February 2019

The New Jersey Division of Insurance (“Division”) recently issued a letter to third party administrators (“TPAs”) making them aware of additional or revised filing requirements for TPAs doing business in New Jersey. The additional or revised filing requirements in New Jersey are as follows:

  • Unaudited Financial Statements previously due by March 1st are no longer required.
  • While Annual Questionnaires, Annual Reports and audited Financial Statements continue to be due on May 31st, the Division’s letter states, “Any company looking to file an extension must formally submit a written request to Mr. Tim Stroud by May 15, 2019. Any request for an extension submitted after May 15, 2019 will be denied. The request for an extension should state how long of an extension is requested and why an extension is requested.”
  • The Annual Questionnaire must now include an organizational chart which identifies the corporate structure (parent company, affiliates or subsidiaries of the TPA).
  • The Division’s letter states that TPAs must submit updated contact information to Mr. Stroud no later than May 31, 2019, which must be attached to the TPAs annual filing.
  • The Division’s letter also states, “This letter is reasonable notice that any TPA that files late will be fined on a per day basis.” Pursuant to N.J.A.C. 11:23-4.3, the Division may impose enforcement remedies against a TPA for the late filing of annual reports. Such enforcement remedies include the assessment of a penalty in an amount not less than $250 or more than $5,000 for each day that a TPA is in violation of N.J.A.C. 11:23-4.3. Additionally, a penalty imposed pursuant to N.J.A.C. 11:23-4.3 may be in lieu of, or in addition to, suspension or revocation of a license.


 View the full alert here.