Comment Letters

NASBP often issues public comment letters on initiatives that are counter productive to the surety industry. These comment letters are often written on behalf of NASBP members.  Listed below is a list of public comment letters recently written by NASBP to various state and federal agencies.

Comment Letter Library

Statement by NASBP and SFAA concerning the First Sealord Surety Liquidation

The Surety Industry Remains Strong, Well Regulated, and Committed to the Financial Strength and Security of Surety Bonds.

Green Building and Surety Bonds

Ohio Construction Reform Surety Bond Rules

Comments from NASBP to the Ohio Department of Administrative Services regarding the draft Construction Reform Surety Bond Rules present in a recently passed bill, OH HB 153.

Hill Visit Report Form

Standard Form 28 - Affidavit of Individual Surety

NASBP's comments in recommendation that the Office of General Services (GSA) approve an extension to the current information collection requirement which provides that, in order to qualify as a surety, individuals must complete and furnish contracting...

Fiscal FMS Comment Letter

Comments on Financial Management Service (FMS) docket number FISCAL-FMS-2010-0001 with regards to concerns with proposed rules impacting the administration of the corporate surety program by FMS.

NASBP Points about Individual Surety and Proposed MD Bills

NASBP has developed these points about Individual Surety and the proposed MD legislation for you to help educate and to share with your legislators. NASBP’s position is that any insurer, whether a natural person or a corporation, should be subject...

NASBP Comments on FASB Revenue Recognition Proposal

These are the comments that NASBP sent to FASB on October 13, 2010 with regard to the Exposure Draft on Revenue Recognition from Contracts with Customers. This issue is particularly of concern to the surety industry, since the Financial Accounting...

NASBP Comments on FASB 715 - Compensation-Retirement Benefits-Multiemployer

On November 1, NASBP submitted comments on the Financial Accounting Standards Board's (FASB) proposal with respect to disclosure about an employer's participation in a multiemployer plan (FASB 715 Exposure Draft issued on September 1, 2010.)

NASBP Comments on FASB Exposure Draft Topic FASB 450 – Loss contingencies in general

NASBP submitted comments on September 20, 2010 on the Financial Accounting Standards Board (FASB) Exposure Draft Topic FASB 450 – Loss contingencies in general of which multiemployer plans are a very small part . NASBP held a Virtual Seminar on September...

NASBP comments on IASB Exposure Draft IAS 19 – Employer accounting for defined benefit plans

NASBP submitted comments on September 3, 2010 on the International Accounting Standards Board (IASB) Exposure Draft IAS 19 – Employer accounting for defined benefit plans in general of which multiemployer plans are a part. NASBP held a Virtual Seminar...

NASBP Comment letter concerning resident agent countersignature requirements in Florida that prohibited by statute

Letter sent August 4, 2010 to Mr. Richard J. Bechtold, Construction Contracts Coordinator, Design and Construction Division, General Services Administration Department (GSA), Re: Countersignature requirements for Project/Contract Number GSA W20167

FR Doc. 2010-14144, June 11, 2010 - Small Business Task Force Request for Comments

NASBP SFAA Joint letter to the US Small Business Administration on how to increase opportunities for small contractors on federal projects. Mr. Joseph Jordan, Associate Administrator, Small Business Administration

NASBP/SFAA’s comment letter concerning proposed legislation to create a bond program through the US Dept. of the Interior

NASBP/SFAA’s comment letter concerning proposed legislation to create a bond program through the US Dept. of the Interior

NASBP’s comment letter to the General Services Administration concerning warranty terms for photovoltaic systems

NASBP’s comment letter to the General Services Administration concerning warranty terms for photovoltaic systems

NASBP’s comment letter to the New York State Education Department concerning waiving statutory bonding requirements

NASBP’s comment letter to the New York State Education Department concerning waiving statutory bonding requirements

NASBP’s comment letter to the MN DOT concerning Disadvantaged Business Enterprise (DBE) Provisions & Forfeiture of Bid Security

NASBP’s comment letter to the MN DOT concerning Disadvantaged Business Enterprise (DBE) Provisions & Forfeiture of Bid Security

NASBP’s comment letter to the WI Dept. of Workforce Development concerning an increase to the bonding threshold

NASBP’s comment letter to the WI Dept. of Workforce Development concerning an increase to the bonding threshold

NASBP’s comment letter to the FAR Council concerning mandatory threshold increases to the Federal Miller Act

NASBP’s comment letter to the FAR Council concerning mandatory threshold increases to the Federal Miller Act

NASBP’s letter to US Senate Leaders supporting Senator Cardin’s amendment to make permanent enhancements to the SBA Bond Guarantee Program

NASBP’s letter to US Senate Leaders supporting Senator Cardin’s amendment to make permanent enhancements to the SBA Bond Guarantee Program

NASBP’s letter to DC Council Member Cheh opposing legislation to increase bond threshold requirements

NASBP’s letter to DC Council Member Cheh opposing legislation to increase bond threshold requirements

NASBP’s comment letter to the Arizona Secretary of State concerning countersignature requirements

NASBP’s comment letter to the Arizona Secretary of State concerning countersignature requirements

NASBP/SFAA letter to US Small Business Administration’s Administrator Mills concerning suggested changes to the SBA Bond Guarantee Program

NASBP/SFAA letter to US Small Business Administration’s Administrator Mills concerning suggested changes to the SBA Bond Guarantee Program