Vermont Legislature SmartTranscripts:

[Speaker 0]: Good afternoon, everyone. This is the Vermont House Committee on Commerce and Economic Development. It is Tuesday, 01/13/2026, at 02:10 in the afternoon. We're back from a short break, now we're here to take a look at page six forty nine. We have our legislative counsel, Maria Royal, with us to set things up, and we have members from the financial regulation. This is a bill dealing with captive insurance. Maria, welcome. Good to see you again. Hope you had a great summer and fall.

[Speaker 1]: Did. I did. Thank you very much. It's good to be back and see you all again. And you did a great job. You did my part. I'll just say a little bit more than that. As you know, DFRR does typically a captive insurance bill, which this is, and then a more general banking insurance security. Sometimes they're combined. This year, they're not. So you'll look at each six forty eight later in the week. So there are only three provisions here. They all pertain to captive insurance. As you remember, captive insurance is a form of self insurance. There are lots of different structures and models for companies to self insure their risks and manage them rather than buying on the open insurance market. But the first two sections actually concern what are called risk retention groups, which are authorized under federal law, but chartered in states, an individual state where they're domiciled. And the proposal here, with respect to risk retention groups, is that they no longer be allowed to make any loan or investment in its parent company or its parent company's members or affiliates. So risk retention groups are owned by their members, and they tend to be sectors of industry that share similar risks and exposures. So they all get together and try to manage, create an entity where they share liability risks, basically. So product liability, officers liability, general liability, that kind of thing. So the proposal here is basically just to limit. So they can't give loans to their individual members or their affiliates. There is a prospective provision saying that this new prohibition shall not apply to any loan or investment in effect prior to 01/01/2026. Actually, it's not prospective. Yeah. Never mind. Okay. When I first look at that, I forgot what year we were in. So forget everything I just I'm really not keeping up. Anyway. So, and you'll hear kind of the policy rationale from the department.

[Speaker 0]: Risk retention group were to take a loan or invest in any of their parent companies or affiliates after January 1, before this bill was passed.

[Speaker 1]: It would be retroactive. So I think it would make that it would make it null and void.

[Speaker 0]: You know? Assume that any risk retention groups that are thinking about that are gonna put those thoughts on hold?

[Speaker 1]: I I think so. That's not unusual in heavily regulated industries. I think it's incumbent upon them to kind of keep track of what's happening. It's not that unusual for laws like this to be applied retrospectively. So, yeah.

[Speaker 2]: Do we have any idea of how often this is actually taken advantage of?

[Speaker 1]: I know.

[Speaker 2]: And what are other states doing? Do they have similar laws?

[Speaker 1]: About the the lending and the Yeah. I'm not sure of that.

[Speaker 0]: Okay.

