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< Return to Articles Synopsis of Risk Purchasing Group A search for "Risk Retention Act" on the internet results in dozens of references to publications, statutes, regulations, and opinions, not to mention advertisements by a variety of service providers, lawyers, and others. Some, like the National Risk Retention Association ( www.nrra-usa.org ) and the Risk Retention Reporter (www.rrr.com) provide good information and practical advice about the Act and how it works. Other sites are not as informative. People unfamiliar with the federal statute can be forgiven if they find the array of information confusing. This outline is intended to assist in the process of understanding what the federal statute permits and does not permit. But first, the answer to the $64,000 question: may an admitted insurer issue a single master policy to a Risk Purchasing Group and extend coverage to its members in all 50 states without obtaining rate and form approval in all 50 states? The answer, sadly, is no. There are other advantages to a Risk Purchasing Group, however, from the insured's perspective, as well as from the broker's and the insurer's perspective. These advantages are both economic and regulatory. What's is all the Fuss About? In Two Words, Group Insurance . Unlike life and accident & health insurance, property/casualty insurance historically has been prohibited from being written on a group basis under the laws of most states. While individuals who work for the same employer or are members of the same labor union have been permitted to obtain life and health insurance under a group policy since the beginning of time, property/casualty insurance has historically been limited to individually issued and underwritten policies under most states' laws. Why? The reason for this has been the perception that actuarially there is little difference in experience between individually underwritten policies and policies underwritten on a group basis, and the regulatory concern that group contracts unfairly discriminate against similarly situated non-group members. Further, there has been strong opposition from the small producer lobby to group insurance programs that result in a lower volume of policies overall, and therefore, fewer opportunities to earn commission. Several states' insurance laws contain prohibitions against so-called "fictitious groups", which in concept, are associations or other entities formed for the principal purpose of permitting their members to buy insurance coverage. These statutes may define the term "fictitious group" sufficiently broadly, however, that legitimate groups formed for non-insurance purposes (for example, the American Bar Association) would not be able to avail their members of the benefits of group insurance. It is difficult to pin down the basis for every state's prohibition against group property/casualty insurance. Anti-discrimination rules, fictitious grouping statutes, the absence of specific statutes authorizing the group approach, are among the reasons why group property/casualty insurance might fall afoul of state law. At the end of the day, state insurance regulators have generally not permitted group property/casualty insurance (although group property/casualty insurance is not unlawful in all states or in all instances), and there are as many bases for declaring it illegal as there are states and individual regulators in those states. The federal Risk Retention Act, however, in the case of commercial liability insurance, trumps all state laws that would otherwise prohibit underwriting on a group basis. In so doing, it authorizes the formation of risk purchasing groups. Origins of the Liability Risk Retention Act . The original risk retention legislation was enacted by Congress in 1981, as the Products Liability Risk Retention Act, in response to a very hard market for products liability insurance. The 1981 statute permitted for the first time the formation of risk purchasing groups and risk retention groups, to buy and sell, respectively, products liability insurance for their members on a group basis. Insurance carriers were also permitted to sell products liability insurance to the members of purchasing groups on a group basis without being subject to regulatory sanction. In the mid-1980s, in response to crises in the availability and affordability of liability insurance across the board, which affected public entities, medical professionals and small businesses in particular, Congress enacted the federal Liability Risk Retention Amendments of 1986. The 1986 legislation extended the 198 1 legislation to cover all forms of commercial liability insurance, not just products liability. Property insurance and worker s' compensation insurance are not included within the scope of the legislation. For the most part, property insurance and worker s' compensation insurance may only be individually underwritten and issued. The federal law did not establish a federal regulatory system. Enforcement of its provisions, and by default, regulation of risk purchasing groups and risk retention groups, was left to the states. How does the Risk Retention Act Work? The statute authorizes the formation of risk purchasing groups to obtain insurance for their members on a group basis, and risk retention groups to act as collective self-insurance vehicles. The objective of the statute is to permit groups of insureds with similar