Business Insurance

Terrorism Risk Insurance Act

Chapter Eight

September 11th, 2001 marked a change in how America views terrorism: we were attacked on our own soil by terrorists.  As a result of this act, TRIA was enacted in 2002 with the expectation of expiring by 2006.  Congress expected private insurance to develop policies by that date that would provide the protection given by the Terrorism Risk Insurance Act (TRIA).  It looked likely that Congress would not renew TRIA.

  That view was changed with the terrorist attack on London in mid-2005.  In July 2005 Treasury Secretary John Snow said: “Nobody is talking about ending the backstop.  What we’re talking about is revamping.”  He added that they wanted to make some improvements that still allowed private insurers to assume a larger role in providing businesses with terrorism insurance.

  The cost of terrorist acts is staggering.  According to the Insurance Information Institute, damage from the July 7^th London bomb attacks will rank far below the top five costliest terror attacks.  Ranked by insured property losses, adjusted to 2004 cost levels, include:

1. September 11^th, 2001 World Trade Center and Pentagon attacks: $34.7 billion and 2,995 deaths.

2. April 24^th, 1993 bomb near NatWest tower in London: $967 million and 1 death.

3. June 15^th, 1996 IRA car bomb near Manchester Mall: $794 million and no deaths.

4. February 26^th, 1994 bomb in the World Trade Center garage: $773 million and 3 deaths.

5. April 10^th, 1992 bomb in London’s Financial District: $716 million and 3 deaths.

6. The Oklahoma City bombing in 1995 and the Madrid bombing in 2004 each resulted in more than 150 deaths with insured losses over $100 million each.

  It has been suggested that TRIA was designed in haste due to the circumstances that triggered it (the September 11^th terror attack).  As a result there is need for revisions.  Some have charged that the Terrorism Risk Insurance Act primarily took the place of the terrorism reinsurance market preventing the market from adapting and creating new products, although the intention had been to allow insurers time to do so.  Not all agree, of course.

Act of Terrorism

  In order to come under TRIA, an aggressive act must fit the definition of terrorism.  To qualify, the act must be certified by the Secretary of the Treasury, in concurrence with the Secretary of State and the Attorney General of the United States to be an act of terrorism.  It may be further defined as a violent act or an act that is dangerous to human life, property, or infrastructure of the United States resulting in damage within the United States, or outside the United States in the case of an air carrier or vessel or the premises of a United States mission, committed by an individual or group of individuals acting on behalf of any foreign person or foreign interest, as part of an effort to coerce the civilian population of the Untied States or to influence the policy or affect the conduct of the United States Government by coercion.

TRIA

  Prior to the 2001 terrorist attack, few people considered the need for insurance to cover such a loss.  The Terrorism Risk Insurance Act, called TRIA, was designed to make coverage available for acts of terrorism.  The intent of TRIA was to provide a bridge of time allowing private insurers the ability to develop this type of policy. Following the enactment of TRIA, terrorism insurance became readily available for those who felt the need to have it.  This legislation was necessary for two primary reasons:

• TRIA required the federal government to share the risk of loss from terrorist attacks so that the insurance industry did not have to carry the entire load alone.

• It enacted a “make available provision”, that required insurers to offer terrorism insurance to policyholders on the same terms and conditions as other types of property and casualty insurance.

  TRIA was intended to be a temporary measure, expiring on December 31, 2005.  It is important to note the law now requires all insurance companies doing business in the U.S. to offer terrorism insurance coverage on the same terms and conditions under which they offer property and casualty coverage.  As previously stated, it was known as the “make available” provision.

  Although September 11^th, 2001 was not the first terrorist act on American soil, it was the first time we realized how vulnerable we were to the terrorists of other nationalities.  Until that event, most people assumed any threat came from home-grown terrorists, such as Timothy McVeigh’s act in 1995, rather than extremists from other countries.  Suddenly American policyholders became interested in purchasing insurance to help them recover financially from outside acts of terrorism. 

  Although the House Financial Services Committee approved H.R. 4634, “The Terrorism Insurance Backstop Extension Act of 2004”, Congress adjourned on October 9^th, 2004 without passing the bill.  This piece of legislation would have extended TRIA though 2007 and would have expanded its scope to include group life insurance.

  With the federal government sharing in losses, law sets the retention level.  In 2003 it was seven percent of direct earned company premiums, in 2004 it rose to 10 percent, and in 2005 it increased to 15 percent.