[Speaker 1]: I'm not sure how many. I did a little bit of my own research. You should hear it from the department. But that there is some concern about, you know, not wanting to put into jeopardy the the money that's held in reserve to be available for any claims. It's not But Bill's better speak to what's happening in the market and why this might be a good idea. So, Section two also applies to risk retention groups, and you'll see the amendment is to Section 6,007, which applies to reports and statements, annual reports and quarterly statements and so on that are required to be filed by all captive insurance companies generally. There are some existing provisions in this law that are specific to risk retention groups. And you see there the stricken language beginning on line seven. Except as otherwise provided, each risk retention group shall file its report in the form required by and that's a cross reference to reporting requirements that apply to insurance companies generally. Not cap this is specific to captive insurance, but it's now for risk retention groups referring back to the general reporting requirements. And each risk retention group shall comply with the requirements, again, of the general insurance reporting requirements. So the proposal here is to strike that provision. And then similarly, strike a provision subsection D that's specific to risk retention groups. And then add basically new subsections that instead of having risk retention groups complying with the general insurance requirements or even the specific captive insurance requirements in this particular statute, but having a specific subsection or two related to risk retention groups. And so basically in subsection C, you'll see that beginning on or before March 1 annually, in a form and manner prescribed by the Commissioner, Each group shall file with the NAIC a copy of its annual statement convention blank, the signed jurat page I'm not even sure if I'm pronouncing that correctly and the actuarial certification any other filings prescribed by the commission. And then also any amendments or addendums should be filed with both the Department of the Commissioner and with NAIC. And then subsection F just specifies primarily the dates by which those the quarterly statements. So there's an annual report and their quarterly statements, and this primarily specifies when those quarterly statements are due. And then another provision again about any amendments to the quarterly statements that are subsequently made have to be filed with the commissioner and NAIC. Another a new provision that allows the commissioner to adopt additional rules specific to these risk retention group filings as necessary. Also specifying that they're to be filed electronically with NAIC. And then one final provision, and I believe it's already existed in current law, but again specifying I think that was the second subsection that I looked at but specifying that the reports and statements are not confidential. You know, the beginning, yeah. So that subdivision 6,002 c three is a confidentiality requirement. It's in another section of law that applies to reports and statements. There's an exemption from that, and I think that has to do with they're not permitted to keep these statements and reports confidential under federal law. But again, we'll hear more about that. And so finally, Section three, different type of captive. This pertains to sponsored captive insurance companies and their protected cells. As you remember, sponsor captive is often an insurance company that does all of the management, the administration, sometimes putting up the initial capital, or their participants who all have their own cell where they can manage their own risks without having to do all the administrative work. So a company will contract with a sponsored captive insurance company and pay fees, pay premiums to that sponsored captive, but not have to do all the administrative work. It's an entity that's structured to kind of help usually smaller or mid sized businesses so they can remove some of the costs of having to do it all themselves. But importantly, each of those protected cells, all of their money and all their risks are completely separate. They have segregated accounts. So that's the structure. And so what this is is a new law that basically requires within thirty days after commencing business, each protected cell shall file with the Commissioner a statement under oath certifying that the protected cell possessed the requisite funding prior to commencing business, including any required collateral in accordance with the protected cell's approved plan of operation. So that filing requirement and then subsection B specifies that the statement shall be signed by and that there are three provisions, either the president and secretary of the protected cell or two individuals authorized by the governing board. And I think you'll remember last year, I think, for companies that are formed as limited liability companies don't have president and secretary. So you went through a lot of those insurance and said, except in the event that you don't have a president and secretary, two individuals authorized by the governing board. So again, just an additional statement that needs to be filed and signed by the appropriate officers. That is it. This bill would be effective on July 1.

[Speaker 3]: So, on the very second to last page at the bottom, we're talking about statement under oath certifying. We just did the oaths and affirmations through the House, and we touched on the captive piece and added oath or affirmation. And it hasn't passed the Senate yet, but I don't know where it is, but it just passed out of

[Speaker 1]: the House. And so just wanted Okay, add thank you. Any other questions for

[Speaker 3]: me? Brandon,

[Speaker 0]: how would this affect detected cells that are already in existence? Or is this just for new ones? If those within early data, I have to connect the different

[Speaker 1]: Yeah. That's a good point. And maybe some I think it would just be for new ones after the effective date of this act. At this point, they're already operating, so we haven't done so.

[Speaker 0]: Just saying that they got to collab with. Anything else from?

[Speaker 4]: Thank you. You're welcome.

[Speaker 0]: Maria's done. Everybody's out the door.

[Speaker 2]: No,

[Speaker 0]: I didn't say that, Commissioner.

[Speaker 3]: You might have been thinking.

[Speaker 2]: I can give into ledge counsel now.

[Speaker 0]: Oh, there you go.

[Speaker 1]: Oh, and

[Speaker 3]: you can take that.

