HB 3320 creates a new chapter in the Texas Insurance Code authorizing a “Religious Institutions Self-Insurance Pool” for churches, nonprofit religious organizations, and religious denominations. The pool would allow qualifying religious entities to band together to self-insure for property and casualty risks, primarily damage to or loss of buildings and structures, and optionally for premises liability, contents, wind and hail, loss of use, and medical payments coverage. The bill specifies that the pool is not an insurer, not insurance for purposes of the code, not a partnership, and not covered by the Texas Property and Casualty Insurance Guaranty Association.
The bill sets out a detailed framework for forming and operating the pool, including creation by agreement among at least two qualifying organizations or one or more denominations, establishment of a trust fund, selection of a nine-member board, and application for a certificate of authority from the Texas Department of Insurance before coverage may begin. It imposes financial and operational requirements such as minimum net worth and liquidity thresholds, advance premium payments, reserve accounts, excess insurance or reinsurance, annual financial reporting, commissioner-approved rates, and recordkeeping and examination standards. It also includes provisions governing agents, member liability, refunds, investments, dissolution, and enforcement, including corrective action plans and administrative penalties.
The bill would affect the Insurance Code by adding a specialized regulatory structure for a narrow class of self-insurance arrangements tied to religious institutions. It gives the commissioner rulemaking authority, application-review authority, examination powers, and enforcement tools similar to those used for insurers, while also carving the pool out of many ordinary insurance-law provisions. Religious institutions that join the pool would assume joint and several liability for pool obligations, and agents, administrators, and trustees would be subject to specific licensing, bonding, and contractual requirements.
Overall sentiment appears favorable. The bill passed the House overwhelmingly and was reported favorably in the Senate Business & Commerce Committee by a 10-1 vote, indicating broad support with limited opposition. The absence of committee transcript debate suggests no major recorded controversy in the available materials, and the bill’s progression to the Senate intent calendar indicates it advanced through the process without significant procedural resistance.
The main point of potential contention is the policy choice to create a special insurance-like structure for religious institutions outside the standard guaranty and insurance framework. Concerns could include the joint and several liability imposed on members, the exclusion from the guaranty association, and whether the pool’s exemption from general insurance regulation creates consumer-protection or solvency risks. Supporters likely view the bill as a way to give faith-based organizations a tailored and potentially more affordable risk-management option, while critics may focus on financial exposure, regulatory carve-outs, and the possibility of insolvency affecting member institutions.
HB 3320 would add Chapter 2214 to the Insurance Code and create a new regulatory regime for a religious-institutions self-insurance pool. It would authorize qualifying churches, nonprofit religious organizations, and religious denominations to form a pool, obtain a certificate of authority, and provide specified property and casualty coverages under commissioner oversight. The bill also establishes financial, governance, reporting, examination, enforcement, and dissolution requirements, while expressly excluding the pool from treatment as an insurer, partnership, or guaranty-association member.
The available voting history indicates strong support for the bill, with large bipartisan margins in the House and a favorable Senate committee vote of 10-1. No committee transcript is available, so there is no recorded floor or committee debate to suggest broader disagreement in the provided materials. The overall tone is therefore supportive, with only limited opposition reflected in the committee vote.
The likely areas of contention are the bill’s special treatment of religious institutions and the risk allocation built into the pool structure. Opponents may question the exemption from ordinary insurance regulation and guaranty-association protection, the requirement that members be jointly and severally liable for pool liabilities, and whether the financial safeguards are sufficient to protect participating organizations. Supporters, by contrast, appear to favor the bill as a targeted mechanism to help religious entities self-insure property and casualty risks under state supervision.