Office of the Chief Information Officer (OCIO) 1

Presentation to the Advisory Committee on Risk-Sharing Mechanisms

February 1, 2024

Federal Insurance Office

Terrorism Risk Insurance Program:

Update on Current Activities
Introduction

▪ Update on Recent Activities: Since the last ACRSM meeting on July 26, 2023, TRIP has 

continued to address the operational readiness and administration of the Program, including

▪ Security upgrades to the TRIP Claims System;

▪ Reauthorization of TRIP Claims System forms and processes; and

▪ Calculation of the Insurance Marketplace Aggregate Retention Amount (IMARA) for 2024.

▪ Upcoming Activities: There are also a number of upcoming events to highlight relating to TRIP, 

including

▪ The 2024 TRIP Data Call; 

▪ Terrorism Risk Insurance Modeling; and 

▪ The 2024 IFTRIP Annual Conference.

▪ Federal Insurance Response to Catastrophic Cyber Incidents: A further Status Update on this 

work, which emerges out of the 2019 TRIP Reauthorization Act, will be addressed later in the 

meeting.

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TRIP Claims System and the Federal Share Claims Process

▪ Security Upgrade for TRIP Claims System: In the event of the certification of an “Act of 

Terrorism” by the Treasury, TRIP is prepared to receive claims through a web-based facility that will 

permit insurers to submit and Treasury to review documentation supporting payments made by 

insurers. The TRIP Claims System has recently undergone a security upgrade, including the 

migration of the system to the Treasury Cloud. In addition to the receipt of claims information, the 

TRIP Claims System is structured to receive data in connection with a certification process, and if 

necessary to manage the collection of surcharges imposed by Treasury through either a mandatory 

or discretionary recoupment process.

▪ Documentation Requirements: The information required for submission of claims for the federal 

share of compensation, and other purposes associated with the Program, is an “information 

collection” within the meaning of the Paperwork Reduction Act, which requires that any forms 

associated with that information collection be reauthorized every three years, through a public 

notice and comment process, with approval from the Office of Management and Budget (OMB).

OMB recently approved the continued use of the forms for an additional three-year period, to 

January 31, 2027. There were no changes to the forms or information sought in this recent 

renewal.

▪ Information: Although the TRIP Claims System will not be opened for receipt of claims until there 

has been the certification of an “Act of Terrorism,” information concerning its operation, including 

copies of the forms identifying the information that will be required in support of a claim, a data call, 

or a recoupment process can be found on the TRIP Website at https://home.treasury.gov/policyissues/financial-markets-financial-institutions-and-fiscal-service/federal-insurance-office/terrorismrisk-insurance-program/federal-share-claim-process. 

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Insurance Marketplace Aggregate Retention Amount (IMARA)

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The Insurance Marketplace Aggregate Retention Amount (IMARA) is the measure that 

defines whether Treasury must recoup amounts it pays as the federal share of 

compensation.

▪ It is the average sum of insurer deductibles under TRIP over the prior three years. Thus, the 

IMARA for Calendar Year 2024 is based upon the average of all insurer deductibles in 2023, 

2022, and 2021. Because the TRIP deductible is 20 percent of TRIP-eligible lines premium in 

the prior year, the deductibles for 2023, 2022, and 2021 are based upon 2022, 2021, and 2020 

TRIP-eligible lines premium.

▪ Accordingly, the IMARA will increase each year if industry premiums in the TRIP-eligibles lines 

of insurance also increase.

▪ If industry payments in connection with certified acts of terrorism in a particular calendar year 

are below the IMARA, any amounts paid by Treasury must be recouped, at a rate of 140 

percent, at least up to an amount where the industry payments and the amount subject to 

recoupment reach the IMARA.

▪ To the extent industry payments in a particular calendar year are above the IMARA, Treasury 

may (but is not required) to recoup amounts it has expended. Such recoupment above the 

IMARA is made at a rate of 100 percent.