[Speaker 2]: I'm Samson, commissioner of Department of Financial Regulation. As you saw, it's a fairly straightforward and and skinny housekeeping bill this year in captives. And I just wanted to visit with you and introduce Christine briefly before before she gets started and before you hear from the the other folks, VCIA. Couple reasons. I won't be here later in the week. I have a conflict, so I didn't wanna not show up for any housekeeping bills. They're all important. They can be boring and in the weeds, but they're all important. And also just to emphasize, you know, with captives and and really to invite with the chair's permission while you have acting deputy Christine Brown, I'll touch on that, and the VCIA here. Captives is, you know, my prior, life in Bishka and and DFR was, on the insurance side. And as you know, we regulate those differently, different deputy, different section. Captives is really, an amazing story in terms of how it came to be, how Vermont came to be the global leader in this kind of esoteric realm of insurance. And but it can also be for for those not inherently intrigued by finance and insurance issues. It can be kind of dry and boring. But if if anyone can can make it interesting and tangible to folks, think it's the the folks who hear from next. So if, again, with the chair's permission, I would I would ask that you guys ask questions and make sure you have a good base level understanding, obviously, not just of the bill, but take the opportunity to ask the question you've maybe been afraid to ask. Like, what exactly is the difference between an RNG and a captive and protected cell? You know? Ask those questions because I think it is important. While certainly not the biggest industry in Vermont, the captive industry is something that, unlike insurance or banking or securities, these are things that happen in every state, and they provide revenue to every state. They need regulating in every state. Captives is very different in that, you know, with a lot of hard work, reputation, and then a little bit of luck, we've become a global leader in this. And so we've attracted an industry to do business in the state that has you know, aside from the cost of regulating it, really doesn't have a cost on the state and provides a lot of revenue to the state and a lot of jobs, so direct and indirect revenue. And, again, it's just a very amazing niche industry. And, you know, we got a couple of awards this year in 2025, domicile of the year by US captive review, international domicile of the year in the European captive review, and that's something we're seeing an increased interest as European entities seeking to form a captive in Vermont. And I think Christine mentioned that's a bad deputy about 10% of our current licensing or licensed entities, active entities. We grew this year by 24 net entities. Every year, we have a lot of new licenses. I sign them all, so I get to see them. A lot of DocuSign activity. And and with it, you know, with it with each one is a really interesting story that I enjoy reading a couple paragraphs when it comes to me for licensure just about, you know, what the company is, why they're forming a captives a a captive, and also what I've asked them to start including what the economic benefit is, you know, what what are we expecting for premium volume and those premium taxes that would come to Vermont for each of these new licenses. And then every year, do lose some either they that their purpose, some of them particularly on the life side might have a life insurance side might have a defined end of life, you know, that's a block of business, and sometimes they do move to other jurisdictions. So that's the other thing I wanted to talk about is that while we have a great reputation and accolades globally as being a great destination, it's a competitive environment. Many, many states have replicated it, and and in fact, the two top competitors, believe, are offshore. So where there are some some tax advantages that we just can't compete with, like US federal tax advantages that we don't have influence on. So it's a competitive environment, and a lot of it comes about, a lot of our success as a state comes about because of integrity and quality and regulation. It is being an alternative form of insurance or or risk. You know, there there is scrutiny on it. And what we hear, and I think what you'll hear, I hope what you'll hear from from VCIA is that, you know, one thing that does among many things attracts entities to form a Vermont captive is that we have the confidence of our fellow global and other state regulators in terms of, you know, that's a domicile that's doing things the right way. We're accredited. The division that, you know, RRGs are part of the NAIC accreditation that you've heard heard us talk about. So we're we're happy that we accept entities that are looking for good regulation because they understand the reputational importance of that to their whatever their other business is. So in terms of the division, you know, Sandy Biegelstone had been there for several years as deputy, been there twenty nine years, did retire from the state effective January 1. Christine Brown is our acting deputy at this point. And as I'm sure you're familiar with, there's a bit of a process to appoint a permanent deputy. And I will say that I believe our permanent deputy will have almost identical, if not identical experience and, accolades and, character and all that good stuff as Christine Brown. But at this point, nothing's fine. But feel really good about Christine's background, the recommendations I got for her to, you know, sit in as acting deputy from Sandy before she left Sandy Biegelstone. And, you know, that remains another key part of Vermont's success in this industry is the stability, the succession planning of our regulatory structure, the lack of politicization of it. It's a very professional staff, and the tenure in the regulatory depart division is amazing. So lots of CPAs, CFEs that

[Speaker 0]: have

[Speaker 2]: been there a long, long time and are committed to what we can do for the Vermont economy and what we can do in the insurance space. So I think I'll I'll leave it at that and introduce Christine to answer any questions specifically about the bill. And, hopefully, you guys have some questions about what captives are because I can't imagine we all know.

