2016 Captive Insurance Update | Issue 2 | 2016

by Downs Rachlin Martin PLLC
Contact

Downs Rachlin Martin PLLC

A summary of state and federal developments in the captive insurance industry

DEVELOPMENTS IN VERMONT

Changes at the Top

Vermont Released Aggregate Financial Data for Vermont Captives in 2015

2016 Captive Legislation

FEDERAL TAX MATTERS

831(b) Legislation

PROTECTED CELL LITIGATION

FHFA ISSUE RULE PREVENTING CAPTIVES FROM FHLB MEMBERSHIP

FEDERAL STUDY ON THE OVERALL EFFECTIVENESS OF THE TERRORISM RISK INSURANCE PROGRAM

RISK RETENTION GROUP DEVELOPMENTS/FEDERAL PREEMPTION

 

Developments in Vermont

More Changes at the Top

Governor Peter Shumlin (D-Vt.) is not running for re-election this fall, so Vermont will have a new governor in January 2017.  In addition, the Commissioner of the Vermont Department of Financial Regulation (DFR), Susan Donegan, stepped down in June, and Governor Shumlin has appointed a new commissioner.  The new commissioner, Michael Pieciak, is an attorney who previously served as Deputy Commissioner of the DFR’s Securities Division, and was very active in an investigation by the DFR, in coordination with the federal Securities and Exchange Commission, into the use of large amounts of funds raised under the Immigrant Investor Program (the “EB-5 Program”) by Vermont developers.  It is not clear whether the new governor will reappoint Commissioner Pieciak (assuming that the Commissioner is interested in staying on) or bring in a new person.

We expect no substantive change to the DFR’s Captive Division as a result of these changes “at the top;” Deputy Commissioner David Provost continues to lead the Captive Division along with his deep bench of long-term staffers.

Vermont Released Aggregate Financial Data for Vermont Captives in 2015

Sandy Bigglestone, Director of Captive Insurance at the DFR, issued Memo #2016/03 on July 15, 2016, providing aggregate financial data for all Vermont captives as of December 31, 2015.  Vermont captives’ 2015 gross written premium totaled $27.6 billion, which was a significant increase over the prior year.  There were 588 active captives in Vermont as of December 31, 2015.  Nine new captives were licensed in Vermont during the first six months of 2016.

2016 Captive Legislation

After a busy year in 2015, the legislative package for 2016, signed by the Governor on April 13, 2016, is less ambitious with a focus on improving existing laws rather than introducing new initiatives. Significant provisions of the new law include:

  • Sale or Conversion of Cell Captives. Three new sections were added to Vermont’s Sponsored Captive law. These sections, 8 V.S.A. §§6034(b) - (d), are intended to clarify the process for: (i) converting an existing protected cell into an incorporated protected cell; (ii) selling, transferring or assigning an existing protected cell to a new sponsor; and (iii) converting one or more existing protected cells or incorporated protected cells into a different type of captive (pure, RRG, industrial insured, etc.).  These provisions will provide a clear path for Vermont-domiciled cell captives to expand and adapt to the changing needs of their businesses.
  • Dormancy. 8 V.S.A. §6024 allows pure captives to apply for a certificate of dormancy if they had: (i) ceased transacting the business of insurance; and (ii) no remaining liabilities associated with insurance transactions. If approved, a dormant captive is subject to a statutory minimum capital requirement of $25,000 (rather than $250,000), and is not subject to any premium tax. Dormancy, therefore, allows a company to mothball a captive, rather than dissolve it, so that it can cheaply and easily be restarted if and when conditions warrant. The 2016 legislation allows sponsored captives and industrial insured captives to take advantage of the dormancy provisions and eliminates the prohibition on dormancy for captives that historically insured controlled unaffiliated business.
  • Fiscal Year Filers. 8 V.S.A. §6007(c) allows pure captives and industrial insured captives to request that annual reports be due after the fiscal year-end, rather than the calendar year-end. This may be useful for captives whose insureds use a fiscal year that does not match the calendar year.  The 2016 legislation adds association captives and sponsored captives to the list of entities that can request a fiscal-year-end filing.
  • Governance Standards for Risk Retention Groups. With a year of experience in implementing the new governance standards for risk retention groups, the 2016 legislation adds several provisions intended to rationalize the governance standards and ease (somewhat) the related implementation burden.

8 V.S.A.§6052(g)(1)(D) was revised to make it clear that a defense counsel will only be deemed to be a material service provider if its annual fees meet the statutory thresholds for three of the past five years. It is very difficult to predict defense counsel’s fees in advance so the proposed legislation relaxes the requirement and makes the inquiry retrospective.

8 V.S.A. §6052(g)(2) was revised to eliminate the requirement that the attorney-in-fact of a reciprocal meets the same independence requirements as a company’s board. Most reciprocals have a subscribers advisory committee that is subject to the independence requirement and that supervises the attorney-in-fact.  Applying the independence requirement to the attorney-in-fact was duplicative.

8 V.S.A. §6052(g)(5) was revised to replace the term “plan of operations” with “business plan” to make it clear that a company’s business plan for governance standards, one of the required components of the governance standards, does not need to be filed in each state in which a risk retention group is registered.

In addition, the DFR issued Memo #2016/02 on March 25, 2016 clarifying several provisions of the new Governance Standards, and requiring that all RRGs attest to their compliance with the standards.  The DFR is expected to issue additional guidance shortly, which will address a number of other issues that have arisen in connection with the implementation of the new Governance Standards.

Federal Tax Matters

831(b) Legislation

Shortly after so-called 831(b) captives appeared on the IRS’s “dirty dozen” list, Congress passed new legislation significantly expanding the scope of the election while tightening the eligibility requirements to address the perceived abuses that led to IRS scrutiny. Section 831(b) of the Internal Revenue Code allows certain small property and casualty insurance companies to be taxed solely on investment income, excluding underwriting income.