exposures to loss to achieve the economies of scale that result from buying insurance in bulk. The law relies on a broad preemption of state law prohibitions to achieve its goals. In that regard, it is noteworthy that risk purchasing groups are subject to all state insurance laws and regulations that would otherwise be applicable except those that Congress listed in the statute as being inapplicable . (In contrast, with a small number of exceptions, risk retention groups are not subject to any laws of any state other than their state of domicile which means that a risk retention group can do business anywhere once it gets licensed in one state.) The following is an overview and explanation of the key provisions of the federal law as it affects risk purchasing groups. Risk retention groups, insurers authorized by Congress to operate in a multi-state regulation free environment, are not covered in this outline. A copy of the statute in its entirety is attached. It should be noted that the NAIC has adopted a model risk retention law, a version of which has been enacted by all of the states either by statute or regulation. There are variations within the state enactments and reference to the specific statute is also advisable. The New York statute may be found in Article 59 of the Insurance Law, and in Insurance Department Regulations 134 and 135. What is a Risk Purchasing Group? The statute defines a risk purchasing group as "any group" which:
Some observations about the definition are as follows. First, the statute does not define the legal form that the group must take. It can be a corporation, a partnership, or merely a bunch of folks who share a similar exposure to loss who get together to buy their insurance. In that regard, because limited liability is a goal of corporate membership (suppose one of the guys above decides to blame all the other guys as individuals because his claim was denied) a corporate entity is advisable even if the actual members of the purchasing group are the individual insureds. This writer favors the formation of risk purchasing groups as not-for-profit corporations for this reason. [2] Second, purchasing commercial liability insurance on a group basis needs to be one of the purposes of the group. The statute does not state that a purchasing group may not have any other purposes, so long as the liability insurance it purchases is limited to members of the group and only covers claims arising from their similar or related exposure. In other words, one of the purposes of the group may be to purchase property insurance without being in violation of the statute - - subject to compliance with applicable state law, meaning that individually issued and underwritten (i.e. non-group) property policies may be purchased by a purchasing group [3] , but not group property policies because they might violate fictitious group prohibitions and anti-discrimination laws. Third, the definition of homogeneity is quite broad, and indeed somewhat vague. The legislative history to the 1986 legislation makes it clear that a manufacturer of a product may be included with a wholesaler and a retailer of the same product under the homogeneity test. What is less clear is the degree to which the membership must he homogenous. For example, it is not clear that a purchasing group can consist of any doctor, regardless of medical specialty, or must be limited to practitioners of a particular specialty, e.g. orthopedists only. Again the legislative history makes it clear that homogeneity requirements are to be read liberally. Since it would apparently be lawful to combine attorneys in a purchasing group without regard to specialty area of practice, there appears to be no reason why different medical specialties cannot be combined in the same purchasing group. Fourth, the statute does not define what group insurance is. This leads to questions as to whether a risk purchasing group must obtain a group master policy with individual certificates to each member, or whether the members may be issued individual policies, which are typically preferred by insureds. The better view is that the form of the coverage; i.e. group versus individual policy, is irrelevant for purposes of complying with the statute. [4] The issue is whether the underwriter viewed the risk as a collective one, applied the group's own loss experience in coming up with a rate, and built in economies of scale in the rate determination. Fifth, a purchasing group will meet the homogeneity requirement by having common premises, not just a common trade or business or product. It would be permissible for all of the commercial tenants in an office building to form a purchasing group for their business liability coverage needs, even if the tenants were all engaged in different occupations. The Role of State Regulators . A risk purchasing group is exempt from all state laws, rules, regulations or orders that would:
Risk purchasing groups and their insurers are subject to all other state laws and regulations. The anti-discrimination provision is obviously a useful provision. For example, New York Regulation 135 prohibits purchasing group policies being issued in the Free Trade Zone (N.Y. Ins. Law. Art. 63). It is this writer's opinion that excluding purchasing groups and their members from obtaining coverage in the Free Trade Zone is discriminatory and falls afoul of the federal statute. It is noteworthy that the preemption provisions also apply to the provision of insurance related or management services to a purchasing group or a member of the group. This particular provision has been instrumental in the formation of purchasing group management companies and the provision of fee-based services to purchasing groups. A state may impose a licensing requirement on individuals or entities that provide broker or producer services, but it may not deny a license solely on the basis of residency. Translation: It is possible for brokers to obtain non-resident surplus lines broker licenses for purchasing group business. This used to be a major advantage to producers because most if not all states imposed residency requirements for such licenses. The recently adopted NAIC model producer licensing law has diluted the advantage of this because now most states will issue non-resident E&S licenses for general business. Prior to doing business in any state, a purchasing group is required to file a notice of its intent to do so with the local insurance commissioner. The notice must contain four pieces of information: the state in which the group is domiciled; the type of liability insurance to be purchased; the insurance carriers and their state(s) of domicile; and the purchasing group's principal place of business. The group must also register with and designate the local insurance commissioner as its agent for service of process in any state in which it actually does business. Some states, for example Florida, have gone way overboard in their interpretation of the requirement to "register", and have made the registration process a complex, time consuming and expensive process. Fortunately, most states have adopted a version of the NAIC model purchasing group registration form. Although the NAIC arguably goes beyond the permitted scope of state authority (because it seeks more information than the federal statute otherwise appears to require), it has had the effect of streamlining the registration process. In addition, many states impose a purchasing group filing fee, thereby adding to a purchasing group's costs of doing business. FAQ Q. If a carrier issues a policy on a master basis to a risk purchasing group, may it be subject to a shared aggregate? A. Definitely not in New York. Unclear in other states, generally the answer is no. Q. Are purchasing group policies subject to multi-state rate and filing requirements? A. For the most part, the answer is yes. A few states, e.g. Virginia and Texas exempt non-domiciliary purchasing groups from these requirements. Q. An insurer wishes to write a risk purchasing group with members in all 50 states on admitted paper. If it has state-specific endorsements for terrorism, cancellation, extended reporting periods, may it issue a group policy or must it issue separate policies for each state with state specific requirements'? If it wishes to cancel or non-renew, to whom must notice be sent? A. There is no legal requirement that group policies be issued versus individual policies, only that the members achieve economies of scale. Whether written on a group or individual policy basis, rate and form filing requirements must be followed, although no state can decline to approve a benefit based upon the group's unique loss and expense experience. As a practical matter, state-specific endorsements would be required irrespective of whether groups or individual policies are issued. Cancellation/non-renewal requirements vary state to state, but typically, notices need to be sent to the individual member. A notice to the group applicable to all members likely would not satisfy the requirements of the statute. Q. If a policy is issued to a risk purchasing group with members in more than one state by a non-admitted white listed surplus lines insurer: - Does the state where the purchasing group is headquartered control where the surplus lines tax is paid, and where the affidavits of declination by admitted carriers must be filed (and where the surplus lines broker must have a surplus lines license,) or do the surplus lines laws and regulations of each state where the insured purchasing group members are located/headquartered control? Does one set of declinations from admitted companies suffice for the entire purchasing group or must the process be done for each insured purchasing group member? A. Each state's surplus lines laws must be followed and they vary from state to state. In several states the surplus lines broker must obtain a single declination for the entire group at inception of the coverage, but is relieved of the obligation to file individual affidavits as members join the group (not true in New York). The surplus lines taxes are the same as non-group policies. - Does the answer depend on whether it is a group master policy or individual policies issued to the purchasing group members? A. No. It makes no difference. - Assuming the risk is otherwise appropriate for the non-admitted market, are there any restrictions on issuing group P&C policies on a surplus lines basis'? A. The same restrictions apply to non-admitted policies as admitted policies in the sense that an excess lines broker may not place coverage in the non-admitted market that would be unlawful if placed with an admitted carrier. While non-admitted paper is not regulated per se, if an aspect of insurance is not permissible to a licensed carrier it is not permissible to an unlicensed carrier. Q. So, why form a risk purchasing group?