[Speaker 0]: Kidding. Thank you. Thank you, commissioner. Congratulations to the department for the the awards. And Thank you. We thank Sandy as well for her year service to its captive insurance industry in the state of the launch. She's helped propel it to where it is now. Appreciate it.

[Speaker 2]: Yep. Yeah. And I forgot one one thing on here in addition to those accolades is that the whole department I forgot to mention this where I visited with you last. The whole department received its accreditation from the NAIC, which is a once every five year if you know, activity. And we did so in a way that, you know, again, from my prior time in the insurance division, went through two two, perhaps three of those cycles. And there was always Vermont always did very well in terms of between the standards that the NAIC has for all the 50 states plus jurisdictions. But there was always one or two things that we had to improve very formally and had to and as a commissioner or a deputy, you had to sit in front of that accreditation committee at an NAIC meeting and explain what your action plan was for one or two things. We had none none of those this year. So that was really quite an accomplishment. And as a commissioner walking in in April, knowing that and that was that was in the December meeting, you know, knowing that I had nothing to do with it and had the privilege of being able to sit down and say, thank you. You know? And, you know, that that was really a privilege and, again, a testament to not only in the captive division, but the insurance division and the experience and commitment that we have as regulators to this this industry and training and all that good stuff. And the support of the legislature and and this administration and past administrations to understand the economic benefit we bring and then and what we need on the staffing and training and and budget and things to sustain that. So it's a a great story all around and certainly part of what attracted me back into regulation and into this role. So thank you very much. Thank you.

[Speaker 3]: Good afternoon.

[Speaker 1]: Thank you very much for

[Speaker 3]: having my for the record, I'm Christine Brown, as Kai mentioned, acting deputy commissioner for since January 1. And thank you very much for giving me the opportunity to walk through the bill and explain anything further about captives that you might have questions about. It's it is a a niche industry for sure. But it I could just start from the first section and answer questions or give a little more color, I guess, to what we're trying to do and why. So if we go to that first section about the risk retention groups shall not make any loans or investments in its parent company or members and affiliates. In practice, and I think this is important for both parts of the risk retention group changes that we've had. In practice, we're already doing this. There's one company right now that has an investment in a member, but that is the only risk retention group right now that has such a transaction that that was previously approved. So this is really just codifying practice that we standard practice that we already employ in the department. And the reason why we don't allow loans to members is as, you know, as was explained that we Maria explained that we want to protect the the premium dollars and the capital that's in the captive and make sure that that money is available to pay claims for the members slash owners of the risk retention group. And, you know, with there's credit risk associated with loaning money back. And in cases where we would need liquidity, it could be difficult to get the money quickly. So it's just best practice that we, you know, we don't do it. Any and for your benefit, I'll just add that any transaction like this requires prior approval already from the department. So that's why we can say very confidently that we don't allow this to happen currently. The one case that we do have is almost like a single parent. It's a health system. It's called it is a risk retention group because it operates in various states, has different entities across state borders, but essentially, it's like a pure captive. And and so we allowed a little bit of leeway there. But generally speaking, we we don't wanna do it. We haven't done it. And so that's why we're making this change. Anybody have any questions about that? Again oh, go ahead.

[Speaker 0]: Are they allowed to risk retention group allowed to make investments outside of their parent?

[Speaker 3]: Yes. Yep. There's there are statutory restrictions around what they can invest in because we want to make sure they're investing prudently. We actually point to the commercial insurance laws for that, so it's very similar types of restrictions on what they can invest in.

[Speaker 0]: Questions? Are you? Okay.