Purpose
Insurance Marketplace Aggregate Retention Amount (IMARA) 

(continued)

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Calculation for CY2024: In 2020, the current methodology for calculating the IMARA 

commenced. FIO calculates the IMARA each year and publishes the figure in the Federal 

Register. The IMARA for CY2024, $48.5 billion, was published in the Federal Register (88 FR 

87843) on December 19, 2023. The chart below shows the growth of the IMARA year-overyear from 2015 to 2024. 

Further Study: The Committee noted in its May 2020 Report and Recommendations that, as 

the IMARA continues to increase, FIO should consider whether “Mandatory Recoupment and 

the growing IMARA can lead to unintended results.” FIO is continuing to evaluate the impact of 

the IMARA in relation to other Program mechanics. 

29.5 31.5 33.5 35.5 37.5

40.9 41.7 42.7 45

48.5

0

10

20

30

40

50

60

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

IMARA ($Bn)

Year
2024 TRIP Data Call

The annual TRIP Data Call was established by the 2015 TRIP Reauthorization Act to permit the 

Secretary to evaluate the effectiveness of TRIP, including whether terrorism risk insurance is 

available and affordable. The first data call (held on a voluntary basis) was conducted in 2016. 

Since 2016 Treasury has conducted seven mandatory data calls, and the 2024 TRIP Data Call 

will be the eighth mandatory data call. FIO uses the data to satisfy the reporting requirements 

also imposed by the 2015 TRIP Reauthorization Act, which require a report on the 

effectiveness of the Program (in even-numbed years) and a report on the competitiveness of 

small insurers in the terrorism risk insurance marketplace (in odd-numbered years). 

2024 TRIP Data Call: There are no substantive changes in terms of the information that will be 

requested in the 2024 TRIP Data Call. A notice announcing the commencement of the TRIP 

Data Call will be published in the Federal Register, at some point after state statutory reporting 

by insurers to state regulators has concluded at the beginning of March 2024. 

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TRIP Data Call
Terrorism and Cyber Risk Modeling

▪ Terrorism Risk Modeling: FIO has augmented its ability to model terrorism risk events, 

including their potential impact upon TRIP, through the acquisition of a commercial terrorism 

risk model as well as a separate application developed specifically for TRIP that evaluates 

impacts of modeled events upon TRIP. These tools provide FIO with additional information 

regarding the private market for terrorism risk, as well as the operation of the Program in 

various future circumstances. 

▪ In the 2023 Small Insurer Report, Treasury used the models to analyze the likely impact of the 

Program Trigger on the ability of Small Insurers to access the Program, and the likely impact of the 

Program Cap on limiting payment of the federal share of compensation and insurer payments in 

connection with certain potential acts of terrorism.

▪ Cyber Risk Modeling: FIO is also in the process of installing a cyber risk model that will 

permit it to model the impacts of various cyber terrorism events and cyber incidents.

▪ Reporting: As it did in its 2023 Small Insurer Report, FIO will continue to report on its 

evaluation of various modeled events and their implications for the Program, and to engage 

with the ACRSM and industry stakeholders on those issues.

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2024 IFTRIP Annual Conference, Washington, DC

▪ IFTRIP: IFTRIP is the International Forum of Terrorism Risk (Re)Insurance Pools, which is 

an organization of the national risk pooling arrangements of 15 nations. IFTRIP is a forum 

for the development of best practices and areas of common interest in the insurance of 

terrorism risk. FIO serves as the Chair of IFTRIP. 

▪ Annual Conference at Treasury: IFTRIP has historically conducted an annual conference, 

consisting of a “Pools Only” meeting on the first day, followed by a public conference on the 

second day, involving the Pools, stakeholders, academics, governmental representatives 

and others. The public conference has typically consisted of panel discussions and 

presentations in the area of terrorism risk insurance, as well as the role of public-private 

partnerships more generally. 

▪ 2024 Details: Planning is now underway for an in-person IFTRIP Annual Conference to be 

held the week of April 22, 2024 in Washington, DC, which will be the first public in-person 

conference since 2019. Treasury will be hosting the Pools Only meeting at Treasury, with 

the public conference to be held in Washington at an off-site location. Further details and 

information will be circulated by IFTRIP shortly. We look forward to ACRSM participation 

and engagement in this event. 

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