2025 Terrorism Risk Insurance Program Data Call
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Abstract
Pursuant to the Terrorism Risk Insurance Act of 2002, as amended (TRIA), insurers that participate in the Terrorism Risk Insurance Program (TRIP or the Program) are directed to submit information for the 2025 TRIP Data Call, which covers the reporting period from January 1, 2024 to December 31, 2024. Participating insurers are required to register and report information in a series of forms approved by the Office of Management and Budget (OMB). All insurers writing commercial property and casualty insurance in lines subject to TRIP, subject to certain exceptions identified in this notice, must respond to this data call no later than May 15, 2025.
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<title>Federal Register, Volume 90 Issue 74 (Friday, April 18, 2025)</title>
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[Federal Register Volume 90, Number 74 (Friday, April 18, 2025)]
[Notices]
[Pages 16593-16595]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-06704]
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DEPARTMENT OF THE TREASURY
2025 Terrorism Risk Insurance Program Data Call
AGENCY: Departmental Offices, U.S. Department of the Treasury.
ACTION: Data collection.
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SUMMARY: Pursuant to the Terrorism Risk Insurance Act of 2002, as
amended (TRIA), insurers that participate in the Terrorism Risk
Insurance Program (TRIP or the Program) are directed to submit
information for the 2025 TRIP Data Call, which covers the reporting
period from January 1, 2024 to December 31, 2024. Participating
insurers are required to register and report information in a series of
forms approved by the Office of Management and Budget (OMB). All
insurers writing commercial property and casualty insurance in lines
subject to TRIP, subject to certain exceptions identified in this
notice, must respond to this data call no later than May 15, 2025.
DATES: Participating insurers must register and submit data no later
than May 15, 2025.
ADDRESSES: Participating insurers will register through a website that
has been established for this data call. After registration, insurers
will receive data collection forms through a secure file transfer
portal, and they will submit the requested data through the same secure
portal. Participating insurers can register for the 2025 TRIP Data Call
at <a href="https://tripsection111data.com">https://tripsection111data.com</a>. Additional information about the
data call, including sample data collection forms and instructions, can
be found on the TRIP website at <a href="https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-fiscal-service/federal-insurance-office/terrorism-risk-insurance-program/annual-data-collection">https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-fiscal-service/federal-insurance-office/terrorism-risk-insurance-program/annual-data-collection</a>.
FOR FURTHER INFORMATION CONTACT: Richard Ifft, Lead Management and
Senior Insurance Policy Analyst, Terrorism Risk Insurance Program,
Federal Insurance Office, Room 1410, Department of the Treasury, 1500
Pennsylvania Avenue NW, Washington, DC 20220, (202) 622-2922; or
Mallory Marchant, Policy Advisor, Federal Insurance Office, at (202)
622-4793. Persons who have difficulty hearing or speaking may access
these numbers via TTY by calling the toll-free Federal Relay Service at
(800) 877-8339.
SUPPLEMENTARY INFORMATION:
I. Background
TRIA \1\ created the Program within the U.S. Department of the
Treasury (Treasury) to address disruptions in the market for terrorism
risk insurance, to help ensure the continued availability and
affordability of commercial property and casualty insurance for
terrorism risk, and to allow for the private market to stabilize and
build insurance capacity to absorb any future losses for terrorism
events. The Program has been reauthorized on a number of occasions, and
was most recently extended until December 31, 2027.\2\ TRIA requires
the Secretary of the Treasury (Secretary) to collect certain insurance
data and information from insurers on an annual basis regarding their
participation in the Program.\3\ TRIA also requires the Secretary to
prepare a biennial study on the competitiveness of small insurers in
the terrorism risk insurance marketplace (Small Insurer Study).\4\ The
next Small Insurer Study must be submitted to Congress by June 30,
2025. The Federal Insurance Office (FIO) is authorized to assist the
Secretary in the administration of the Program,\5\ including conducting
the annual data call and preparing reports and studies required under
TRIA.
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\1\ Public Law 107-297, 116 Stat. 2322, codified at 15 U.S.C.
6701, note. Because the provisions of TRIA (as amended) appear in a
note, instead of particular sections, of the United States Code, the
provisions of TRIA are identified by the sections of the law.