[Speaker 3]: Great. So if we move on to the next section, which is the section that relates to the annual filing requirements. We as Kai mentioned, we just went through our accreditation, and we we didn't get any big comments. But they when you undergo an audit, you're always somebody wants to give you some feedback. Right? So one of the points that they made was that our law did not explicitly require quarterly filings, only an annual statement filing. But in practice, we get quarterly statements because we review those statements on a quarterly basis and annually. So we just this was really just a fix to make sure that we codify what we already do in practice. And you'll see very similar language in the housekeeping bill for the traditional insurance section later this week. They also had to make these changes because, as we mentioned, this points to their law. So what we wanted to do is, instead of pointing to that other section of the law, include our own language in the captive, section that just clarifies, again, what we require. We have a filing checklist currently, So people knew what we required, but it wasn't codified in the statute. And this just explicitly says what we what we need. There's nothing new here. No new requirements. It's all the same things that we've been collecting for as long as I've been with the department, which is twenty three years. So I don't think there's there's nothing new, no surprises for any of our regulated entities. Again, just making sure that we're taking the recommendation of the NAIC and making it explicit. And and I guess one point I'll I'll mention here, the reason why there's a distinction between risk retention groups and other types of captives with respect to filing requirements is that they're authorized under a federal act to ensure business across state lines. And different states rely on our regulation and our oversight to ensure that the captive is solvent and can pay the claims in a manner that is timely. So they have a little bit different filing requirements compared to a traditional pure captive insurance company that's the only owned subsidiary of another type of entity. A little strict more strict there. But, again, nothing new here, just codifying what we already do. And Maria mentioned that we just moved that piece about confidentiality from up top to the bottom. And, again, for other types of captives, we have very strict confidentiality laws around certain what we can and can't disclose. Risk retention groups are different. They file with the NAIC, and the information is public. So we needed to make sure that there was that exception for risk retention groups in this section. Can you explain what a is like? Yes, sure. Of course.

[Speaker 1]: I know that's definitely You were

[Speaker 3]: right, Gerard Page, I think is how I've been pronouncing it. And that is just an attestation by the board of directors. It's an informational cover page, basically. Gives the name of the insurance company. They all have an NAIC number. It lists the board of directors, and then it has the, officers sign that everything in the financial statement package is accurate and complete, and that requires the president and secretary to sign in under oath, and it's notarized. So that's what that page is. So then since it's gonna come up again Mhmm. We're looking for more proactive statements from these entities that they're following our laws with these oaths, with the draft, with the oaths and affirmations later. We're not changing what we're asking from them. We're still doing the same detailed review and also having them sign. That's right, the next section. Yes. But also for this, right? For this? Requiring that page as well. Yes. Yeah. But that that's always been required for risk retention groups. So that's not new. We always we're just putting it into the the statute. And actually, that was in the statute in the section that it was referring to before. It's just we laid it out here in the captive section as well. You want our laws to be easy to understand. That's right. Yes. And not have to go back and forth because we have to do that too often. So that is a good segue into the next section about the cell actives. And Maria did a great job explaining what those are, but an analogy that you probably heard, I know you have because I've been sitting in the room, is an apartment building with an owner renting out apartments, which are the cells to different people who want to utilize a captive structure to ensure their own risks. And typically, it is smaller entities that or it can also be for people that want ease in and out of the market. It's an easy way to get into a captive insurance company. We've been seeing some growth in this area, and we have been employing very similar, if not the same standards, regulatory standards around our supervision of cells, because they are like little mini captive insurance companies. The one piece that we weren't doing was getting this attestation. So in a licensed captive in Section 6,004 of the law currently, we require this attestation for all licensed captive insurance companies. We want to also require this for cells, so there's no difference in how we're regulating. Again, it's really just to make sure they're putting the money, the funding that they tell us collateral premium into the captive before they start doing business. So making sure that it's properly funded. We have an application process of in order for a company to get approved and licensed. And within that application, they talk about the business plan. They tell us how they're going to fund the sell, any requirements associated with collateral. And, again, this is just to make sure that they're actually doing what they said they were gonna do before they get off the ground. So aligning our regulation over cells with what we do in licensed captives. Anybody have any questions about that? I think, you know, the bill is although they're not substantive changes, you know, it's it's things that we pretty much are already doing with the exception of that cell piece. It I think it shows again that where where we want to always look at the law and make sure it's clear, make sure that our requirements are laid out for for our you know, the the captive owners. And then also, they're not we're not loosening anything. So to Kai's point, companies come to Vermont because of the quality of our regulation and the fact that we're doing things the right way. I know you asked the question about other jurisdictions and with risk retention groups and the loan backs. I honestly am not sure what other jurisdictions are doing, but Vermont is a leader in that space, and a lot of jurisdictions call us, you know, on a pretty regular basis to find out what we're doing or how we're feeling. And we just we typically set best practices. We we chair a committee at the NAIC for risk retention groups that set policy for risk retention groups. So we always try to make sure that we're being good stewards, not just in Vermont, but for these types of companies. It's a it can it's a national issue that we wanna make sure that other states are regulating captives in a responsible way.

