In the fourth episode of our Surplus Lines 360 series, John Emmanuel and Zachary Lerner discuss why using surplus lines insurance to satisfy state financial responsibility requirements can be problematic and varies by state, and why newer rideshare laws provide clarity that traditional commercial auto insurance lacks.Read More Financial Responsibilities in the Surplus Lines Market
UK, Bermuda and EU Markets: For US Business, Ditch Direct Procurement, Go Surplus Lines
This article was originally published on Insurance Business UK and is republished here with permission as it originally appeared on December 23, 2025.
It’s a tale as old as time: A U.S. insurance broker wants to place bespoke coverage for its U.S. client. Sometimes, it’s a layer within a commercial tower. Perhaps there are some participating admitted (licensed) U.S. carriers, mixed in with an array of eligible surplus lines insurers. But alas, satisfying all layers through the admitted and surplus lines markets proves allusive, so the broker approaches an unauthorized carrier in Bermuda, a European country, or another non-U.S. jurisdiction. It makes sense, right? The broker tried its best to find coverage another way, and it wants to do right by its client.Read More UK, Bermuda and EU Markets: For US Business, Ditch Direct Procurement, Go Surplus Lines
Demystifying Surplus Lines Group Insurance
In this episode, John Emmanuel and Zachary Lerner unpack one of the hottest regulatory topics in surplus lines: group insurance. Learn how affiliated and unaffiliated groups are treated under the NRRA, why “home state” determination drives compliance and tax obligations, and the state-by-state rules that can make or break a group structure.Read More Demystifying Surplus Lines Group Insurance
Understanding the Surplus Lines Broker’s Role: Key Responsibilities and Regulatory Insights
Join Troutman Pepper Locke Partners John Emmanuel and Zachary Lerner as they break down the critical role of surplus lines brokers in insurance transactions. Learn the distinctions between admitted and surplus lines markets, the unique responsibilities brokers shoulder, and the regulatory requirements that shape their relationships with agents. Gain practical insights into enforcement actions and the importance of careful delegation in surplus lines placements.Read More Understanding the Surplus Lines Broker’s Role: Key Responsibilities and Regulatory Insights
Introducing Surplus Lines 360
Join Troutman Pepper Locke Partners John Emmanuel and Zachary Lerner as they kick off Surplus Lines 360, a series that demystifies the evolving landscape of surplus lines insurance. In this video, discover what surplus lines are (and are not), how eligibility works for both domestic and alien insurers, the regulatory dynamics between state and federal oversight, and the expanding reach of surplus lines into other coverage areas.Read More Introducing Surplus Lines 360
When Surplus Lines Brokers Are Off the Hook: Connecticut Department Issues Bulletin on New Diligent Effort Exception
On October 10, 2025, the Connecticut Department of Insurance (the Department) issued Bulletin SL-6 (the Bulletin) to restate the requirements generally applicable to surplus lines placements, and to advise that the diligent effort exception established by Public Act 25-87, effective October 1, 2025, only applies to surplus lines brokers when they procure insurance coverage through an unaffiliated wholesale broker. The Bulletin additionally supersedes and rescinds Connecticut Bulletins SL-3 and SL-5.Read More When Surplus Lines Brokers Are Off the Hook: Connecticut Department Issues Bulletin on New Diligent Effort Exception
California Commissioner Announces Proposed Changes to Proposition 103 and Intervenor Process
In a press release dated September 19, 2025, Commissioner Ricardo Lara announced proposed changes to California’s rate review and intervenor system. The state’s intervenor system, initially established by Proposition 103 in 1988 and last updated in 2006, currently authorizes “intervenors” to participate in rate review. The system allows intervenors to recover costs, expenses, and attorneys’ fees related to their intervention from insurers. By law, insurers are permitted to pass these costs on to consumers.Read More California Commissioner Announces Proposed Changes to Proposition 103 and Intervenor Process
New York Amends Voidable Transactions Law for Application to Federal Home Loan Banks
On September 26, 2025, Governor Kathy Hochul of New York signed into law AB 5600 (the Bill), which amends N.Y. Ins. Law §7425 to address the treatment of voidable transfers involving Federal Home Loan Banks (FHLBs), as well as the conduct of parties to delinquency proceedings against New York domiciled insurer-members of an FHLB. FHLBs are government-sponsored entities that lend to members on a fully secured basis at a low interest rate. According to the legislative findings accompanying the Bill (the Legislative Findings), FHLBs were created during the Great Depression to provide easy liquidity for banks and insurance companies and to provide a stabilizing mechanism in times of economic uncertainty.[1] Insurance companies and depository institutions must apply for membership, subject to approval by the Federal Housing Finance Agency, and purchase a certain amount of stock in the FHLB to avail themselves of member benefits.[2]Read More New York Amends Voidable Transactions Law for Application to Federal Home Loan Banks
NYDFS Announces Leadership Change: Adrienne Harris to Step Down, Kaitlin Asrow Named Acting Superintendent
New York Governor Kathy Hochul announced today that Adrienne Harris will step down as superintendent of the New York State Department of Financial Services (NYDFS), effective October 18. Following Harris’s departure, Hochul has appointed Kaitlin Asrow to serve as acting superintendent.Read More NYDFS Announces Leadership Change: Adrienne Harris to Step Down, Kaitlin Asrow Named Acting Superintendent
New York Legislators Investigate Residential Property Insurance
What Happened
In a press release published August 25, New York Senators James Skoufis, Jamaal Bailey, and Brian Kavanagh announced a joint investigation into residential property insurance. The purpose of the investigation is “to identify the causes of reported increases in premiums and other obstacles to insuring new and existing single- and multi-family homes, including those occupied by homeowners and renters, and to identify legislation and policy changes that New York State should implement.”Read More New York Legislators Investigate Residential Property Insurance