  The intent has always been for private insurers, not the government, to provide adequate capacity to meet the demand for terrorism coverage.  TRIA was never intended to be a permanent measure.  However, many professionals feel the private insurance markets still have not completely stabilized.  This can be seen in the lack of reinsurance available for the retained loss amounts held by private direct insurers, even though the potential loss is quantifiable as measured by the individual company retention amount.  There is little terrorism insurance coverage being offered by private carriers for such things as chemical, biological or radiological events, despite the fact that the federal backstop would cover these losses if they were insured against.

  Insurers are notifying their customers of the terrorism insurance act.  For example, commercial policies issued by Farmer’s Insurance Group states in part:

“Dear Valued Customer: You should know that as part of the Terrorism Risk Insurance Act of 2002, coverage for certified acts of terrorism is made available as part of the coverage under your policy.

Coverage provided by this policy for losses caused by certified acts of terrorism is partially reimbursed by the United States under a formula established by federal law.  Under this formula the United States pays 90% of covered terrorism losses that exceed the statutorily established deductible paid by the insurance company providing the coverage.”

  The previous statement was issued for commercial policies.  Not all policies types are the same, of course, so agents and policyholders must examine their contracts for exact details.

President Bush Signs TRIA

  Signed into law on November 26^th, 2002 by President Bush, the Terrorism Risk Insurance Act was intended to be a temporary federal system of shared public and private compensation for insured losses resulting from certified acts of terrorism.  The established definition of terrorism must be met in order to be covered by TRIA.  By insuring terrorist risks consumers could be protected from market disruptions while providing continued availability and affordability of property and casualty insurance.  Additionally it allowed for a transitional period for the private markets to stabilize, and resume pricing of this type of insurance, build capacity to absorb any future losses, and preserve state insurance regulation and consumer protections.

  This was important legislation for several reasons, including the financial climate in the United States following the tragic events of September 11th, 2001.  The legislation was intended to stimulate business investments, which had seriously declined following the acts of terrorism against America.  The law created a three-year federal program that backed up insurance companies and guaranteed that certain terrorist-related claims could be paid.

It is important to note that TRIA was designed to be a short-term measure enabling the insurance market time to recover and develop new solutions.

    The 9/11 terrorist attacks resulted in approximately $34.7 billion in insured losses.  Of course, there were additional uninsured losses.  The insured losses involved many types of insurance coverage, including commercial property, business interruption, workers compensation, aviation, life and disability insurance.  The potential of huge losses from terrorism cannot be ignored.  Obviously, the companies that insure these types of losses also cannot ignore the possibilities.

The Role of Terrorism Insurance

  There was a time when risk of terrorism in America seemed equal to the risk posed by volcanic eruption in the continental US; yes, it was possible (consider Mt. St. Helens), but the likelihood did not seem great.  Since the attack on the World Trade Center, we no longer view it the same.  Terrorism insurance provides coverage to policyholders and insured businesses for potential losses due to acts of terrorism that meet the required definition.  Before 9/11/2001, standard commercial insurance policies included terrorism coverage as part of the package, effectively free of charge.  Today, terrorism coverage is generally offered separately at a price that is more adequate in terms of current risk.  Insurance losses that can be attributed to terrorist acts under these contracts are insured by private insurers and then reinsured or “backstopped” by the federal government as a result of the Terrorism Risk Insurance Act of 2002 (TRIA).  Under TRIA, owners of commercial property, which would include such things as office buildings, factories, shopping malls, and apartment buildings, must be offered the opportunity to purchase terrorism coverage.  The events of September 11^th, 2001 obviously impacted how we looked at terrorism insurance.  A June 2004 report from insurance broker Marsh, Inc. found that the proportion of U.S. businesses that purchased terrorism insurance during the first quarter of 2004 rose to its highest level following the enactment of TRIA.  Marsh, Inc. states that 44.2 percent of U.S. businesses purchased terrorism coverage in the first quarter of 2004.  That compares with a 32.7 percent purchase rate for the fourth quarter of 2003.

  While business property would probably be the most likely targets for terrorists, individual property owners would not be immune from damage as a side affect of terrorist activity.  Standard homeowners insurance policies include coverage for damage to property and personal possessions resulting from acts of terrorism.  Terrorism is not specifically referenced in most homeowner policies, but these types of contracts do cover the homeowner for damage due to explosion, fire and smoke.  Since this is the type of damage that is likely to happen during a terrorist attack the homeowner has coverage under these circumstances unless terrorism is specifically excluded.

