Roy Woodall

  • 1966-1967 - Kentucky Insurance Commissioner
  • 1981 - NALU
  • 1989-?? - Kentucky Insurance Commissioner
  • 1990 - National Association of Life Companies (NALC) 
  • 1993-1999 - NALC merged with ACLI
  • 2000-? - attorney with the Washington, D.C. office of the Atlanta law firm of Morris, Manning & Martin. 
  • 2002-2011 - senior insurance analyst for the Department of Treasury. 
  • 2011 0630 - Lexology - Roy Woodall nominated as voting member of FSOC, Locke Lord - [link]
  • 2011-?- FSOC Insurance Expert, Financial Stability Oversight Council
  • 2018 -  bipartisanpolicy.org/press-release/roy-woodall-jr-joins-the-bipartisan-policy-center-as-a-fellow/
  •  Roy Woodall:  It is important to identify particular activities in order to encourage appropriate and further action that could lessen any company-specific threat to U.S. financial stability.
  • *Paraphrasing what one insurance thought leader once told me: “We should not tolerate any insurance company posing a threat to our financial system – pinpoint what makes them systemically risky and let’s fix them.”3
    • 3Therese M. Vaughan, Ph.D., Dean of the College of Business and Public Administration, Drake University, and former Iowa Insurance Commissioner, President and CEO of the National Association of Insurance Commissioners, International Association of Insurance Supervisors Executive Committee member, and Chair of the Joint Forum.>

2014 12 - Woodall / Hamm / FSOC - re: MetLife Designation - Views of the Council’s Independent Member Having Insurance Expertise - 13p

  • 1998 0205 - WSJ - How Insurance Firms Beat Back An Effort for Stricter Controls, By Scot J. Paltrow - [link]
    • On May 22, 1996, the nation's leading insurance regulators traveled to Nick's Fish Market near Chicago to dine privately with executives of two major insurance companies.
      • On the menu was an urgent question: Just how forceful would these regulators be in policing the $750 billion industry? The answer, which the participants agreed to before dessert had arrived, would quietly but dramatically alter the course of insurance regulation in America.
    • Insurers say they won significant concessions.
      • At a recent NAIC budget hearing in Kansas City, S. Roy Woodall Jr. of the American Council of Life Insurers announced: "Our companies are very well-pleased."
      • Says J. Robert Hunter, former Texas commissioner and now head of insurance for the Consumer Federation of America: "The boycotters won."
  • 1981-1, NAIC Proceedings 
    • (p591) - Life Insurance Disclosure (C3) Task Force - LIDS - Statement of S. Roy Woodall, Jr., Executive Vice President, The National Association of Life Companies
    • (p610-613) - Comments on Behalf of the National Association of Life Companies, Presented by: S. Roy Woodall, Jr., Executive Vice-President
  • Model Life Insurance Solicitation Regulation
  • Management of our companies know as well as anyone could that the consumer is best served by a simple method to assist in selection of a product.
    • Complexity is of no help and can serve only to confuse the consumer.
  • Based upon these cost figures and a comprehensive review of your proposal, it was the unanimous opinion of the directors of NALC that it was time for us to say "Wait just a minute! This is insanity!"
  • The NALC was founded in 1955 as a direct result of a proposal being considered by the NAIC at that time, and supported by many large companies, that would have outlawed all "specialty" policies and  thereby put many smaller and more innovative companies out of business.
  • The criticism your report levels at the simplified net cost method centers on the fact that it does not reflect the time value of money.
    • This has never been disputed.
    • But when the consumer is so informed of the defects in any simplified method, perhaps that is all that you as regulators can or should do without risking the confusion of more complicated systems that leave the consumer worse off than he is today.