[Speaker 0]: So does this The way that we're looking at this, something that's recommended by the NAIC, or is it something for

[Speaker 3]: Though though we did not get a recommendation with respect to the loan back piece from the NAIC. That's just in practice what we what we've learned. You know, other types of captives are are allowed to do loan backs or invest in their parents upon prior approval. So we have to make sure we properly vet any of those requests. But, you know, with the risk retention group, some of them are very small members. Some you know, if you can imagine a trucking RRG, which is transportation. There's unsophisticated members. We we don't want to use their money to loan to another member who may not even know that that's what's happening. So it's just a different type of of company. You. Thank you. Thank you. And, yeah, if you ever have any questions about how we regulate or what we do, happy to answer. Thank you for your time. Thank you. Ian? Welcome.

[Speaker 4]: Thank you. It's good to be here. Good to be back. Good afternoon. My name is Ian Davis. I'm president of the Vermont Captive Insurance Association. And before I kind of jump into my remarks, I thought it might be good to just reintroduce myself to the committee. I've served in the captive insurance industry for the last ten years of my career, Started at the Department of Economic Development, where I helped to market and promote the industry. Most recently, prior to joining VCIA, I was with M and T Bank, leading their captive practice. And as of August year, I started as president of ECIA. So I've really enjoyed my time in the industry. I'm actually a product of the captive industry. My mom had a career in captive insurance for a number of years. So I hope that helps to put kind of a face when we refer to the kind of local community of service providers that exist here. It helps to illustrate that can have a career, live here, work here in Vermont, working in this incredible industry. So I wanted to share that with all of you. I thought it might be helpful to talk a little bit about how the captive bill is developed each year because VCIA, along with the department, plays a very active role in helping to put together the amendments that we're looking to do. So I think more than anything, it's really a model of collaboration and transparency. It begins early in the fall each year where we convene industry, VCI representing the industry and on behalf of our members, we go out to our membership to solicit ideas and input about ways in which Vermont can continue to further advance and modernize its laws and regulations. You all, of course, play a critical role in that as well. But as I said, it's a very collaborative process. And really, the results are always the same. It's always a consensus bill working with industry, working with regulators and policymakers to put forward really prudent, thoughtful modernizations to our statutes. And from an industry standpoint, it's not just a tradition for Vermont, it's really as much as anything an expectation. As Kai or Commissioner Sampson alluded to, other states, other jurisdictions, both nationally and internationally, really do look to Vermont and to our laws and how we regulate to seek to model their own laws and regulations. And so we are very much looked at as a leader in the space. And again, Commissioner Sampson and Christine, Interim Deputy Brown, I should say, just alluded to the competitive environment that exists today in the industry. And I can't underscore that enough, just how many, whether it's states or countries, are looking to attract and recruit both existing and new captive business to their domiciles. So captive owners have more choices than ever. You'll be hearing next week from one of our members who is a risk retention group. So if you have questions specific to RRGs, you can ask Julie Bordeaux next week, but they exist to provide liability insurance for long term care providers. So I think a really interesting space. And in any event, Julie is an instance of an owner company that moved to Vermont from another jurisdiction as well. So the reason that owners want to be here is in large part because of the laws and regulations that exist. And so the professionalism, the familiarity that our regulators at the department have with their licensed entities is really, I think, our biggest differentiator. So none of this means a cozy relationship with regulated entities. I hear firsthand from our members that there are instances where difficult conversations are had, as you might expect. And I think more than anything, it's the clear communication and level of professionalism that has been a hallmark of the department's success. That is really, again, one of the main reasons why our membership continue to choose Vermont. And so, I guess to kind of summarize, I would just note again that what originally brought companies to Vermont, and that being kind of the consistency of our regulatory framework and really the professionalism that the department is able to bring to that relationship is constantly being challenged. And so the more that we're able to convey to the global captive industry that Vermont is not resting on its laurels, that we're constantly looking to further elevate and modernize our laws and regulations. I think it really serves not just VCIA, but Vermont really well. And we hope to be around for another forty years. We last year celebrated our fortieth anniversary. And Kai talked about the incredible success story that is Vermont's captive industry. And so we are here today wanting to continue that and to be a willing partner in ensuring the success of this industry. I'm also happy to field any questions that you all may have. We'll be back again next week, so you can think about them over the week as well.