Condominium or co-op owner policies provide coverage for damage to personal possessions resulting from acts of terrorism since these types of structures are similar to apartment buildings.  Damage to common areas of a building (including the roof, basement, elevator, boiler, and walkways) would only be covered if the condo or co-op board has purchased terrorism coverage.

  Standard renters policies provide coverage for damage to personal belongings as a result of a terrorist attack.  As previously stated, damage to the apartment complex itself would only be covered if the owners had purchased such coverage for terrorism.

  Auto insurance policies will cover a car that is damaged or destroyed in a terrorist attack only if the insured has purchased “comprehensive coverage.”  Most people who have loans on their vehicles or leases for their vehicles are required by the lenders and leasing companies to carry this optional form of coverage.  People who buy liability coverage only are not covered for damage resulting from terrorist attacks.

  Life insurance policies do not typically contain terrorism exclusions.  Proceeds will be paid to the beneficiary as designated in the policy.

  Commercial policies will pay for a terrorist attack as long as the Secretary of the Treasury has declared it to be a certified terrorist attack, termed a “certified act”.  Such a declaration by the Secretary of the Treasury is not required to trigger coverage under home and auto policies because there are no exclusions for terrorism.

  Some states may require a doctrine known as “fire following” in order to be covered.  What does this mean?  If a terrorist attack results in a fire that causes damages, insurers could be liable for losses attributable to the fire, but not necessarily for the explosion that caused the fire.  Even if a commercial property owner had not bought terrorism coverage, he or she might be covered for the damage caused by the fire.  Due to this fact, many insurers are now lobbying to limit fire coverage resulting from a terrorist attack, because commercial policyholders that choose to reject TRIA or other terrorism coverage are effectively paying no premium for the protection offered by fire-following coverage.  Several states have responded to the requests of insurers by amending their standard fire policy laws to exclude acts of terrorism.

No Policy Covers Everything

  Every policy excludes or limits claims.  There are restrictions regarding war coverage and nuclear, biological, chemical and radiological events in both personal and commercial insurance policies. Nuclear, biological, chemical and radiological events are typically referred to as NBCR.  Acts of war are fundamentally uninsurable, which is reflected in the war-risk exclusions.  Additionally, if we are under attack due to war, whether or not our insurance policy will cover the event is probably not our main focus at that point.

  No formal declaration of war by Congress is required for the war risk exclusion to apply.  Nuclear, biological, chemical and radiological (NBCR) attacks are another example of catastrophic events that are fundamentally uninsurable due to the nature of the risk.  Under the Terrorism Risk Insurance Act, if some NBCR exclusions are permitted by a state, an insurer does not have to make available the excluded coverage.

Business Interruption Due to Terrorism

  Many types of business could not conduct their trade as they normally would following a terrorist attack.  Although some businesses were able to regroup and continue operating after the September 11^th attack many others were not able to.  It can depend upon many variables including the type of business, whether or not special operating conditions are necessary (such as would be the case for manufacturing companies), and whether or not key people were injured or killed during the attack.

  Property damage to commercial buildings following a terrorist attack may cause the inability of some companies to quickly resume the normal course of business.  Therefore, their business has been interrupted as a result of the terrorist attack.  Those that carry business interruption insurance will be submitting claims.  Business interruption insurance is sometimes referred to as business income coverage.  It covers the financial losses that occur when a company is forced to suspend their normal business operations either due to direct damage or because civil authorities have found it necessary to limit access to the area that was attacked.  Policies will vary, but typically coverage begins after a waiting period (called a “time deductible”).  This waiting period will depend upon the policy written, but it is often two or three days.  The length of benefits will also depend upon the policy.  They are written for anywhere from two weeks to several months.

  Business interruption losses associated with acts of civil authority, meaning the closure of specified areas around the location of the terrorist act, can only be triggered when there is physical loss or damage as a result of the covered peril.  The peril would probably be explosion, fire, or smoke, but it could include additional perils.  The damage does not have to actually occur to the actual business structure. 