--  Comments on Behalf of the National Association of Life Companies (NALC) Presented by S. Roy Woodall, Jr., Executive Vice-President (p610)

1981-1, NAIC Proceedings

  • (p12) - Roy WOODALL, member, Financial Stability Oversight Council (FSOC) - Speaking from a retro type position, too, I think it emphasizes what he said, the fact that what triggered it was activities going on at financial products in the United States.
    • [Bonk: He = Ben Nelson, NAIC CEO]

2013 0613 - GOV (House) - The Impact of International Regulatory Standards on the Competitiveness on US Insurers, Randy Neugebauer (R-TX) - [PDF-164p. VIDEO-YouTube]

  • 2011 0630 - Lexology - Roy Woodall nominated as voting member of FSOC, Locke Lord - [link]
  • 2015 1208 - GOV (House) - Oversight of the Financial Stability Oversight Council - [PDF-146p
    • Mr. WOODALL. No, but I think you should put in the record—
    • Mr. GREEN. Okay. That should go in the records. I am going to take it from that comment, Mr. Woodall, that you joined the rest of your colleagues and let the record should show there is unanimous consent that you don’t have to be an insurance expert to sit in judgment of an insurance company.
    • *Mr. WOODALL. I am not sure what an insurance expert is.
    • Mr. GREEN. I am glad you said it, because some people have claimed that you are, so my assumption is that you don’t know what you are.
    • Mr. WOODALL. That is because it was put in the title of DoddFrank.
  • 2014 12 - Woodall / Hamm /  FSOC - re: MetLife Designation - Views of the Council’s Independent Member Having Insurance Expertise - 13p
    • Woodall (FSOC Member with Insurance Expertise) - p1-6
    • Hamm (NAIC- ND) - p7-13
  • (p8) - 18Dating as far back as 1991, Roy Woodall – the former independent member of the Financial Stability Oversight Counsel with Insurance Expertise – warned that “national regulation of insurance is the culmination of a state supported regulatory scheme whereby a select few insurance regulators are able to engineer methods by which the NAIC can usurp legislative and judicial powers of the states by expending existing NAIC regulatory vehicles to impose illegal and unconstitutional regulatory jurisdiction and requirements upon the insurance industry in all fifty states – without the benefits of any state or federal oversight or legislative action.”

    • S. Roy Woodall, Jr., The NAIC and “National Regulation,” Editorial, National Association of Life Companies Newsletter (1991). - <WishList>

2018 - LR - Is U.S. Insurance Regulation Unconstitutional?, by Daniel Schwarcz - 67p

  • Only one voting member of the FSOC, Roy Woodall Jr., dissented from the FSOC’s final determination.29
  • Woodall contended that the FSOC’s asset liquidation transmission channel analysis relied on “implausible, contrived scenarios as well as failures to appreciate fundamental aspects of insurance and annuity products, and, importantly, State insurance  regulation.”30
  • Woodall argued that, although it is easy to presume a hypothetical total insolvency and designate MetLife under the First Determination Standard, the FSOC should have analyzed MetLife’s specific activities and explained how they contribute to systemic risk.31
  • Furthermore, Woodall argued that MetLife’s 2013 designation, by the Financial Stability Board (“FSB”), as a “global systemically important financial institution” (“G-SIFI”) was a driving force behind the FSOC’s designation.32
  • In essence, Woodall concluded that the FSOC was merely falling in line with the FSB, and that the FSOC never really critically and independently analyzed whether MetLife poses a threat to U.S. financial stability.33

2015 - LR - Review of Banking and Financial Law 34(2), 435-442. - 8p

  • 1966-2. NAIC Proceedings
    • (ix) - Woodall, S. Roy, Jr., Kentucky
      • Appointed to Resolutions Committee ---- 285
      • Elected Vice Chairman of Examinations Committee ----- 627
      • Introduced ------ 279
      • NAIC-FTC Resolution Subcom. Report ----- 606
        • (p285) - The Resolutions Committee shall be: Chairman, Frank Burch of Maryland, Dudley Guglielmo of Louisiana, Elmer V. Omholt of Montana, Walter G. Korlann of Oregon, Bob Haase of Wisconsin, and S. Roy Woodall, Jr., of Kentucky. 

