Virginia Regulatory Town Hall
Agency
Department of Criminal Justice Services
 
Board
Department of Criminal Justice Services
 
chapter
Regulations Relating to Private Security Services Businesses [6 VAC 20 ‑ 172]
Action Amend 6VAC20-172 and 6VAC20-174 to Address Insurance Requirements for Independent Contractors
Stage Proposed
Comment Period Ended on 4/21/2017
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2/21/17  10:22 am
Commenter: Thomas Kaschak; Hanover Consulting LLC DCJS#11-8638

Proposed Changes to Insurance/Bond requirements for Private Security Businesses
 

The current regulation setting insurance limits at 100,000 dollars per incident and 300,000 aggregate or a surety bond in the amount of 100,000 dollars is more than sufficient coverage to set as a minimum requirement to have a private security business or as a private investigator.  There are no valid reasons to increase the minimum amount and no valid reasons have been presented by DCJS.

House Bill 1628, presented in the 2017 General Assembly, required, in part, that the option to have a bond, in lieu of liability insurance, has been delayed until passed a second time by the 2018 General Assembly.  During a hearing on House Bill 1628 a representative from DCJS argued that the reason for the elimination of the bond  and raise in liability insurance to 1,000,000 dollars was due to a survey showing that a large percentage of security businesses already carried liability insurance in excess of 100,000 dollars.  

This reason has no foundation of common sense and I believe that this type of regulation is nothing more then regulatory overreach, by a State Regulatory Agency, which will do more harm to small businesses such as Hanover Consulting LLC, which is owned and operated by one person.  Additionally; this proposed action does not meet any common sense standard of protecting the consumer.  The increase in the insurance minimum is not based on any incident which harmed any consumer; it is based on what larger businesses, with more employees, already have in place on their own, based on the owners business needs and does not need to be mandated on all businesses for the sake of just doing it because other businesses have done it.

I am completely against this regulatory action as the cost of this insurance will triple my costs for insurance and there is no sound basis for this increase.

CommentID: 57217