Addendum- Federal Liability Risk Retention Act Sec. 3901. Definitions (1) ''insurance'' means primary insurance, excess insurance, reinsurance, surplus lines insurance, and any other arrangement for shifting and distributing risk which is determined to be insurance under applicable State or Federal law; (A) means legal liability for damages (including costs of defense, legal costs and fees, and other claims expenses) because of injuries to other persons, damage to their property, or other damage or loss to such other persons resulting from or arising out of - (i) any business (whether profit or nonprofit), trade, product, services (including professional services), premises, or operations, or (ii) any activity of any State or local government, or any agency or political subdivision thereof; and (B) does not include personal risk liability and an (3) ''personal risk liability'' means liability for damages because of injury to any person, damage to property, or other loss or damage resulting from any personal, familial, or household responsibilities or activities, rather than from (4) ''risk retention group'' means any corporation or other limited liability association - (A) whose primary activity consists of assuming, and spreading all, or any portion, of the liability exposure of its group members; (B) which is organized for the primary purpose of conducting (i) is chartered or licensed as a liability insurance (ii) before January 1, 1985, was chartered or licensed and (D) which does not exclude any person from membership in the (i) has as its owners only persons who comprise the membership of the risk retention group and who are provided insurance by such group; or (ii) has as its sole owner an organization which has as - (I) its members only persons who comprise the membership of the risk retention group; and (II) its owners only persons who comprise the membership of the risk retention group and who are provided insurance by such group; (F) whose members are engaged in businesses or activities similar or related with respect to the liability to which such members are exposed by virtue of any related, similar, or common business, trade, product, services, premises, or operations; (G) whose activities do not include the provision of insurance other than - (i) liability insurance for assuming and spreading all or any portion of the similar or related liability exposure of its group members; and (H) the name of which includes the phrase ''Risk Retention (5) ''purchasing group'' means any group which - (A) has as one of its purposes the purchase of liability insurance on a group basis; (B) purchases such insurance only for its group members and only to cover their similar or related liability exposure, as described in subparagraph (C); (C) is composed of members whose businesses or activities are similar or related with respect to the liability to which members are exposed by virtue of any related, similar, or common business, trade, product, services, premises, or operations; and (D) is domiciled in any State; (6) ''State'' means any State of the United States or the District of Columbia; and (7) ''hazardous financial condition'' means that, based on its present or reasonably anticipated financial condition, a risk retention group is unlikely to be able - (A) to meet obligations to policyholders with respect to known claims and reasonably anticipated claims; or (B) to pay other obligations in the normal course of business. (b) Nothing in this chapter shall be construed to affect either the tort law or the law governing the interpretation of insurance contracts of any State, and the definitions of liability, personal risk liability, and insurance under any State law shall not be applied for the purposes of this chapter, including recognition or qualification of risk retention groups or purchasing groups. Sec. 3902. Risk retention groups (a) Exemptions from State laws, rules, regulations, or orders. Except as provided in this section, a risk retention group is exempt from any State law, rule, regulation, or order to the extent that such law, rule, regulation, or order would - (1) make unlawful, or regulate, directly or indirectly, the operation of a risk retention group except that the jurisdiction in which it is chartered may regulate the formation and operation of such a group and any State may require such a group to - (A) comply with the unfair claim settlement practices law of the State; (B) pay, on a nondiscriminatory basis, applicable premium and other taxes which are levied on admitted insurers and surplus lines insurers, brokers, or policyholders under the laws of the State; (C) participate, on a nondiscriminatory basis, in any mechanism established or authorized under the law of the State for the equitable apportionment among insurers of liability insurance losses and expenses incurred on policies written (D) register with and designate the State insurance commissioner as its agent solely for the purpose of receiving service of legal documents or process; (E) submit to an examination by the State insurance commissioners in any State in which the group is doing business to determine the group's financial condition, if - (i) the commissioner of the jurisdiction in which the group is chartered has not begun or has refused to initiate an examination of the group; and (ii) any such examination shall be coordinated to avoid (F) comply with a lawful order issued - (i) in a delinquency proceeding commenced by the State insurance commissioner if there has been a finding of financial impairment under subparagraph (E); or (ii) in a voluntary dissolution proceeding; (G) comply with any State law regarding deceptive, false, or fraudulent acts or practices, except that if the State seeks an injunction regarding the conduct described in this subparagraph, such injunction must be obtained from a court of competent jurisdiction; (H) comply with an injunction issued by a court of competent jurisdiction, upon a petition by the State insurance commissioner alleging that the group is in hazardous financial condition or is financially impaired; and ''NOTICE (2) require or permit a risk retention