Treasury’s December 7, 2016 interim final rule contains a 30-day notification provision, but it does not set a 30-day deadline for certifying an act of terrorism. The clock begins when the Secretary commences review. It does not begin automatically on the date of a violent event, and the resulting notice is not a final certification decision. [2016-29313][2016-06920]

The operative communication provision requires Treasury to announce that review has begun within that period. When circumstances make timely notification impracticable, notice must follow as soon as practicable in a manner the Secretary considers appropriate. Treasury declined strict deadlines for the overall certification determination; that choice does not eliminate the rule’s separate notification and consultation milestones. [2016-29313][2016-06920]

The April 1 proposal helps define what the December action does not complete. It proposed broader Terrorism Risk Insurance Program revisions, including civil penalties and final netting of payments. The interim final rule addresses only certification procedure and reserves the wider revision for later. These are successive documents in the same rulemaking, not separate confirmation that the entire proposed package became operative. [2016-29313][2016-06920]

The specified effective date and written-comment deadline are both January 6, 2017, two functions of the same date rather than immediate effectiveness in December. For readers, the useful distinction is between process information and an outcome: under review does not mean certified, and certification is not itself a payment guarantee. The retained documents establish procedural requirements, not the resolution of any particular insurance claim. [2016-29313][2016-06920]

Source documents

  1. Terrorism Risk Insurance Program; Certificationhttps://www.govinfo.gov/content/pkg/FR-2016-12-07/html/2016-29313.htm
  2. Terrorism Risk Insurance Programhttps://www.govinfo.gov/content/pkg/FR-2016-04-01/html/2016-06920.htm