The action holds that regulators have misinterpreted the longstanding, essential role that reinsurance plays in a widely used workers’ compensation insuring format and has attempted to restrict the program in direct violation of section 531 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which precludes state insurance regulators from rewriting the terms of an out-of-state reinsurance contract. The Petition requests confirmation that Applied’s program is a valid captive reinsurance arrangement under New Jersey law and should be affirmed at a time when the format’s desirability among businesses is growing as a preferred risk transfer vehicle among Applied’s many New Jersey based clients and their employees. The Petition protects the clients of independent agents who have implemented the Applied programs as a sound, wise choice, an alternative to “off the shelf” policies in which the buyer has little influence on costs and little benefit from favorable outcomes.