2010s - NAIC - Insurance Commissioners - Snippets

  • Writing in our pages in February, former New York Insurance Superintendent Eric Dinallo said that "policyholders would have been protected" in the event of an AIG bankruptcy.
    • That seemed clear enough, but then Mr. Dinallo immediately added that an AIG bankruptcy "would have been bad for those same policyholders."
      • 2010 0202 - WSJ - What I Learned at the AIG Meltdown: State Insurance Regulation Wasn’t the Problem, by Eric Dinallo - [link]  
  • ⇒  So which was it?
    • State insurance regulators and industry analysts have since told us that Mr. Dinallo was wrong when he suggested that policyholders would have suffered.

2010 0910 - WSJ - 'Systemic Risk' Stonewall: Some bailout questions the Fed still hasn't answered  ---  [BonkNote]  ---  [link]

⇒  [Bonk: Who authored this article?]

  • (p17) - John Huff, NAIC / Missouri Insurance Commissioner
    • I agree with your conclusion that insurance is not included in the agency’s jurisdiction. [Bonk: Agency = CFPB) 
    • And to be fair to insurers, not all of those queries are complaints.
      • They are really an opportunity for us to have an education process.
    • Many times, they are more inquiries of how a product works, what did I buy?

2011 0728 and 1025 - GOV (House) - Insurance Oversight: Policy Implications for U.S. Consumers, Businesses and Jobs - Part 1 (2011 0728), Part 2 (2011 1025) - [PDF-285p, VIDEO-?] 

  • The analyst should have a firm understanding of the following risk classifications:
    • Reputational—Negative publicity, whether true or not, causes a decline in the customer base, costly litigation and/or revenue reductions.  (p37)
  • Procedure #17 guides the analyst through the assessment of any legal risk the insurer or group may have.
    • The analyst should ensure that a thorough understanding of the litigation and potential financial impact is documented.
    • Further, the analyst should communicate with the insurer’s management regarding the impact of reputation risk on continuing operations.
    • The analyst should understand the insurer’s plan to address the reputational risk and track the progress.  (p113)

2012 - NAIC - NAIC Financial Analysis Solvency Tools, Financial Analysis Handbook: Life/A&H/Fraternal Edition. 2012 Annual/2013 Quarterly - 398p

  • IAIS Question 83:
    • NAIC Response: Lapse risk is an example of an overall important category of policyholder behavior, which is an important risk in a number of products such as universal life and variable annuities.  (p11)

2015 0213 - IAIS - IAIS Insurance Capital Standard Public Consultation Document - Final NAIC comments – February 13, 2015 - 18p

  • The vast majority of the Department of Insurance's cases are brought in an administrative as opposed to judicial forum.
    • The Department's administrative authority to obtain remedies for individual consumers is more limited than that of a plaintiff in a UCL lawsuit with respect to monetary and injunctive relief.
  • Further, the existence of private plaintiffs' lawsuits helps forward the course of the law more effectively than would be the case if the only adjudications were those proceedings, largely administrative, initiated by the Commissioner.

2015 - LC - Brief of the State of California and the California Insurance  Commissioner as Amicus Curiae in Support of Plaintiffs, Walker vs Life Insurance Company of the Southwest. Case: 15-55809, 12/16/2015, ID: 9795445, DktEntry: 24, p27-28

  • 2017 0914, NAIC  - LIIIWG  - CC
    • Richard Wicka [Chair - WI] - said he had some concerns about Mr. Birnbaum’s revised introduction to the policy overview, where it says,
      • “If you have questions about this life insurance product, contact the state insurance department as well as your agent, broker, advisor, or contact a company representative.”
    • Richard Wicka ...explained that state insurance departments do not give advice and should not be a place where consumers call with questions about how a specific policy works.
    • Ms. Winer said that she understands wanting to help consumers, but state insurance departments do not do analysis or endorse particular products. She cautioned against equating state insurance departments with insurance agents relative to the process of shopping for insurance.
    • Mr. Reyna and Mr. Struk agreed with Mr. Wicka and Ms. Winer.
    • Ms. Lerner said she agrees as well but thinks consumers should be able to contact the state insurance department if they are not getting a satisfactory explanation.
    • Mr. Birnbaum said he is trying to provide an objective source where consumers could obtain unbiased information.
  • Complaints and inquiries related to life insurance and annuity products ... generally concerned consumer dissatisfaction with, or confusion regarding, universal life insurance policies.  (p90)

2018 - Wisconsin OCI - Wisconsin Insurance Report - 219p