\2\ Terrorism Risk Insurance Program Reauthorization Act of
2019, Public Law 116-94, 133 Stat. 2534.
\3\ TRIA, section 104(h)(1). Treasury regulations also address
the annual data collection requirement. See 31 CFR 50.51, 50.54.
\4\ TRIA, section 108(h).
\5\ 31 U.S.C. 313(c)(1)(D).
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FIO will be using the same data collection form for Small Insurers
that was used during the 2024 TRIP Data Call. For Alien Surplus Lines
Insurers, Captive Insurers, and Non-Small Insurers, FIO has eliminated
a number of lines from the Geographic Exposures (US) Worksheet (which
Small Insurers do not complete), which will reduce the burden for those
insurers. FIO solicited public comment concerning these forms after
their use during the 2024 TRIP Data Call, and before the reduction in
certain reporting elements,\6\ and received no substantive comments in
response. The forms were then submitted for approval to the Office of
Management and Budget (OMB), with the reduction in requested data
elements on the Geographic Exposures (US) Worksheet, pursuant to the
requirements of the Paperwork Reduction Act. Only one comment was
received in connection with that notice, which addressed the TRIP Data
Call but did not offer any comments concerning the substance of the
forms.\7\ The data collection forms have now been approved for use by
OMB under Control Number 1505-0257 for a period ending April 30,
2028.\8\
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\6\ Agency Information Collection Activities, Proposed
Collection, and Comment Request; Terrorism Risk Insurance Program-
Data Collection Forms, 89 FR 93,405 (Nov. 26, 2024).
\7\ The comment states that Treasury is not collecting
sufficient data on captive insurers in its TRIP Data Calls because
``only a small number of captive insurance companies participating
in the program respond to Treasury's compulsory data calls . . . .''
See Comment of Centers for Better Insurance (March 8, 2025), <a href="https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202502-">https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202502-</a> 1505-004.
Treasury has addressed the number of reporting captive insurers in
previous reports. See, e.g., Federal Insurance Office, ``Report on
the Effectiveness of the Terrorism Risk Insurance Program'' (2024),
66-72, <a href="https://home.treasury.gov/">https://home.treasury.gov/</a> system/files/311/2024
ProgramEffectivenessReport FINAL6.28.2024508.pdf (2024 TRIP Report).
Not all captive insurers are required to report in the TRIP Data
Calls for a variety of reasons; large captive managers report that
only about 15 percent of all captives they manage are required to
report in the TRIP Data Calls. See 2024 TRIP Report at 66, n.170
(reflecting that only 240 of 1600 captives were required to report).
That percentage is consistent with the number of captives that do
regularly report to Treasury, and Treasury will continue to engage
with state regulators and the captive insurance industry in this
area .
\8\ Office of Information and Regulatory Affairs, Office of
Management & Budget, OMB Control No. 1505-0257, <a href="https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202502-1505-004">https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202502-1505-004</a>.
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II. Elements of 2025 TRIP Data Call
For purposes of the 2025 TRIP Data Call, FIO, state insurance
regulators, and the National Association of Insurance Commissioners
(NAIC) will again use the consolidated data call mechanism first
developed for use in the 2018 TRIP Data Call. This approach relies on
four joint reporting templates, to be completed by Small Insurers, Non-
Small Insurers, Captive Insurers, and Alien Surplus Lines Insurers,
each as defined below. The use of joint reporting templates is designed
to satisfy the objectives of both Treasury and state insurance
regulators, while also reducing the burden on participating insurers.
State insurance regulators or the NAIC will provide separate
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notification regarding the reporting of information into the state
reporting portal, including any reporting requirements to state
insurance regulators that are distinct from the Treasury requirements.
Insurers subject to the consolidated data call that are part of a group
will report on a group basis, while those that are not part of a group
will report on an individual company basis.
A. Reporting of Workers' Compensation Information
The TRIP Data Call requests certain information relating to
workers' compensation insurance. For the 2025 TRIP Data Call, Treasury
will again work with the National Council on Compensation Insurance
(NCCI), the California Workers' Compensation Insurance Rating Bureau
(California WCIRB), and the New York Compensation Insurance Rating
Board (NYCIRB) to provide workers' compensation data relating to
premium and payroll information on behalf of participating insurers,
either directly or through other workers' compensation rating bureaus.
