Tribal Program
Managers
A regulatory program needs a code the council adopts, a commissioner with authority to license, an office that reviews and renews, and a system of record that holds it all. We stand up all four and operate them under the Tribe's own law. The first program is insurance.
Engaged for one piece of the program, or for all of it.
The code, the license classes, the fee schedule, and the commissioner's authority — drafted for the council to adopt, built on a published model act rather than invented.
We staff the licensing office: applications and review clocks, capital compliance, annual filings, renewals, fee collection, and examinations. The Commissioner decides; we do the work behind the decision.
Our platform runs the whole licensing lifecycle online — applications, identity checks, payments, sealed certificates, and a public registry anyone can search. Operated as a managed service, with no tribal IT burden.
End-to-end responsibility: we stand the program up, staff it, run it, and report on it — and hand it back whenever the Tribe is ready to run it in-house.
The Tribe does not insure anything. It licenses the companies that do, sets the rules they follow, and collects a fee for the license — every year. Licensed companies post their own capital and carry their own risk.
A commissioner, a code, and an administrator. No construction, no inventory, no staffing up.
A Certificate of Authority is not a one-time sale. Each licensee pays again next year, and the year after.
Insurance regulation sits outside the gaming framework entirely. No IGRA, no compact, no NIGC.
Tribal domiciles have been licensing companies since 2013, and the industry lists them alongside the states.
Two principals: four decades in insurance and surety, alongside fifteen years standing up and running administrative programs.
General Counsel
Forty years in insurance and surety claims, including senior claims leadership at Great American, Highlands, Hanover, and Hudson Insurance Group. LL.M. in Insurance Law; Certificate in Indian Law; licensed before several tribal courts.
Program Manager
Fifteen years building and running administrative programs, operations, and staffing at scale. Two-time Inc. 5000 honoree and advisor to the Tribal Association of Insurance Commissioners.
Tell us what the council is considering and where the questions are. We will tell you plainly whether we are the right people for it.
Some Tribes bring us a code that was adopted and never staffed. Others start from nothing and hand us the whole program. Both are normal engagements.
The rules of the road, drafted for the council to adopt.
A regulatory program is a legal instrument before it is an office. We draft the code, define what can be licensed, set what it costs, and put the authority in one seat — then bring it to council as a decision, not a concept.
The licensing office, staffed and run under the Tribe's law.
An adopted code with nobody behind it does not produce revenue or protect anyone. We do the administrative work the code requires — intake, review, filings, renewals, collections — and put decisions in front of the Commissioner with the file complete. We can hold the Commissioner seat until the Tribe is ready to staff it.
The record of the program, in one place.
A licensing registry is a legal record. SecretaryOS holds it — a public site, a company portal, and a commissioner console reading and writing to a single source of truth.
Turnkey: nothing for the Tribe to build or staff.
We scope the program, design it, stand it up, staff it, run it, and report on it — then transfer it back to tribal employees whenever leadership decides the time is right.
That is a normal place to start. Describe where the council is and we will tell you which engagement fits — including if the answer is none of them.
If you understand the DMV, you already understand this. What follows is what a Tribal Insurance Domicile actually is, and what it is not. No insurance background required.
The whole model fits in a comparison every council member already knows.
It licenses the people who do, sets the rules they follow, and collects a fee for the license.
It licenses the companies that do, sets the rules they follow, and collects a fee for the license.
A Tribal Insurance Domicile is a DMV for insurance companies, run by the Tribe, under tribal law.
One simple idea: many people put money in a pot so that the unlucky few can be made whole.
Each pays $1,000 a year. None of them can afford to rebuild a house on their own.
The pot holds $1,000,000. Three rebuilds cost $600,000. The three families are made whole.
What remains covers claims staff, reserves for a bad year, and profit. Get the math wrong and the company fails.
Everything else in insurance — underwriting, reserves, actuaries, reinsurance — exists to make sure the pot is big enough when the fire comes. And somebody has to license and supervise the companies holding it.
Every function a state DMV performs has a direct counterpart in an insurance domicile.
No. And the DMV is exactly why.
The state that issued the license does not pay for the wreck, does not get sued for the wreck, and does not lose money because of it. The driver and the driver's insurer carry that.
