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The insurance industry has claimed that a specific provision of the SRA (“Net Book Quota Share”) is a tax on technical income and supplants private reinsurance. The negotiation process included the development of a draft contract by the USDA, the separate meeting with insurance companies, and the response to comments, concerns, and proposals from insurance companies and the public. On June 10, 2010, RMA published what is known as the final draft of the new SRA for the 2011 and subsequent reinsurance years.2 On July 13, 2010, the USDA announced that the agreement had been signed by all 16 licensed insurance companies and had therefore entered into effect for the 2011 reinsurance exercise. Notes: During the 2016 reinsurance year, the three largest PIAs were, after a direct written premium, ACE American Insurance Company (Rain and Hail, LLC), Rural Community Insurance Services and NAU Country Insurance Company. Together, they wrote about 47% of all federal crop insurance premiums before reinsurance…