The Federal Insurance Office has finally issued the report required by the Dodd-Frank Act assessing the regulation of insurance in the United States. The report includes recommendations for the federal government to consider a limited role in helping to make the regulation of insurance more uniform. With respect to reinsurance, the report contains the following recommendations:
· States should develop a uniform and transparent solvency oversight regime for the transfer of risk to reinsurance captives (see page 32 of the report); and
· To afford nationally uniform treatment of reinsurers, FIO recommends that Treasury and the United States Trade Representative pursue a covered agreement for reinsurance collateral requirements based on the National Association of Insurance Commissioners Credit for Reinsurance Model Law and Regulation (see page 37 of the report). This would apparently be an international level agreement to introduce uniformity throughout the states, which under Dodd-Frank would pre-empt state laws.
This post written by Rollie Goss.
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