The Tribe that issued the certificate does not pay the claims. Every licensed company posts its own capital. The Tribe holds no policies, insures nothing, and takes no underwriting risk.
The Tribe collects fees. The companies carry the risk. That separation is the entire point of the model, and it is written into the Insurance Code.
The DMV does not earn money selling cars. It earns money issuing licenses — small amounts, from a great many people, every year.
A driver's license is not a one-time sale. Neither is a Certificate of Authority. Each licensed company pays again next year, and the year after.
Year two is year one's licensees, minus a few who leave, plus everyone new. The base grows on itself without new spending.
No building, no inventory, no construction. A commissioner, a code, and an administrator — the same reason DMV fees are nearly all margin.
This is fee revenue for a government service — not premium, not investment income, and not dependent on anyone visiting the reservation.
The same reason a startup incorporates in Delaware: jurisdictions compete, and companies choose.
State insurance codes are built for national carriers. A tribal code can be written for the companies actually applying.
All-in annual pricing instead of a stack of separate charges that shift year to year.
The main alternative is Bermuda or the Caymans. A tribal domicile is on U.S. soil, which banks and the IRS treat very differently.
Companies already licensed elsewhere can redomesticate — the same as re-registering a vehicle after moving states.
Tribal domiciles are not a concept being tested.
Two have been operating for years, and the industry lists them alongside the states. One opened in 2013, focused on reinsurance companies owned by vehicle dealers and specialized producers, with an all-in annual fee and formations completed in about three business days. A second launched in 2018 with its own insurance code, commissioner, and tribal court review; its fees fund child care, scholarships, and housing.
The alternative these companies would otherwise choose is Nevis, the Seychelles, Bermuda, or Turks and Caicos. Offshore means wrestling with U.S. bank accounts, foreign-entity tax elections, and a reputation problem with regulators.
A company licensed under tribal law is domestic for U.S. tax and banking purposes. That single fact is why tribal domiciles win business from the islands.
Three kinds of companies make up the market. None is a household-name insurer, and that is exactly why they need a domicile that will have them.
A trucking firm with 400 trucks gets tired of its premiums and forms its own insurance company to cover its own fleet. If the year goes well, the money stays in the family instead of going to an outside carrier. That new company has to be licensed somewhere. That somewhere could be here.
When a dealer sells you a service contract, that coverage is often backed by a small reinsurance company the dealer owns. There are thousands of these, they are formed constantly, and every one needs a license. This is the market we recruit from, and an established tribal domicile is built almost entirely on it.
Companies that take on slices of risk from other insurance companies rather than from the public. They are licensed entities like any other, they are often small and specialized, and they are frequently the largest licensees a domicile has.
An insurer covering 1,000 homes in one town can handle three house fires. It cannot handle a wildfire that takes 400 of them at once. So it buys its own coverage from a larger company, which agrees to step in above a certain level of loss. That larger company is a reinsurer — and it is a licensed insurance company too, which means it also needs a domicile. Every link in the chain is a licensed entity, and a domicile earns fees from links most people never see.
Day to day, the work looks far more like running a licensing office than running an insurance company — and we run it for you.
Council enacts the Insurance Code. This is the rules of the road, and it is drafted for you.
One tribal official holds the authority to license, examine, and revoke. We can serve in this seat until the Tribe is ready to staff it.
Applications come in with financials attached. The Commissioner approves, conditions, or denies — the same call a licensing board makes.
Fees come in annually, filings are reviewed, and companies that fall out of compliance lose the license.
Most of the concern this idea raises comes from imagining something it is not. Four things worth ruling out up front.
No IGRA, no compact, no NIGC. Insurance regulation sits outside the gaming framework entirely.
This is not tribal online lending. It is a licensing regime for regulated, capitalized companies with real balance sheets.
Domestic, U.S.-based, and treated as such by banks and the IRS — a selling point against Bermuda, not an imitation of it.
No construction, no land, no staffing up. The Tribe can stop at any point and has lost nothing.
It is a licensing office. The Tribe writes the rules, issues the licenses, collects the fees, and never touches the risk.
Insurance is a pot of money that many pay into so the unlucky few can be made whole.
