Last reviewed: 17 September 2026

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The federal law that could replace state-by-state insurance licensing — and still hasn't

Our non-resident licensing explainer covers how a producer gets a separate, reciprocal license in every state they actually sell in today. That whole system exists partly because of a federal law written 25 years ago to threaten something bigger: a single national licensing body that could have replaced it. States avoided that outcome once already, and a second attempt to actually build the federal alternative — as an option layered on top, not a replacement — still hasn't gotten off the ground more than a decade later.

1999: a deadline states had to meet, or else

The Gramm-Leach-Bliley Act of 1999, the federal law best known for loosening the wall between banking and insurance, included a narrower and less-remembered provision aimed squarely at producer licensing: states had three years to make nonresident producer licensing genuinely reciprocal or uniform, with the National Association of Insurance Commissioners (NAIC) determining whether at least 29 states met that bar by November 2002. Miss it, and the law would trigger creation of a federal body — the National Association of Registered Agents and Brokers (NARAB) — to license producers directly, bypassing individual state licensing systems for interstate business.

States met the bar. The NAIC found that 35 jurisdictions, well past the 29 required, had achieved reciprocal or uniform nonresident licensing by the deadline, largely by adopting the reciprocity provisions now found in the NAIC Producer Licensing Model Act (Model #218) described in our non-resident licensing explainer. The original, deadline-triggered version of NARAB was never created.

2015: a second NARAB, built as an option rather than a threat

The idea didn't stay dead. The National Association of Registered Agents and Brokers Reform Act of 2015 — commonly called NARAB II — was signed into law in January 2015, alongside that year's renewal of the federal Terrorism Risk Insurance Act. Unlike the 1999 version, NARAB II isn't a penalty for state non-compliance; it's designed as a voluntary, opt-in clearinghouse. A producer who qualifies — holding a resident license in good standing and clearing a background check — could get a single NARAB membership recognized for nonresident authority across every participating state, instead of filing for, and maintaining, a separate nonresident license in each one individually.

NARAB II is structured as a nonprofit corporation, not a government agency, governed by a 13-member board: eight current or former state insurance commissioners and five insurance-industry representatives, with every member subject to presidential appointment and US Senate confirmation.

Why it still hasn't launched

More than a decade after NARAB II became law, that board has never been fully seated. A president has to nominate the full slate of members and the Senate has to confirm them before NARAB can begin operating at all — and that step simply hasn't happened under any administration since the law passed, despite continued lobbying from producer trade groups for it to be filled. No NARAB membership has ever been issued, because there is no functioning NARAB to issue one.

What this means for checking a producer today

Nothing about how you verify a license changes because of any of this. Every method described in our licensing guide and non-resident licensing explainer — a state DOI's own lookup, or the National Insurance Producer Registry's multistate record tied to a producer's National Producer Number — remains the entire system in practice. Even if NARAB II's board were seated tomorrow, it was written to sit on top of state licensing as an additional, opt-in credential for qualifying producers, not to replace the state-by-state license a producer still has to hold and keep current in every state where they actually do business.