2011 1016 - Regulations.gov - FIO / DOT - Public Input on the Report to Congress on How To Modernize and Improve the System of Insurance Regulation in the United States

  • 147 Comments
    • NAIFA - 2011 1216 - On the domestic front, FIO has a dual focus – on both the federal government and the States. - regulations.gov/comment/TREAS-DO-2011-0010-0097
      • NAIFA believes it is critical that FIO use its role as the insurance expert in the federal regulatory structure to
        • (a) educate all levels of the federal government – from the Treasury Department, to the Securities and Exchange Commission (SEC), to the Department of Labor (DOL) – about the insurance industry, how it works, and how it interacts with other financial sectors; 
    • IIRPC - regulations.gov/comment/TREAS-DO-2011-0010-0070
      • The Commission has an operational track record of adopting Uniform Standards that have generally raised the bar for product content requirements, specificity and consumer disclosures.
      • The result is comprehensive content requirements that every product filed through the Commission must comply with (no desk drawer rules or exceptions) and that contain very strong protections for consumers.
      • These protections range from a Flesch readability score requirement of 50 to only allowing voluntary (not mandatory) post-dispute arbitration to generally prohibiting no-assignment provisions.