Beginning in 2016, insurance regulators in all states and the District of Columbia ("States") agreed to participate in a data call to collect information related to terrorism risk insurance to serve important regulatory objectives, such as monitoring the affordability and availability of insurance coverage for acts of terrorism and assessing insurers' financial exposure to terrorism risk. Prior to 2018, States and Treasury collected data individually concerning terrorism risk insurance. Beginning in 2018, Treasury and the States took a consolidated approach designed to permit companies subject to both data calls to submit the same information to Treasury and the States using the Joint Reporting Templates.

All insurers who write commercial property/casualty policies in the lines of business subject to the Terrorism Risk Insurance Program, except those subject to exemption as described below, must submit data to both Treasury and the NY Portal. The Terrorism Risk Insurance Act specifically excludes crop insurance, private mortgage insurance, title insurance, financial guaranty insurance, medical malpractice insurance, health or life insurance, flood insurance, or reinsurance (15 U.S.S. 6701 Note, P.L. 107-297). The Act also excludes commercial auto, burglary and theft, professional liability (except for directors and officers liability), and farm-owners multiple peril (P.L. 109-144).

Entities required to submit data on the Joint Data Templates must visit https://www.tripsection111data.com/ to download a registration form for the 2023 data collection. The completed registration form must then be emailed to tripsection111data@iso.com. After the entity's registration is processed, they will be provided with the appropriate data collection template or other specifications for reporting data. The data must be transmitted to Treasury via secure file transfer protocol (SFTP) as well as to the States in Excel format through the New York Portal. Data on the Joint Reporting Template will be due May 15, 2023. If a reporting group or company submits corrected information after an original submission of one or more of the Joint Reporting Templates, it will be expected to resubmit the same corrected data to both the States and Treasury.

STATE PROPERTY SUPPLEMENT

Due to data quality issues limiting the utility of the data received and the recent reauthorization of the Terrorism Risk Insurance Program, state regulators decided to suspend issuance of the State Supplement beginning in 2021. State regulators may nonetheless reinstitute the State Supplement at any time going forward. Therefore, if they have not already, insurers should prepare their systems to enable them to submit the State Supplement data completely and accurately in the future.

EXEMPTIONS

Insurance groups and individual insurers not part of a group with TRIP-eligible commercial direct earned premium of less than $10 million in 2023 are exempt from the 2024 data call (the Joint Reporting Templates and the State Property Supplement).  This exemption does not apply to captive insurers or alien surplus lines insurers.

JOINT REPORTING TEMPLATE

The States and Treasury are requiring insurers to report on a group basis using the appropriate Joint Reporting Template

• Non-Small Insurers - Form | Instructions
• Small Insurers - Form | Instructions
• Captive Insurers - Form | Instructions
• Alien Surplus Lines Insurers - Form | Instructions

For purposes of the 2024 data call (focusing on calendar year 2023 information), insurance groups or entities that had both policyholder surplus and direct earned premium in the TRIP-eligible lines of insurance of less than $1 billion (each) in 2022 should complete the "small insurer" Joint Reporting Template. Insurance groups or entities that had either policyholder surplus and direct earned premium in the TRIP-eligible lines of insurance of greater than $1 billion (each) in 2022 should complete the "non-small insurer" Joint Reporting Template.

Data from insurers writing workers' compensation insurance has been collected via a separate data call. However, the Joint Reporting Templates do require completion of data pertaining to excess workers compensation coverage. Reporting insurers who only write workers' compensation policies are still required to register for data collection and submit certain data elements on the Joint Reporting Template. Please visit https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-fiscal-service/federal-insurance-office/terrorism-risk-insurance-program/annual-data-collection or contact tripsection111data@iso.com for more information on what is required for insurers writing workers compensation or excess workers compensation coverage.

The NAIC's International Insurance Department ("IID"), through the NAIC's Surplus Lines (C) Working Group, has historically collected terrorism risk insurance data at an insurer level from alien surplus lines insurers. The IID will continue to collect such data, which is equivalent to what is being sought in Treasury's alien surplus lines Joint Reporting Template and the IID's data collection will remain separate from this data call. More information on this subject can be found at: https://content.naic.org/cmte_c_surplus_lines_wg.htm