Introduction to Surplus Lines

In the world of casualty insurance, the vast majority of policies are written by admitted carriers. These are insurance companies that have received a certificate of authority from a specific state's department of insurance to transact business under that state's regulations. However, not every risk fits neatly into the underwriting guidelines of standard admitted companies. This is where the surplus lines market, also known as the non-admitted market, plays a vital role.

Surplus lines insurance serves as a "safety valve" for the insurance industry. It provides a mechanism for businesses and individuals to obtain coverage for risks that are too high, too unusual, or too large for the standard market to handle. While these carriers are "non-admitted," they are still regulated by their home state or country and must be authorized to write surplus lines in the state where the risk is located. Understanding this distinction is a critical component of the complete Casualty exam guide.

Admitted vs. Non-Admitted Carriers

FeatureAdmitted MarketSurplus Lines (Non-Admitted)
Rate and Form RegulationStrictly regulated by State DOIFreedom of Rate and Form
Guaranty Fund ProtectionProtected if insurer goes insolventNo protection from State Guaranty Fund
StandardizationHighly standardized (ISO/AAIS)Highly customized to the specific risk
Agency AccessStandard licensed agentsSpecially licensed Surplus Lines Brokers

The Diligent Effort Requirement

Insurance producers cannot simply place business in the surplus lines market because they prefer the commissions or the carrier's branding. Most states require a diligent effort search of the admitted market before a risk can be exported to a non-admitted carrier. This typically involves the producer attempting to place the coverage with several (often three) admitted insurers and receiving rejections from each.

There are exceptions to this rule, such as "export lists" maintained by state insurance departments. These lists contain types of risks that the state has already determined have no viable admitted market, allowing brokers to bypass the individual search requirement. Common examples might include demolition contractors, specialized medical malpractice, or high-limit excess liability for unique events. You can test your knowledge of these regulatory requirements with practice Casualty questions.

Why Risks Enter the Surplus Lines Market

⚠️
High Loss History
Distressed Risks
🦄
One-of-a-Kind
Unique Risks
📈
Extremely High Limits
Capacity Risks
🚀
New Tech/Industries
Emerging Risks

Regulation and Surplus Lines Taxes

While surplus lines carriers enjoy Freedom of Rate and Form—meaning they can change their premiums and policy wording without prior state approval—they are not entirely unregulated. They must maintain significant capital and surplus to ensure they can pay claims. Furthermore, the surplus lines broker bears much of the regulatory burden, ensuring the carrier is on the state's "white list" of eligible non-admitted insurers.

A unique feature of this market is the Surplus Lines Tax. In the admitted market, premium taxes are usually paid by the insurer. In the surplus lines market, the tax is typically charged to the insured and collected by the surplus lines broker, who then remits it to the state. This tax helps compensate the state for the lack of direct oversight and the absence of participation in the state guaranty fund.

Common Surplus Lines Exposure Categories

Chart preview loads in the browser.

A breakdown of typical casualty risks found in the non-admitted market.

💡

Exam Tip: The Guaranty Fund Distinction

If you see a question on the Casualty exam regarding the State Guaranty Fund, remember: Surplus lines policies are not covered. If a non-admitted carrier becomes insolvent, the policyholders cannot turn to the state's fund to pay their claims. This is why checking the financial strength (A.M. Best rating) of a surplus lines carrier is paramount for brokers.

Frequently Asked Questions

No. Non-admitted simply means the company is not licensed as an admitted carrier in that specific state. They are legally authorized to write business through licensed surplus lines brokers provided they meet the state's eligibility requirements.
While the tax is usually passed on to the policyholder (the insured), the surplus lines broker is responsible for collecting it and remitting it to the state insurance department.
It is the ability of surplus lines carriers to use policy forms and set premium rates without having to file them for approval with the State Department of Insurance. This allows them to react quickly to unique or rapidly changing risks.
A risk is distressed if it has a high frequency or severity of previous losses, or if the nature of the business (such as a nightclub or hazardous waste hauler) makes it unappealing to standard admitted underwriters.