State interpretation and application of anti-rebating laws varies, and, about a year ago, those variations prompted the National Association of Insurance Commissioners’ (NAIC) Innovation and Technology Task Force, led by Commissioner Jon Godfread (ND), to further investigate the section of the Unfair Trade Practices Act (Model #880) that addresses rebating. Prompted by that investigation, the Task Force tasked a …
Author: Lauren Pachman
Counsel & Director of Regulatory Affairs
Regulatory Update on Executive Actions
Although the House is poised to return early to address issues related to Postal Service funding, Congress is no closer to a deal on a new coronavirus package than it was last week, when the Senate recessed with plans to return in September. However, the creaky wheels of the administrative state have continued to turn …
Paycheck Protection Program Clarifications Continue
In July, PIA National submitted comments on two different regulatory proposals promulgated by the Small Business Administration (SBA) concerning the implementation of the Paycheck Protection Program (PPP). Since then, regulatory activity has continued apace in formal and informal ways. The latest entry in the growing literature on How to Interpret the PPP is an August …
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Paycheck Protection Program: Legislative Update (Part 2 of 2)
Earlier this month, Congress passed and the president signed H.R. 7010, the Paycheck Protection Program Flexibility Act, expanding the “covered period” (see yesterday’s post for details) from eight to 24 weeks. In other words, thanks to the modifications in H.R. 7010, employers now have an extra 16 weeks in which to spend their PPP loan …
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Paycheck Protection Program: Regulatory Update (Part 1 of 2)
The Paycheck Protection Program (PPP), a new loan program created within the Treasury Department’s Small Business Administration (SBA) as part of the CARES Act, was designed to provide an avenue of potential loan forgiveness for those businesses whose borrowing and spending met certain requirements. Today in Part 1, we’ll go over the main points of …
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PIA Comments on Paycheck Protection Program Rule
On May 15, PIA National submitted a response to the interim final rule promulgated by the U.S. Small Business Administration (SBA) regarding its implementation of the Paycheck Protection Program (PPP). The PPP was created by H.R. 748, the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. 116-136). In the CARES Act, Congress authorized …
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IRS Says Small Business Loans Are Taxable Income
Last week, the Internal Revenue Service (IRS) issued Notice 2020-32, which announced that business expenses that are normally tax deductible but are expected to be forgiven as part of loans provided in accordance with the Small Business Administration’s (SBA) Paycheck Protection Program (PPP), a part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, …
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PIA Continues to Engage with Commissioners
As the global pandemic caused by COVID-19 (also referred to as the novel coronavirus) continues to upend the insurance industry and the economy as a whole, PIA National has offered to collaborate with state insurance leaders via the National Association of Insurance Commissioners (NAIC) and the National Insurance Producer Registry (NIPR). PIA National is represented …
The $2 Trillion Relief Bill at a Glance
On March 25, the U.S. Senate unanimously approved H.R. 748, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, a $2 trillion emergency package intended to provide urgently needed aid to several sectors of the economy. The House is set to vote on it tomorrow. PIA National has put together this chart to identify, to the …
What Ever Happened to NARAB?
The statutory creation of the National Association of Registered Agents and Brokers (NARAB) was included in the 2015 law reauthorizing the terrorism risk insurance program (the Terrorism Risk Insurance Program Reauthorization Act of 2015, which became P.L. 114-1). (More recently, you may remember that the terrorism risk insurance program was reauthorized again in December of …