group to participate in any insurance insolvency guaranty association to which an insurer licensed in the State is required to belong; (3) require any insurance policy issued to a risk retention group or any member of the group to be countersigned by an insurance agent or broker residing in that State; or (4) otherwise, discriminate against a risk retention group or any of its members, except that nothing in this section shall be construed to affect the applicability of State laws generally applicable to persons or corporations. (b) Scope of exemptions. The exemptions specified in subsection (a) of this section apply to laws governing the insurance business pertaining to - (1) liability insurance coverage provided by a risk retention group for - (B) any person who is a member of such group; (2) the sale of liability insurance coverage for a risk retention group; and (A) insurance related services; (B) management, operations, and investment activities; or (C) loss control and claims administration (including loss control and claims administration services for uninsured risks retained by any member of such group);
(c) Licensing of agents or brokers for risk retention groups. A State may require that a person acting, or offering to act, as an agent or broker for a risk retention group obtain a license from that State, except that a State may not impose any qualification or requirement which discriminates against a nonresident agent or broker. (d) Documents for submission to State insurance commissioners. Each risk retention group shall submit - (1) to the insurance commissioner of the State in which it is chartered - (A) before it may offer insurance in any State, a plan of operation or a feasibility study which includes the coverages, deductibles, coverage limits, rates, and rating classification systems for each line of insurance the group intends to offer; and (B) revisions of such plan or study if the group intends to (2) to the insurance commissioner of each State in which it intends to do business, before it may offer insurance in such State - (B) a copy of any revisions to such plan or study, as provided in paragraph (1)(B) (which shall include any change in the designation of the State in which it is chartered); and (3) to the insurance commissioner of each State in which it is doing business, a copy of the group's annual financial statement submitted to the State in which the group is chartered as an insurance company, which statement shall be certified by an independent public accountant and contain a statement of opinion on loss and loss adjustment expense reserves made by - (A) a member of the American Academy of Actuaries, or (B) a qualified loss reserve specialist. (e) Power of courts to enjoin conduct. Nothing in this section shall be construed to affect the authority of any Federal or State court to enjoin - (1) the solicitation or sale of insurance by a risk retention group to any person who is not eligible for membership in such group; or (2) the solicitation or sale of insurance by, or operation of, a risk retention group that is in hazardous financial condition or is financially impaired. (f) State powers to enforce State laws. (1) Subject to the provisions of subsection (a)(1)(G) of this section (relating to injunctions) and paragraph (2), nothing in this chapter shall be construed to affect the authority of any State to make use of any of its powers to enforce the laws of such State with respect to which a risk retention group is not exempt under this chapter. (2) If a State seeks an injunction regarding the conduct described in paragraphs (1) and (2) of subsection (e) of this section, such injunction must be obtained from a Federal or State court of competent jurisdiction. Nothing in this chapter shall affect the authority of any State to bring an action in any Federal or State court. (h) State authority to regulate or prohibit ownership interests in Nothing in this chapter shall be construed to affect the authority of any State to regulate or prohibit the ownership interest in a risk retention group by an insurance company in that State, other than in the case of ownership interest in a risk retention group whose members are insurance companies. Sec. 3903. Purchasing groups (a) Exemptions from State laws, rules, regulations, or orders. Except as provided in this section and section 3905 of this title, a purchasing group is exempt from any State law, rule, regulation, or order to the extent that such law, rule, regulation, or order would - (1) prohibit the establishment of a purchasing group; (2) make it unlawful for an insurer to provide or offer to provide insurance on a basis providing, to a purchasing group or its members, advantages, based on their loss and expense experience, not afforded to other persons with respect to rates, (3) prohibit a purchasing group or its members from purchasing insurance on the group basis described in paragraph (2) of this subsection; (4) prohibit a purchasing group from obtaining insurance on a group basis because the group has not been in existence for a minimum period of time or because any member has not belonged to the group for a minimum period of time; (5) require that a purchasing group must have a minimum number of members, common ownership or affiliation, or a certain legal form; (6) require that a certain percentage of a purchasing group must obtain insurance on a group basis; (7) require that any insurance policy issued to a purchasing group or any members of the group be countersigned by an insurance agent or broker residing in that State; or (8) otherwise discriminate against a purchasing group or any of its members. (b) Scope of exemptions. The exemptions specified in subsection (a) of this section apply to - (1) liability insurance provided to - (A) a purchasing group; or (B) any person who is a member of a purchasing group; and (A) liability coverage; (B) insurance related services; or to a purchasing group or member of the group. (c) Licensing of agents or brokers for purchasing groups. A State may require that a person acting, or offering to act, as an agent or broker for a purchasing group obtain a license