Example:

  ABC insurer is located in the building next to one that was bombed during a terrorist act.  Although the actual location of ABC insurer was not damaged, due to the fire of the building that was hit, there is heavy damage, causing the possibility of a building collapse along with smoke drifting through the area.  In the name of safety, the entire area is closed off.  Even though ABC insurer could operate from their building, since civil authorities have declared it off-limits, there business interruption policy will cover their losses, subject to policy limitations.

Workers Compensation and Other Coverage

  Workers compensation would automatically cover those who were injured or killed on the job, if the injury or death resulted while in the workplace or while performing activities for the employer at the time of their injury or death.  Workers Compensation is a compulsory line of insurance for all businesses.  Workers compensation is also the only line of insurance that does not exclude coverage for acts of war.  Coverage for terrorist acts cannot be excluded from workers compensation policies in any state.

  There are three basic types of workers compensation benefits:

• Reimbursement for a workers lost wages while they recover from an injury.

• Coverage for all medical expenses incurred as a result of the injuries received.

• Payments to the families of workers killed on the job.

  There may be additional benefits available under an individual’s life, health, or disability policy.

TRIA Coverage

  TRIA is a combination of public and private risk sharing between the federal government and the insurance industry.  The program is designed to ensure that adequate resources are available for businesses to recover and rebuild if they become the victims of a terrorist attack.  There are specific requirements in the legislation.  Although it is likely that the original provisions of TRIA will be modified, the initial provisions included:

1. The event must cause at least $5 million in aggregate property and casualty insurance losses, which must be certified by the Secretary of the Treasury as an act of terrorism.  If the event were not so certified, it would not be considered under the terms of the Terrorism Risk Insurance Act.  (It has been proposed that the $5 million mark be raised to $500 million for the event size that triggers coverage, as well as increasing dollar deductibles and percentage of co-payments, while eliminating certain lines of insurance.)

2. The bill is limited to international terrorism committed on behalf of any foreign person or foreign interest on U.S. soil.  Therefore, the bombing that occurred in Oklahoma would not have qualified had this Act been in effect at that time.

3. Damage to an air carrier or vessel outside of the U.S. or to the premises of a U.S. mission is covered by TRIA even though it may not occur on our soil.

4. Each participating insurer is responsible for paying out a certain amount in claims, considered a deductible, before Federal assistance becomes available.  This deductible is based on a percentage of direct earned premiums for the calendar year 2002.  The deductibles were:

1. 2002: 1% from enactment through the end of the year.
2. 2003: 7%
3. 2004: 10%
4. 2005: 15%

5. For losses above a company’s deductible the federal government will cover 90 percent while the insurance companies contribute 10 percent. 

6. If the federal government pays for insured losses during the course of a year, the Treasury Secretary will be required to recoup the difference between total industry costs (individual insurers’ losses up to their deductibles, plus the industry’s 10% cost share above the deductibles) and the following dollar amounts per year:

1. The aggregate insurance industry retention in 2002 and 2003 was $10 billion,
2. For 2004 it was $12.5 billion, and
3. $15 billion in 2005.

7. Losses covered by the program are capped at $100 billion.  Above this amount, Congress must determine the procedures for and source of any payments.

8. Lines excluded from the program are personal lines (home and auto), assumed reinsurance, federal crop, mortgage guaranty, financial guaranty, medical malpractice, flood insurance, and life and health products.

9. The Terrorism Risk Insurance Act was initially a three year program, which was scheduled to sunset December 31^st, 2005.

  The Terrorism Risk Insurance Act applies only to provisions of policies written after the legislation’s enactment.  There are several key benefits:

1. Capacity was returned to the market at a time when it was critical to supply it.

2. Without this legislation, insurers were looking at an almost incalculable risk.  Even seasoned analysts were not willing to predict what losses might total from another attack.  TRIA allowed the potential risk to individual companies to be quantified, which enabled the market to function again.

3. The bill does not establish the status quo that existed prior to September 11^th, 2001.  There has been a fundamental change in the nature of risk in our society.  We know that the possibility of future attacks is real and must be considered.

4. The cost of terrorism coverage will depend on many factors, including whether or not we experience another terrorist attack of some sort.  Current market conditions will not change overnight.  There will be added capacity, but individual companies must still make decisions about the nature and amount of risk they want to insure.

5. The reinsurance industry took the most significant hit from 9/11.  More than half of the losses were theirs.  They were unable to assume the same amount of terrorism risk as they had prior to September 11^th, which was the reason it was so important for the federal government to step in.