  • 1966-2. NAIC Proceedings
    • (p605) - Advertising of Insurance (H) Committee
    • The Honorable S. Roy Woodall, Jr., of Kentucky presented the report of the NAIC-FTC Resolution (H1) Subcommittee for consideration by the parent Committee.
    • (p607) - Report of the Results Obtained from Questionnaire Forwarded to Individual Members of the NAIC by the (H1) Subcommittee - To Study NAIC-FTC Resolution
      • insurers or both?  ANSWERS:
        • 27 States answered that complaints were primarily involving LIFE INSURANCE CARRIERS.
        • 7 States answered that complaints were primarily involving LIFE and ACCIDENT and HEALTH carriers.
        • 6 States answered that complaints were primarily involving ACCIDENT AND HEALTH carriers ONLY.
        • 5 States answered that complaints were involving BOTH life and property companies.
        • 1 State answered that complaints involved LIFE, PROPERTY and ACCIDENT AND HEALTH COMPANIES.
        • 7 States answered that they had received NO complaints.
    • NAIC-FTC Resolution adopted in 1963
  •  - [PDF-35p, VIDEO-CSPAN (Title: Financial Agencies Nominations),
    • 12:15 - Ben Nelson (D-Nebraska) - Speaking for Roy Woodall for the nomination.
    • 23:15 - Roy Woodall (FSOC Insurance Expert Nominee)
    • Opening Statement of S. Roy Woodall
      • ....the National Association of Life Companies, which was merged in 1993 with the American Council of Life Insurers (ACLI).  Following the merger I served the ACLI as Managing Director/Issues and Chief Counsel, State Relations until my retirement in 1999.  
  • 1991 0613 - GOV - Insurance Competitive Pricing Act of 1991 - [PDF-237p - GooglePlay. No Video]
      • Roy Woodall - S. ROY WOODALL, JR., PRESIDENT, NATIONAL ASSOCIATION OF LIFE COS., ON BEHALF OF THE ALLIANCE OF AMERICAN INSURERS, AMERICAN COUNCIL OF LIFE INSURANCE <ACLI>, HEALTH INSURANCE ASSOCIATION OF AMERICA, NATIONAL ASSOCIATION OF INDEPENDENT INSURERS, NATIONAL ASSOCIATION OF MUTUAL INSURANCE COS., AND THE COALITION AGAINST FEDERAL REGULATION OF INSURANCE, ACCOMPANIED BY PATRICK J. CROWE, VICE PRESIDENT AND CHIEF ACTUARY, KENTUCKY FARM BUREAU MUTUAL INSURANCE CO.
        • McCarran-Ferguson,  Capital and Surplus Requirements, Banks vs Life Insurance,

  • 1981-1, NAIC Proceedings - Task Force on Life Insurance Disclosure System (LIDS)  ---  [BonkNote]
    • NALU Comments on Behalf of the National Association of Life Companies Presented by: S. Roy Woodall, Jr., Executive Vice-President ……...610
  • 1985-1, NAIC Proceedings - (562-563) - Universal Life Task Force Advisory Committee - NAIC
    • Non-members Invitees:

  • 2000 - SOA - Enhancing Actuarial Input at the Federal Level on Life Insurance Issues, Society of Actuaries - 20p
  • 2002 - CRS - Optional Federal Chartering for Insurers: Major Interest Groups, S. Roy Woodall, Jr.,  Insurance Consultant (Government and Finance Division) - 6p
  •  - [PDF-35p, VIDEO-CSPAN (Title: Financial Agencies Nominations)
  • 2013 0613 - GOV (House) - The Impact of International Regulatory Standards on the Competitiveness on US Insurers - [PDF-164p
  • 2014 12 - Woodall / Hamm /  FSOC - re: MetLife Designation - Views of the Council’s Independent Member Having Insurance Expertise - 13p
  • 2015 0325 - GOV - FSOC Accountability Nonbank Designations CHRG-114shrg95892
    • [PDF-165p,  VIDEO-CSPAN]
    • (p127) - Roy Woodall and John Huff dissents on Prudential 
    • (p140) - Roy Woodall and Adam Hamm dissents on MetLife
  • 2015 1208 - GOV (House) - Oversight of the Financial Stability Oversight Council - [PDF-146p
  • 2018 0406 - 2018 Early Career Scholars Medal Conference Welcome and Keynote, American Law Institute - [VIDEO-YouTube]
    • Mentioned - Kyle Logue, Tom Baker,
    • Present - Michael McRaith, Daniel Schwarcz, Roy Woodall,  Baird Webel
    • Martin Grace, Patricia McCoy, Ted Nickel, Tom Sullivan
    • Maybe Present - Birny Birnbaum-? (29:00-maroon shirt)
    • 05:15 - Daniel Schwarcz:
      • Working across Silos - Legal, Academics, real world,  
      • KeyNote Speaker - Roy Woodall
      • Panel 1 - State v Fed
        • 2008 Financial Crisis - AIG - Traditional v Non-Traditional Activities, Financial Guarantors, Credit Default Swaps (AIG) - AIG - Securities Lending, Run Risks, Options, Withdrawals, Systemic Risk - spreads across state Federal Government would have best the best scope, resources and incentives for the problem. - Then the question is how. When do insurance companies become systemically risky. SIFI - Entities or Activities - 
      • Panel 2 - Rate Regulation
        • Historical viewpoint -public utility
        • overregulation and under regulation
        • antitrust, price fixing
        • Discrimination, pricing, too much competition. 
      • 19:00 - Daniel Schwarcz intro of Roy Woodall
        • Intellectual thought leader, disagrees with Woodall sometimes.
        • MetLife, Amicus Brief
        • We are particularly lucky to have Roy here at this moment.  As of a week ago he is a private citizen.  Which means that he can say whatever he wants and no one is going to hold it against him or censor him in any way. So I am looking forward to hearing the true, uncensored Roy Woodall with the gloves off. And with that I will turn it over to Roy.
      • 22:00 - Roy Woodall -
        • Stimulating Conversation,
          • NAIC Folder - references Dave, Brenda, Bill
            • Brenda Cude - ?
        • Grandfather - Equitable of New York, Dad - Agency in Kentucky
        • ref: Terri Vaughan
        • 4 commissioners in 4 years
        • 1967 - Appointed Commissioner
        • Troubled Companies - was the Rehabilitor for 3 companies
        • NALC  - Atlanta based moved to Washingotn in 18
          • 1985 - NALC moved to Washington 
          • 1992 - NALC merged with ACLI 
        • 1986 Tax Reform
          • Stock Mutual Fight - went for years. Time cured it when most of the Mutuals became Stock
        • retired, 911 Attack - TRIA, 
        • Went to work for CRS - Congressional Research Service...Flood, Terrorism...  Optional Federal Charter
          • Role of CRS - Issues Memoranda and reports to brief Congress.  It was always private, only for Congress. A Bill recently passed. to make it public... website in the next year.
            • 2002 - CRS - Optional Federal Chartering for Insurers: Major Interest Groups, by S. Roy Woodall, Jr., Insurance Consultant, Government and Finance Division, Congressional Research Service - 6p
        • 29:00 - OFR I think is in trouble. Employee base has shrunk.  It was set up to help FSOC....the member of FSOC... to do research for them.
          • ..My own experience, the OFR didn't have which I can. I finally got a person who knew systems and and data...worked for the NAIC and go him on contract for a while. Then pressure ended that.
          • This lead to Treasury.  When the Terrorism bill passed, it was implemented by Treasury.
          • Stayed at Treasury for 8 years, 
          • pull this together.
          • Dodd-Frank - Tom Galas....-?
            • Insurance was overlooked in the beginning....... FIO....State.... the very last minute... came up with an Insurance Expert - Terrible Title - 3 sentences.  It's been a real ride.  
            • Ended with 3 staff. - Technically Treasury Employees.
            • Michael McRaith
            • International Part bothered me
              • Republicans - FSB, G20
              • , IAIS, 
              • FSB and G20 - Not Statutory Creatures, not set up by Congress,  
              • IMF and WorldBank
            • 2014 09 - CIGI - Reforming The Global Architecture Of Financial Regulation The G20, The IMF And The FSB By Malcolm D. Knight, Paper No. 42 - 28p
            • Global SIFI's 
            • Tom Sullivan - Treasury, people at Treasury didn't understand insurance 
            • Next Crisis - pressure to have Federal oversight 
            • Report - BiPartisan Council - Improving US Insurance Regulation  - Justin Shar....
              • Gut Wrenching
          • CRS, FSOC,