For tax years beginning after December 31, 2016, to qualify for the 831(b) election, a captive must satisfy one of the following tests:

  • Diversification. No more than 20% of a captive’s premiums can be attributable to a single insured (including all companies within the same controlled group).
  • Ownership. The ownership test is difficult to parse, but it apparently can be satisfied in one of two ways:

1. None of the captive’s direct or indirect owners is the spouse or lineal descendant of a direct or indirect owner of any of such captive’s insureds; or

2. If one or more of the captive’s direct or indirect owners is the spouse or lineal descendant of one or more of the direct or indirect owners of the captive’s insured businesses, then the direct or indirect ownership interest of such spouse or lineal descendant must match (plus or minus 2%) his or her ownership interest in the relevant insured business.

For captives that are able to satisfy one of these tests, the new legislation increases the cap on written premiums from $1.2 million to $2.2 million and indexes the cap for inflation.

Protected Cell Litigation

Despite the common use of protected cell captives (a/k/a “sponsored captives” in Vermont) around the world, there is very little jurisprudence on the enforceability of the segregation of assets and liabilities afforded by the structure.  On May 13, 2015, the United States District Court for the District of Montana issued an interesting decision in which it found that an unincorporated cell within a protected cell company does not have the capacity to sue or be sued independent of the protected cell company.  The case also seems to support the segregation of assets and liabilities in a protected cell company.  The full case can be reviewed here.

In this case, a dispute arose under a reinsurance contract entered into by Pacific Re, Inc. (Pac Re), which is a protected cell captive insurance company, on behalf of Pac Re 5-AT (Cell 5), which is a cell within Pac Re.  A demand for arbitration was made against Pac Re by the reinsureds, AmTrust North America, Inc. and Technology Insurance Company, Inc. Pac Re responded that the proper party to be named in the demand for arbitration was only Cell 5, and not also Pac Re.  The narrow issue in the case was whether Pac Re was a proper party to the arbitration.

The Court ruled that the unincorporated cell (Cell 5) is not a separate legal entity, although it is clear that the liabilities and assets of the protected cell are segregated from the other cells. Accordingly, the Court found that the cell does not have the capacity to sue or be sued independent of the larger protected cell company.  The Montana protected cell legislation specifically states that the “creation of a protected cell does not create, with respect to that protected cell, a legal person separate from the protected cell captive insurance company unless the protected cell is an incorporated cell.”  The Court ruled that Pac Re was a proper party to the arbitration.

Two interesting conclusions follow from the Montana case.  First, the integrity of the segregation of assets and liabilities between cells in a protected cell company appears to have been respected by at least one court.  And second, there is a difference, at least under Montana law, between the rights and obligations of an incorporated cell versus an unincorporated cell.

FHFA Issue Rule Preventing Captives from FHLB Membership

In January 2016, the Federal Housing Finance Agency (FHFA) issued a final rule amending its regulation on Federal Home Loan Bank (FHLB) membership.  Prior to the new rule, “insurance companies” were eligible for membership in the FHLB and, therefore, eligible for low-cost government-backed financing.  In the last several years, a large number of Real Estate Investment Trusts (REITs) have gained access to this low-cost federal financing indirectly, through ownership of a captive.  The new rule, however, defines “insurance company” to exclude captives.  As a result, captives are no longer eligible to become members of the FHLB and those that are members have five years to terminate their membership (or one year in the case of a captive that joined after the date the rule was first proposed).

Federal Study on the Overall Effectiveness of the Terrorism Risk Insurance Program

On March 4, 2016, the Treasury Department requested that insurers submit insurance data regarding their participation in the Terrorism Risk Insurance Program Reauthorization Act of 2015 (TRIPRA).  The data is being requested on a voluntary basis this year, but reporting of such data may become mandatory in the future. Data being sought includes, among other information, lines of insurance with exposure to terrorism losses, premiums earned on such coverage, geographic location of the exposures, pricing, the take-up rate, and the amount of private reinsurance purchased.  The information is intended to assist the Secretary of the Treasury in analyzing the effectiveness of the TRIPRA program, which was mandated by TRIPRA.

David Provost, the Deputy Commissioner of the DFR, has urged all Vermont captives writing terrorism coverage to comply with the request even though it is voluntary.  Deputy Commissioner Provost noted that submission of the data will likely become mandatory, and voluntary responses provided now will help identify areas where companies may need to improve their data collection (or where Treasury may need to modify its data request).

Risk Retention Group Developments/Federal Preemption

As we have reported in our Captive Insurance Updates in the past, RRGs have won some significant court victories in the last few years on the issue of federal preemption under the Liability Risk Retention Act (LRRA) of non-domiciliary states’ efforts to regulate RRGs. However, a recent decision in Louisiana has gone the other way. In Zeigler, et al. v. The Housing Authority of New Orleans (La. 4th Cir., March 23, 2016), the State of Louisiana Fourth Circuit Court of Appeals reversed the lower state court’s ruling that the Louisiana direct-action statute is preempted by the LRRA.  The National Risk Retention Association filed an amicus curiae brief in the appeal of the decision, in support of the line of cases that have held that the LRRA preempts all state laws that regulate the operation of risk retention groups outside their state of domicile, including those state laws that grant a right of direct action by injured parties against an insurer (rather than its insured).  In June 2016, the underlying case was settled, so the preemption issue will not be pursued further in the case.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Downs Rachlin Martin PLLC | Attorney Advertising

Written by:

Downs Rachlin Martin PLLC
Contact
more
less

Downs Rachlin Martin PLLC on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.