Faculty Profile: Tony Greer

Overview:
Tony Greer practices in the area of insurance regulatory law, with particular emphasis on traditional life, health, and property and casualty insurers, as well as captives, risk retention groups, and self-insurance funds. He also has experience working on state securities and professional employer organization matters.

Before going into private practice, Mr. Greer worked for the Tennessee Department of Commerce and Insurance for approximately ten years where he served as Chief Counsel for Insurance, Securities and TennCare Oversight. While working there, he advised on and helped to enforce numerous laws and regulations impacting the insurance, securities and professional employer organization industries.

Mr. Greer has extensive experience drafting legislation and advising on the impact of pending legislation. He has drafted and lobbied to pass changes to laws impacting the insurance, securities and professional employer industries.

Mr. Greer also has extensive experience advising on insurance company solvency and holding company laws and regulations. Further, he has worked on over twenty-five state insurance department regulatory approvals for insurance companies' mergers, acquisitions and other changes of control. Finally he has worked on 2 conversions of workers compensation self-insurance funds to mutual insurance companies.

Mr. Greer has represented life, health, and property and casualty insurers in contract and regulatory matters. He has also represented rate service organizations, insurance producers, and managing general agents in contract and regulatory matters. Finally, he also represents alternative insurance vehicles, such as captives, risk retention groups, and self-insurance funds.

Prominent Assignments:
Conducted a fifty state survey on life insurance participating policy laws and regulations.

In the Matter of: Snoyer Signs and Accident Fund Insurance Company – represented a rate service organization as a witness in the workers compensation rate appeal hearing.

Provided regulatory guidance to a life insurance company for internal corporate governance matters in the States of Texas and New York and for recorded telephone call record retention requirements in the states of Texas, California, Florida, New York, and Pennsylvania.

Provided regulatory guidance to a property and casualty insurance company on insurance and warranty laws in the states of Florida and California.

Provided regulatory guidance to a property and casualty insurance company on inland marine insurance policy rate and form filing requirements in the states of Florida, Texas California and New York.

Provided regulatory guidance to a property and casualty insurance company on complying with the custodial agreement requirements in the state of Missouri.

Provided regulatory guidance to a property and casualty company on creating an Own Risk Solvency Assessment framework within the company and drafting an Own Risk Solvency Assessment Report to comply with a request from insurance regulators in Switzerland.

Provided regulatory guidance to a health insurance company on complying with the insurance holding company laws in Tennessee; specifically dealing with transaction between affiliates within a holding company system and Own Risk Solvency Assessment compliance.

Provided regulatory guidance to a risk retention group on solvency and corrective action plans in the State of Tennessee.

Provided regulatory guidance to a risk retention group on complying with the change of control under the insurance holding company act and complying with an order of administrative supervision under the insurers rehabilitation and liquidation act in the State of Tennessee as well as drafting a corrective action plan for the risk retention group.

Provided regulatory guidance to 3 different risk retention groups on complying with the managing general agent laws and reviewed the managing general agent contracts to ensure compliance with the managing general agent laws in the state of Tennessee.

Provided regulatory guidance to 2 different risk retention groups on complying with the holding company laws in Tennessee; specifically dealing with whether or not a holding company existed and drafting and filing the holding company registration statements and enterprise risk forms.

Represented over 25 captive insurance companies with new captive insurance company formations in the states of Tennessee, North Carolina and Alabama.

Represented a policyholder in filing a consumer complaint with the Tennessee Department of Commerce and Insurance against a life insurer that resulted in the full refund of all premiums paid on four separate whole life insurance policies several years after the expiration of the insurance policies free look and incontestability periods.

Professional Involvement:
Chair of the Tennessee Captive Insurance Association Government Relations Committee
Member of the Tennessee Bar Association
Register lobbyist in the State of Tennessee

Publications:
Insurance Division Interpretive Opinion No. 01-06, Vehicle Location Unit Warranty
Insurance Division Interpretive Opinion No. 02-06, Foreign Government Ownership of Insurance Company
Revenue Ruling #07-12, Business Tax Timeshare Industry - Off Premises Contact Businesses Tenn. Rev. Rul. LEXIS 1
Revenue Ruling #07-27, Labor Services - Business Tax and Gross Receipts From Temporary Labor Services Tennessee Letter Ruling #07-35, Software - Monthly Subscription Fee for Web-based Software and Services, RIA SLT TN 11/26/2007
Tennessee Letter Ruling #07-36, Equipment - Lease Agreement vs. Service Agreement RIA SLT TN 11/26/2007
Tennessee Letter Ruling #08-08, Purchase of Telecommunication Services by Internet Service Providers
Tennessee Letter Ruling #08-16, Billing Services - Performed Outside Tennessee
Tennessee Letter Ruling #08-17, Single Article Cap - Bundled Computer Software
Tennessee Letter Ruling #08-23, Telecommunications - Telephone Answering Services
Revenue Ruling #08-24, Single Article Limitation - Computer Software and Optional Maintenance Agreements, RIA SLT TN 03/12/2008
Tennessee Letter Ruling #08-29, Telecommunications - Sale of DSL Services