Somebody has to license and supervise the companies that hold that pot. Today that somebody is a state, or an offshore island.
A federally recognized Tribe can do that job under its own law — the DMV of insurance.
Licensed companies pay the Tribe an annual fee, every year, and the Tribe never carries their risk.
It requires no land, no capital, and no construction — which is why it can be tried without betting anything on it.
Questions are welcome at any point. There is no part of this that leadership should have to take on faith.
Companies apply, verify their identity, upload documents, and pay online. The Commission reviews, approves, and issues sealed certificates automatically. The public verifies any licensee in real time. Built on the TAIC Model Tribal Insurance Act.
Figures shown are the model fee schedule and statutory deadlines. The Tribe sets its own against the adopted ordinance.
A public site, a company portal, and a commissioner console — all reading and writing to a single source of truth.
Landing page with Start Application, Licensee Lookup, and FAQs; live registry search with revocation warnings.
Full model application wizard, business plan and capital proof uploads, service providers, sworn attestations.
Government-ID and selfie verification required before any application can be submitted.
Embedded checkout for application fees and annual renewals — confirmed by webhook, never by the browser.
Official sealed PDF generated on approval or renewal, emailed to the company, and kept in its permanent file.
Review queue with 30-day clock, capital compliance, annual filings, premium assessments, examinations, reinsurance credit.
From application to sealed certificate, with the fee cleared before anything changes.
A government-ID and live selfie check runs before submission. Document authenticity, expiry, and face match are checked automatically. The fee cannot be paid until verification passes, and the Commission stores results only — never the ID images.
A five-step wizard: entity and domicile class, governance, capitalization, initial rates, and sworn attestation. Business plan and capital proof are required; pro-formas, affidavits, and incorporation papers attach to the file. Insurance manager, attorney, auditor, and actuary are captured for review.
Card and ACH forms render inside the portal; card data never touches Commission servers. A signed server-to-server message confirms the payment — the browser is never trusted — and the database updates atomically: payment marked paid, certificate active to the next March 31, audit entry written. Bank transfer carries no processing fee; card payments itemize a disclosed card fee the payer covers.
Entity, governance, capitalization, rates, uploaded documents, and verification status sit on one screen with the 30-day clock running. Approval creates the company, issues the numbered certificate to the next March 31, and emails the sealed PDF. A denial is recorded with its reasons and is auditable.
The certificate carries the Tribe's name and seal, entity type, certificate number, effective and expiration dates, and the Commissioner's signature block. It is emailed as a PDF, stored permanently in the company's file, and resolves in the public registry at any time.
Anyone can verify a licensee in seconds — no account required.
Certificates filtered by entity type and status, in a registry updated in real time.
License number, company, entity type, formed date, status, expiration. No personal information.
A revoked insurer is flagged “do not transact” immediately.
A corporations registry files Articles online, assigns a permanent file number and effective date in one atomic step, and issues a sealed Certificate of Incorporation. A company can incorporate under tribal law and then apply for its Certificate of Authority without leaving the platform.
The platform does not invent a process. It implements the model act the Tribe adopts.
A licensing registry is a legal record. The controls below are structural, not procedural — enforced by the system rather than by staff discipline.
Companies see only their own records; analysts only their division; the public only the registry view. Enforced in the database, not the app.
License status and identity results change only on signed webhooks. Nothing the browser says is trusted.
Business plans, capital proof, and certificates live in private storage; every download is access-checked.
Every approval, revocation, payment, examination, and verification result is logged with actor and timestamp.
The payment and identity providers hold credentials and documents. The Commission stores outcomes only.
An adversarial security audit ran before deployment. It surfaced real issues — privilege escalation, fee bypass, document hijack, penalty tampering — and every finding was closed. Magic-link sign-in means there are no passwords to steal.
Turnkey for the Tribe. We build it, we run it, the Tribe owns the record.
Four of the screens a Tribe and its licensees actually use. Names, numbers, and dates shown are illustrative.
This is to certify that
an insurance corporation · formed on March 12, 2018 · TAIC No. 18821
having complied with the insurance laws and regulations of the Tribe,
is hereby authorized to transact the business of insurance within this domicile,
subject to all applicable provisions of the Tribal Insurance Ordinance.
