July 15, 2020

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July 15, 2020

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New Jersey TPA Reporting Requirements in 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.


© Polsinelli PC, Polsinelli LLP in CaliforniaNational Law Review, Volume IX, Number 42


About this Author

Steven L. Imber, Polsinelli PC, Insurance Regulatory Attorney, Enforcement Actions Lawyer,

Steve Imber chairs Polsinelli's Insurance Business and Regulatory group.  As a former General Counsel at a state insurance department, Steve Imber has the knowledge and experience to provide quality counsel to insurers, third party administrators, insurance agencies, medical discount plans and other insurance regulated entities. His practice includes representing and assisting clients on multi-state and national licensing projects, research projects, enforcement actions, market conduct examinations, audits and compliance programs and various other regulatory and...


Jennifer Osborn Nix works diligently for insurance companies, third-party administrators, and other regulated entities to further their goals and help them remain compliant within the 50-state regulatory scheme. She focuses on insurance regulatory and compliance issues, with a primary emphasis on life and health insurance matters.

Jennifer works with many regulated entities, including many in the health care sector, who rely on her for research, advice, strategic counsel, and licensing.


Justin Liby has a talent for organizing and managing large national and multi-state licensure and research projects. This knack provides him with a solid foundation for crafting and implementing sound, efficient strategies that achieve success for his clients. Justin concentrates his efforts on helping the insurance industry navigate the formidable federal and state regulatory maze to achieve the industry’s business needs. He stays current in the insurance industry's evolution, as well as the legislation and regulatory activity impacting the industry.