The data aggregator used by Treasury will provide such insurers with
reporting templates that do not require them to report this workers'
compensation data. Reporting insurers that write only workers'
compensation policies are still required to register for the 2025 TRIP
Data Call and provide general company information and data related to
private reinsurance. The data received from NCCI, the California WCIRB,
and the NYCIRB will be merged with the information provided by the
insurers.
B. Reporting Templates
Treasury has not incorporated any material changes to the Small
Insurer reporting templates used in the 2024 TRIP Data Call.\9\ For
Alien Surplus Lines Insurers, Captive Insurers, and Non-Small Insurers,
FIO has eliminated a number of lines from the Geographic Exposures (US)
Worksheet (which Small Insurers do not complete), which should reduce
the burden for those insurers. The same reporting exceptions apply this
year as applied in the 2024 TRIP Data Call, as specified further below
in the discussions for each category of insurer.
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\9\ The 2025 TRIP Data Call will include a new modeled loss
scenario identified in the Reinsurance Worksheet that will be used
in connection with the modeled loss questions (which have not
changed from those posed in prior data collections). The modeled
loss questions must be completed by Non-Small Insurers, Alien
Surplus Lines Insurers, and Captive Insurers. As in prior years,
Small Insurers will complete a separate Reinsurance Worksheet that
does not contain modeled loss questions.
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Various worksheets used in the 2025 TRIP Data Call seek certain
information relating to workers' compensation insurance. NCCI, the
California WCIRB, and the NYCIRB will complete the workers'
compensation elements of these worksheets on behalf of reporting
insurers. Further information concerning the reporting templates for
each category of insurer, and the individual worksheets contained
within each, can be found in the instructions for the reporting
templates for each category of insurer. The individual reporting
templates and worksheets will also be addressed in the training
webinars discussed below.
For the 2025 TRIP Data Call, an insurer will qualify as a Small
Insurer if it had both a 2023 policyholder surplus of less than $1
billion and 2023 direct earned premiums in TRIP-eligible lines of
insurance of less than $1 billion.\10\ Of this group, Small Insurers
with TRIP-eligible direct earned premiums of less than $10 million in
2024 will be exempt from the 2025 TRIP Data Call.\11\ Neither Captive
Insurers nor Alien Surplus Lines Insurers are eligible for this
reporting exemption. Insurers defined as Small Insurers for the 2025
TRIP Data Call will report the same information to Treasury and to
state insurance regulators (in each case on a group basis), except as
state insurance regulators may separately direct for purposes of the
state data call.
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\10\ Small Insurers are defined in 31 CFR 50.4(z) as insurers
(or an affiliated group of insurers) whose policyholder surplus for
the immediately preceding year is less than five times the Program
Trigger for the current year, and whose direct earned premiums in
TRIP-eligible lines for the preceding year are also less than five
times the Program Trigger for the current year. Accordingly, for the
2025 TRIP Data Call (covering the 2024 calendar year), an insurer
qualifies as a Small Insurer if its 2023 policyholder surplus and
2023 direct earned premiums are less than five times the 2024
Program Trigger of $200 million.
\11\ Individual insurers with less than $10 million in direct
earned premiums in TRIP-eligible lines that are part of a larger
group must still report as part of the group as a whole if the
group's direct earned premiums in these lines are over $10 million.
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The Non-Small Insurer template will be completed by insurance
groups (or individual insurers not affiliated with a group) that are
not subject to reporting on the Captive Insurer or Alien Surplus Lines
Insurer reporting templates, and had either a 2023 policyholder surplus
of greater than $1 billion or 2023 direct earned premiums in TRIP-
eligible lines of insurance equal to or greater than $1 billion.
Insurers defined as Non-Small Insurers for the 2025 TRIP Data Call will
report the same information to Treasury and to state insurance
regulators (in each case on a group basis), except as state insurance
regulators may separately direct for purposes of the state data call.
