NRRA proposing that efforts be undertaken to address ongoing problems associated with registration violation activities by non-domiciliary states. Such activities are disallowed by the LRRA.

In response, the NAIC, on the recommendation of its RRG Task Force, adopted its Best Practices and Frequently Asked Questions (FAQs), which addressed the problems by focusing on the need of states to comply with what NRRA had been talking about for years, consistent with Federal Law.

More important, as a further response in support of its own activities, with additional input from NRRA, the NAIC redrafted its model Registration Form for use in non-domiciliary states. The revised form includes the requirement that such states comply with the LRRA when they adopt the form. For the first time, the NAIC Model Registration form is now fully compliant with the LRRA.

In an effort to keep the momentum going on this initiative before the NAIC RRG Task Force, NRRA has now undertaken efforts to identify and quantify the legislative or regulatory bases on which the offending states rely in continuing to require payment of the illegal registration fees. We’re still working on this now.