[Speaker 3]: So you mentioned that we're trying to stay on top of this and continue modernizing our regulations, and this is a pretty build. So should that start?

[Speaker 4]: I should tell you that we're a mature jurisdiction and we have to work very hard soliciting the input and ideas from our membership start that process earlier and more, I think, with more regularity than we do today. And that's certainly a priority of mine as president of BCIA, to make sure that we really have the ear of our members and make sure that they know that we are encouraging them to provide input in many ways as they do today directly with the department. But we wanna make sure that we carefully vet those ideas so that anything that's brought forward is consistent with Vermont's high regulatory standards. So we always get a few ideas that I don't think match those standards. And we, I think are kind of the first line, if you will, to make sure in our advocacy committee, which also plays an important role, really vetting those. But I'm as eager as anyone. And I know, I think, DFR is eager too, to think about ways in which we can help to further elevate the industry. And yeah, I guess to summarize, it's really the fact that we've been around for as long as we have.

[Speaker 0]: Questions? Is there anyone else that we need to hear from? I

[Speaker 1]: don't know if this is

[Speaker 3]: a question for you, but I actually was just kind of curious what's the uptick in the European captives? Is that an easy question or is that a new question? I didn't hear the question. I'm sorry.

[Speaker 1]: Oh, the uptick in European captives. Yeah. Is it? What's driving?

[Speaker 3]: Oh, the European jurisdictions actually are just starting to come up with their own laws and regulations around captive insurance companies, but I think really what we've nailed down is proportionality. So when we look at a company, we're regulating based on the risk profile of that company, and knowing that it's a wholly owned subsidiary of a larger organization, we look holistically at the organization in Europe. They look at captive insurance companies. A lot of jurisdictions still look at captive insurance companies like a commercial insurance company, and those standards, don't really fit in a lot of So it's a lot more onerous. There's more reporting requirements. Just things that a pure captive insurance company, really, there's no consumer risk that we're worried about. But those laws in Europe, a lot of the times, still look to a commercial type law where there's consumers on the back end that they're trying to protect. So, yeah, I think they're all trying to emulate what we're doing as well. We're talking to a lot of jurisdictions in Europe right now to try to help them with the proportionality issue and making sense of their laws to make sure that they can, even though there's competition out there, that we do try to play nice with other regulators and make sure that it's best for the industry, I think, to have the same standards or very similar high standards. Yeah, that's I think. Do you have anything to add? That would be

[Speaker 4]: No, I mean, I think there's a lot of large global multinationals in Europe, many of whom have US business or operations. And so Vermont captives, could stay or in some cases establish to ensure those risks.

[Speaker 0]: The questions? Is there any reason reason why we shouldn't vote this out?

[Speaker 3]: It's a two members that okay.

[Speaker 0]: Oh, we can get Monique is in the building. I'm sure Jonathan here or Keith's phone?

[Speaker 3]: I'm just not available in second.

[Speaker 0]: So why don't we take a ten minute break, and we'll come back and