According to Becker's comments to Politico, Heartland already has some clients — which it cannot disclose yet — and Nelson and the Heartland team have been spending the past couple of months setting up the venture, around the time he was hired by the NAIC.

Nelson accepted the NAIC position in mid-January and will make a salary of close to $1 million under a two-year renewable contract. Also in January, Nelson accepted a senior advisory position with Agenda, a national public affairs firm with offices in Washington. Agenda is a firm focused on winning through something called “new advocacy,” according to its website.

In addition, the University of Nebraska at Omaha announced the appointment of an educational partnership between Nelson and the UNO Department of Political Science. Nelson will become the department's “Politician-in-Residence.” Part of the Nelson's responsibilities will include team-teaching an upper-division course each semester, UNO announced in February.

“Serving as the chief executive officer for the National Association of Insurance Commissioners is my primary job — and I am passionately committed to our responsibilities of helping state insurance regulators protect consumers and support their regulatory oversight of insurance companies and producers. Throughout my career, I have juggled numerous roles. My teaching responsibilities and advisory positions with other boards, firms and educational institutions will neither interfere nor influence my job as NAIC CEO,” Nelson said in a statement.

Nelson has access to state regulatory information and strategy representing the state governmental agencies he represents as NAIC leader. The business firms he is partnering with will lobby on behalf of interests before branches of government.

The well-funded and experienced former senator did divest his Berkshire Hathaway (insurance company) stock before taking the helm of the NAIC, he said earlier at a press conference. According to open secrets.com, Neslon's PAC Contribution was 86 percent business — much from insurance companies — 4 percent labor and 11 percent ideological/single issue in the 2007-12 election cycle. The top industries contributing to the campaign committee and leadership total PAC are insurance by almost a full length, followed by lobbyists, pharmaceuticals and lawyers/law firms.

The NAIC began courting Nelson at least as early as the fall, when his name came up on a short list of candidates under consideration. He was considered a top choice, according to sources.

Two years is the time former U.S. senators are barred from lobbying after leaving Congress, which Nelson effectively did at the end of the year.

But he can do advisory or advocacy work in the interim, work which his new positions suggest. Back in January, Nelson said being CEO would be his primary function, Nelson said then that the timing of the two hiring announcements – the NAIC and Agenda — was unfortunate, coming as they did within 24 hours of each other.

“We are fortunate to have the expertise and experience of Sen. Ben Nelson at the helm of our organization. During the CEO hiring process, we had a thorough discussion with him about our expectations for the position. At that time, the NAIC's leadership team acknowledged there would be other opportunities he wished to pursue concurrently,” stated Jim Donelon, NAIC president and Louisiana insurance commissioner.

“We are confident these will not interfere with his primary responsibility of serving as our CEO,” Donelon added.

Nelson's predecessor, Terri Vaughan, travelled a great deal for international regulatory and supervisory work, which is likely to fall to other NAIC state regulators, specifically immediate past president Commissioner Kevin McCarty of Florida and Commissioner Tom Leonardi of Connecticut.

The lifting of the international load may afford Nelson more time for his portfolio of positions, some have suggested.

Nelson will speak publicly at the National Conference of Insurance Legislators (NCOIL) event Friday in Washington, his first public conference speech on insurance regulation since becoming NAIC CEO. He has spoken to other groups, but they were closed events.