Pace of Activity Increases for SLA
Activities involving the Surplus Line Association, the Department of Insurance and authors of bills in both houses of-the state legislature have greatly accelerated since the last newsletter. Members of your Executive and Legislative Committees and the Stamping Office, along with outside counsel, have worked closely in strategizing how best to address each of the issues at hand. The Chairman of the Legislative Committee goes into greater detail concerning the myriad activities in Sacramento in the legislative column.
Importantly, since the last newsletter, ER 2174 and permanent 2174, have been proposed twice by the Department of Insurance (DOI) with our opposing both ER 7174's in our submission to the Office of Administrative Law (OAL). It should be noted ER 2174 was rejected by the OAL.
When the DOI submitted the second emergency regulation, now known as ER 23C, they withdrew the first permanent regulation 2174 and submitted a new one which had its hearings on July 28 and 29, 1992. The SLA again asked OAL to reject the new emergency regulation for several substantive reasons, but to no avail. The regulation became effective June 12, 1992 to run its normal life span, ending approximately October 12, 1992. By that time the DOI expects to have permanent regulation 2174 approved and moving. In the interim you will receive a definitive bulletin from the SLA on ER 23C.
The SLA submitted its comments on this proposed permanent regulation within the proper time frame. We hope that each of you thoroughly reviewed your copy and made comments to the DOI in writing concerning negative impacts on your transactional activities.