from that State, except that a State may not impose any qualification or requirement which discriminates against a nonresident agent or broker. (d) Notice to State insurance commissioners of intent to do business. (1) A purchasing group which intends to do business in any State shall furnish notice of such intention to the insurance commissioner of such State. Such notice - (A) shall identify the State in which such group is domiciled; (B) shall specify the lines and classifications of liability (C) shall identify the insurance company from which the group (2) Such purchasing group shall notify the commissioner of any such State as to any subsequent changes in any of the items provided in such notice. (e) Designation of agent for service of documents and process. A purchasing group shall register with and designate the State insurance commissioner of each State in which it does business as its agent solely for the purpose of receiving service of legal documents or process, except that such requirement shall not apply in the case of a purchasing group - (1) which - (A) was domiciled before April 1, 1986; and (B) is domiciled on and after October 27, 1986; in any State of the United States; (2) which - (A) before September 25, 1981, purchased insurance from an (B) since September 25, 1981, purchases its insurance from an (3) which was a purchasing group under the requirements of this (4) as long as such group does not purchase insurance that was (f) Purchases of insurance through licensed agents or brokers A purchasing group may not purchase insurance from a risk retention group that is not chartered in a State or from an insurer not admitted in the State in which the purchasing group is located, unless the purchase is effected through a licensed agent or broker acting pursuant to the surplus lines laws and regulations of such State. (g) State powers to enforce State laws. Nothing in this chapter shall be construed to affect the authority of any State to make use of any of its powers to enforce the laws of such State with respect to which a purchasing group is not exempt under this chapter. (h) States' authority to sue. Nothing in this chapter shall affect the authority of any State to bring an action in any Federal or State court.
Sec. 3904. Securities laws (a) Ownership interest of members in risk retention groups The ownership interests of members in a risk retention group shall be - (1) considered to be exempted securities for purposes of (2) considered to be securities for purposes of the provisions (b) Investment companies. A risk retention group shall not be considered to be an investment company for purposes of the Investment Company Act of 1940 (15 U.S.C. 80a-1 et seq.). (c) State blue sky laws. The ownership interests of members in a risk retention group shall not be considered securities for purposes of any State blue sky law. Sec. 3905. Clarification concerning permissible State authority (a) No exemption from State motor vehicle no-fault and motor Nothing in this chapter shall be construed to exempt a risk retention group or purchasing group authorized under this chapter from the policy form or coverage requirements of any State motor vehicle no-fault or motor vehicle financial responsibility insurance law. (b) Applicability of exemptions. The exemptions provided under this chapter shall apply only to the provision of liability insurance by a risk retention group or the purchase of liability insurance by a purchasing group, and nothing in this chapter shall be construed to permit the provision or purchase of any other line of insurance by any such group. The terms of any insurance policy provided by a risk retention group or purchased by a purchasing group shall not provide or be construed to provide insurance policy coverage prohibited generally by State statute or declared unlawful by the highest court of the State whose law applies to such policy. (d) State authority to specify acceptable means of demonstrating financial responsibility. Subject to the provisions of section 3902(a)(4) of this title relating to discrimination, nothing in this chapter shall be construed to preempt the authority of a State to specify acceptable means of demonstrating financial responsibility where the State has required a demonstration of financial responsibility as a condition for obtaining a license or permit to undertake specified activities. Such means may include or exclude insurance coverage obtained from an admitted insurance company, an excess lines company, a risk retention group, or any other source regardless of whether coverage is obtained directly from an insurance company or through a broker, agent, purchasing group, or any other person.
Sec. 3906. Injunctive orders issued by United States district courts
Any district court of the United States may issue an order enjoining a risk retention group from soliciting or selling insurance, or operating, in any State (or in all States) or in any territory or possession of the United States upon a finding of such court that such group is in hazardous financial condition. Such order shall be binding on such group, its officers, agents, and employees, and on any other person acting in active concert with any such officer, agent, or employee, if such other person has actual notice of such order.
[1] Terry Cummings is a partner with the New York City law firm of Ohrenstein & Brown, LLP and may be reached at (212) 682-4500; email: terry.cummings@oandb.com. [2] It is questionable whether a for-profit corporation whose shareholders included non-insured members of the group (e.g. a producer or broker) would be viewed as a purchasing group entity within the meaning of the federal statute. [3] This view is not uniformly shared by state regulators, many of which are of the view that a purchasing group is limited to purchasing liability insurance only. [4] A definition of group insurance may be found in New York Insurance Department Regulation 135 . [5] T his appears to he directed at protecting policies issued to groups like the ABA or AMA, which would not cover all eligible members . |
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