6. Many of the small and mid-sized businesses across the country experienced little change from TRIA.  Their premiums have increased for other reasons, but the terrorism coverage did not add much to their total insurance costs.  The major problem remains the threat of chemical, biological, nuclear and radiological attacks on high profile companies or structures.  Since terrorists want to make a major statement only high profile companies, buildings, or events are likely to be focused on.  Events or locations containing a large concentration of people will have greater risk than those with few people.  For some companies and groups that fit the high-risk scenarios, the premium cost of terrorism insurance will be high due to the greater risk that is covered.

    The total insured loss for the World Trade Center, Pentagon, and Pennsylvania events amounted to $34.7 billion.  As previously stated, this did not include uninsured losses.  Even with federal support, the insurance industry’s share of the risk under TRIA was huge.  The recoupment will be accomplished through a surcharge on all policyholders.  The surcharge cannot be more than 3 percent of the premium paid for a policy in a given year.

  TRIA did affect the availability and pricing of coverage for terrorism acts.  By sharing the potential losses between private insurers and the federal government, the risk was not as great as it might otherwise have been.  TRIA brought additional capacity to the terrorism market.  Before the Act, businesses were left with little or no terrorism coverage, but now they are able to purchase needed insurance protection.

  Pricing terrorism coverage is not easy.  Because the frequency and severity of an attack is so unpredictable (and insurers have little past statistical information to use during ratemaking) it is difficult to determine the potential losses of such an event.  There are some valuations that can be made.  For example, it is more likely that a sporting arena would be a target than would a residential area.  Therefore, the sporting arena carries a greater risk.  Some industries are more likely to be a terrorist target than others.  A shopping mall is a more likely target than a neighborhood dry cleaner, for example.  Despite the difficulties in pricing terrorism insurance, it does appear that TRIA has had a stabilizing influence.

  TRIA does require all property and casualty insurers in the United States to make terrorism coverage available.  The “make available” provision applies to commercial lines of property/casualty insurance.  Insurers are required to make an offer of coverage for “certified acts”.  If the insured rejects the coverage, the insurer may then reinstate the terrorism exclusion.  Once terrorism is excluded in the policy, if a terrorist act occurs, the commercial policyholder would not receive compensation for any damages or loss.  An individual who has homeowners or renters coverage might be covered, depending upon their policy.  If payment were received, it would be received according to the individual terms of their policy.

  The “make available” provision initially was to end in 2004, but in June of that year the Treasury Department extended this provision through the end of 2005.  With the July 7^th, 2005 bombing in London there was renewed interest in continuing the “make available” provision.  London’s bombing was insured through a captive program, London Transport Insurance (Guernsey).  Because it was an act of terrorism, it falls into the Pool Re agreement where insurers who are part of the group share in the losses.  Pool Re is the United Kingdom’s public-private reinsurance arrangement.  It will not cover the losses resulting from business interruption, which are likely to be absorbed by the Transport for London (TfL).

  While there is no guarantee that Congress will extend TRIA, London’s events make it likely to happen.  If it is not extended, any commercial insurance policy with an inception date beyond January 1^st, 2005 will include a period where no federal “backstop” is in place.  Attacks occurring on or after January 1^st, 2006 could be financially destabilizing and lead to insurer insolvencies.  Insurers and regulators are developing language that would allow insurers to exclude losses associated with terrorist attacks, except for workers compensation, which will continue to cover them.  The majority of the states approved such exclusions in the pre-TRIA period.[1]

  There is great pressure to extend the Terrorism Risk Insurance Act for two years (through December of 2007).  Businesses, professional societies, and insurance agents and brokers support such a move on the part of Congress.  There is fear that failure to renew the Act would leave insurers vulnerable.  The effect of multiple insurers going insolvent is difficult to predict, but everyone feels it would financially cripple to our entire country.  Many types of businesses are able to operate only because they have insurance.  Would banks make a car loan if no insurance could be purchased to protect their collateral?  Would a financial institution make a loan to a business if they could not secure it with insurance?

Contingency Plans Drafted by PC Insurers

    It isn’t just the insurers that have been anxious to have TRIA renewed.  Those who purchase terrorism insurance are also worried that the ability to purchase it will end with the Terrorism Risk Insurance Act.  In a letter to President Bush dated June 8^th, 2005, buyers of terrorism insurance calling itself the Coalition To Insure Against Terrorism voiced their concern.  They represented all types of commercial insureds although groups representing real estate interests organized it.