Captive Insurers are defined in 31 CFR 50.4(g) as insurers licensed
under the captive insurance laws or regulations of any state. Captive
Insurers that wrote policies in TRIP-eligible lines of insurance during
the reporting period (January 1, 2024 to December 31, 2024) are
required to register and submit data to Treasury, unless they did not
provide their insureds with any terrorism risk insurance subject to the
Program.
Alien Surplus Lines Insurers are defined in 31 CFR 50.4(o)(1)(i)(B)
as insurers not licensed or admitted to engage in the business of
providing primary or excess insurance in any state, but that are
eligible surplus line insurers listed on the NAIC Quarterly Listing of
Alien Insurers. Alien Surplus Lines Insurers that are part of a larger
group classified as a Non-Small Insurer or a Small Insurer should
report to Treasury as part of the group, using the appropriate
template. Therefore, the Alien Surplus Lines Insurer template should be
used only by an Alien Surplus Lines Insurer that is not part of a
larger group subject to the 2025 TRIP Data Call.
C. Supplemental Reference Documents
Treasury will continue to make available on the TRIP data
collection website \12\ documents providing a complete ZIP Code listing
for areas subject to reporting on the Geographic Exposures (Nationwide)
Worksheet, as well as several hypothetical policy reporting scenarios.
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\12\ See <a href="https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-fiscal-service/federal-insurance-office/terrorism-risk-insurance-program/annual-data-collection">https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-fiscal-service/federal-insurance-office/terrorism-risk-insurance-program/annual-data-collection</a>.
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D. Training Webinars
As in prior years, Treasury will hold four separate training
sessions corresponding to the four reporting templates that will be
used by insurers (Small Insurers, Non-Small Insurers, Captive Insurers,
and Alien Surplus Lines Insurers). The webinars will be held on April
22 and April 23, 2025 to assist reporting insurers in responding to the
2025 TRIP Data Call, with each webinar focusing on a specific reporting
template. Specific times and details concerning participation in the
webinars will be made available on the TRIP data collection website,
and recordings of each webinar will be made available on the website
following each training session.
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III. 2025 TRIP Data Call
Treasury, through an insurance statistical aggregator, will accept
group or insurer registration forms through <a href="https://tripsection111data.com">https://tripsection111data.com</a>. Registration is mandatory for all insurers
participating in the 2025 TRIP Data Call. Upon registration, the
aggregator will transmit individualized data collection forms (in Excel
format) to the reporting group or insurer via a secure file transfer
portal. The reporting group or insurer may transmit a complete data
submission via the same portal using either the provided Excel forms or
a .csv file.\13\
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\13\ Specifications for submission of data using a .csv file
will be provided to the insurer by the aggregator.
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Copies of the instructions and data collection forms are available
on Treasury's website in a read-only format. Reporting insurers will
obtain the fillable reporting forms directly from the data aggregator
only after registering for the data collection process.
Reporting insurers are required to register and submit complete
data to Treasury no later than May 15, 2025. Because of the statutory
reporting deadline for Treasury's 2025 Small Insurer Study to Congress,
no extensions will be granted. Reporting insurers can ask the data
aggregator questions about registration, form completion, and
submission at <a href="/cdn-cgi/l/email-protection#e296908b92918781968b8d8cd3d3d386839683a28b918dcc818d8f"><span class="__cf_email__" data-cfemail="5d292f342d2e383e293432336c6c6c393c293c1d342e32733e3230">[email protected]</span></a>. Reporting insurers may also
submit questions to the Treasury contacts listed above. Questions
regarding submission of data to state insurance regulators should be
directed to the appropriate state insurance regulator or the NAIC.
All data submitted to the aggregator is subject to the
confidentiality and data protection provisions of TRIA and the Program
Rules, as well as to section 552 of title 5, United States Code,
including any exceptions thereunder. In accordance with the Paperwork
Reduction Act (44 U.S.C. 3501-3521), the information collected through
the web portal has been approved by OMB under Control Number 1505-0257.
An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
control number.
Dated: April 15, 2025.
Steven E. Seitz,
Director, Federal Insurance Office.
[FR Doc. 2025-06704 Filed 4-17-25; 8:45 am]
BILLING CODE 4810-AK-P
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