Effective July 19, 2026 — expires March 31, 2027
Confirm the fee schedule and assessment rates against the ordinance, set official contact details and domain, activate payment and identity accounts, connect the bank for remittance, and designate Commissioner and analyst accounts. We handle the rest.
A program manager who cannot be replaced is not a service, it is a dependency. Everything below follows from that.
The commitments we make in writing at the start of an engagement.
The code, the registry, the licensee files, and the data belong to the Tribe from day one. We hold them as administrator, not as proprietor, and they transfer on request without a fee attached.
Where a program is domiciled, whose law governs a dispute, and which court hears it are structural decisions made at the beginning — not concessions negotiated later when a carrier's form contract turns up.
A licensing program that quietly takes on exposure is a different business with a different balance sheet. We keep that separation explicit in the code, in the fee structure, and in every document a licensee signs.
Our experience runs from inside carrier claims departments to testifying against carriers in bad faith litigation. A regulator needs to know when a filing is thin and when a company is telling the truth about its capital.
If a question about a single licensee takes three phone calls to answer, the program cannot be audited, budgeted, or defended. We consolidate first and optimize second.
Where the roles exist, we recruit and train tribal members into them. A program run entirely by outside staff has a ceiling, and it is lower than leadership usually expects.
Cost, term, and what happens at renewal are stated before work begins. Program administration is not a place for surprises in year two.
Five phases. The last one is the point.
We look at what exists: the authority the Tribe already has, any code on the books, the staffing, and what leadership wants the program to produce. This produces a written assessment whether or not you engage us further.
Code, license classes, fee schedule, commissioner authority, and budget. Leadership approves the design before anything is built.
Code adopted, commissioner designated, platform configured, staff hired and trained, procedures documented. The program opens for applications on a date agreed in advance.
We run it. Leadership gets quarterly reporting on licensees, fee revenue, compliance, and open issues — in a form suitable for council, not a data dump.
Staff, systems, records, and documentation transfer to the Tribe on the schedule set in phase two. If the Tribe would rather we stay, that is a decision made on the merits, not because leaving is impossible.
A scoping assessment is a defined piece of work with a defined cost. Nothing beyond it is assumed.
Insurance law and claims on one side, program operations and administration on the other. Most program failures happen where those two meet.
Insurance law, surety, and fidelity
General Counsel
Gregory Arnold has spent more than forty years in insurance and surety claims, including senior claims leadership at Great American Insurance Company, Highlands Insurance Company, Hanover Insurance Company, and Hudson Insurance Group, where he was the first in-house surety claims hire. He holds a JD from Western State College of Law and an LL.M. in Insurance Law from the University of Connecticut School of Law, with coursework in fidelity and suretyship, reinsurance, insurance solvency, insurance regulation, and American Indian law. Since 2013 he has been retained in more than twenty matters as a testifying bad faith surety and insurance claims expert, and has been qualified by judges in both federal and state court. He co-authors the “Performance Bonds” chapter of the Construction Law Handbook and has published in American Bar Association journals and The Federal Lawyer on insurance regulation and law in Indian country. He holds a Certificate in Indian Law from Seattle University School of Law, is licensed to practice before several tribal courts, and served as a United States Marine Corps courts-martial reporter before law school.
Program management and operations
Program Manager
Jacob Horn brings fifteen years in program management and operations, building and running administrative and staffing programs at scale. His work centers on the administrative, credentialing, and operational infrastructure that sits behind a program — the systems, staffing, and reporting that keep it running and auditable. Companies he has led have twice been named to the Inc. 5000, and recognized by the San Francisco Business Times among the fastest-growing businesses in the region. He works with a deep understanding of Native American affairs and the practical realities of administering programs in Indian country. He serves as an advisor to the Tribal Association of Insurance Commissioners.
Code, structure, and claims questions go to Greg. Program operations, staffing, and the platform go to Jacob. If you are not sure, either of us will route it.
Tell us what the council is considering and where the open questions are. We will tell you plainly whether we are the right people for it.
None of this is required. It just shortens the first call.
One inbox reaches both principals, and it is read the same day.