  Property-casualty companies have a great deal to lose if TRIA is not renewed.  Both the Property-Casualty Insurers Association of America (PCI) and the American Insurance Association (AIA) have drafted contingency plans in the event that TRIA is allowed to expire or renewed with “pared back” provisions.[2]   Some members of Congress feel the private insurance sector will step forward if the Terrorism Risk Insurance Act is not there; others doubt their ability to do so and their desire to do so.

  The Property Casualty Insurers Association of America suggests that the government could encourage the development of a viable private market for terrorism-related catastrophe bonds by providing tax incentives that would facilitate issuance of pre-event bonds.  This would allow companies the ability to better manage the retained exposure at acceptable levels.

  The AIA has proposed that, as a long-term option, the government consider accepting all responsibility for chemical, biological, nuclear and radiation risks, while the private market deals with the liability associated with the lesser risks of terrorism.

TRIA’s Uncertain Future

  Initially we heard a lot about TRIA, the Terrorism Risk Insurance Act.  However, as Americans began to feel more confident that another attack was not imminent it faded to a back burner.  With London’s attack, TRIA is again the focus of many.  Property-casualty insurers and commercial insurance buyers are finalizing battle plans to push for extension of the act, which could end December 31^st, 2005, although it is more likely that a modified version will be passed.

  What are the alternatives for TRIA? 

1. The program may be extended as is for another two years.  This would allow the private market additional time to continue developing their own policies.
2. TRIA could be extended one year.  During this time the Act would be fine tuned for a long-term solution.
3. The program could be cut back in the hope of creating a greater incentive for the private market to develop terrorism insurance outside of the federal government.
4. TRIA could be allowed to lapse, terminating its existence.

  Few people expect the program to be terminated and consider that a worst-case scenario.  It is possible that we will see a series of six-month extensions until a permanent solution is agreed upon.  Many industry specialists feel it will take until 2007 for the private market to adequately develop terrorism insurance.

  According to Rep. Paul Kanjorski, D-PA, the problem lies in the fact that there is nobody at the appointed level at Treasury to marshal the bill through Congress.  The extension of TRIA has not been a pressing issue with the administration until the events in London happened.  Some have questioned whether the government should be involved in yet one more insurance program, especially considering the many funding problems we already face with existing insurance programs (such as Medicare and Medicaid).

  Insurance industry officials have been trying for a year to have the current terrorism reinsurance extended for two years until a permanent solution (through private insurance) can be established.

Congress Clashes Over TRIA’s Future

  Members of Congress seldom agree on any issue and TRIA is no exception.  While few people expect TRIA to completely expire, to what extent it should be renewed has been debated.  Democrats n both the Senate and the House have called for a prompt extension of the Terrorism Risk Insurance Act, National Underwriter reported in their August 2005 article.

  It is likely that some form of TRIA will be passed, although insurance industry leaders have acknowledged that the federal government is likely to play a lesser role.  Insurers are preparing to play a larger role in terrorism risk coverage, realizing that they must inevitably do so.  Jason Schupp, vice president and senior assistant general counsel for Zurich, who also represented the American Insurance Association, told the subcommittee on terrorism: “There remains a critical need for a continuing public-private partnership for terrorism insurance.  This is not an insurance issue – it is a business and national economic security issue.”

London uses a pool reinsurance program for their terrorism coverage.  A representative of the National Association of Mutual Insurance Companies has proposed a similar system for the United States.  A Pool Re (such as that used by the United Kingdom) is a mutual insurance company that is authorized only to write reinsurance relating to terrorism risk on commercial property.  It differs from normal insurers and reinsurers in that it reinsures its liabilities with the British government.  A reinsurance premium is paid to the British government and that reinsurance premium is used to recover any claims that exceed company resources.

  Whatever method is used to extend TRIA, it is likely that change will be continual as private business and government try to find the best fit for everyone.

Thank you,

United Insurance Educators, Inc.

End of Chapter Eight

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[1] Because this chapter was compiled in mid 2005 agents must expect this chapter to date itself as of 2006, unless rewritten at that time.

[2] Insurers, Buyers Brace for TRIA Decision, by Arthur Postal, June 20, 2005