Gary Hughes

ACLI
1982-, NAIC Proceedings – Design their own
199x – GOV – Gary Hughes – pre-GLB – mergers, ratings—Eric Dinallo-
Functional Regulation

We believe it is very important for the subcommittee, and other committees in Congress with jurisdiction over insurance, to have a sound understanding of how our industry operates…
… I would like to focus my remarks this morning on why the ACLI believes that the new Federal Insurance Office, FIO, is an extremely important new player in the insurance arena and why it is important for that office to be fully funded and staffed as quickly as possible. (p26)

— ACLI – Statement of Gary E. Hughes, Executive Vice President & General Counsel, American Council of Life Insurers – Part 1

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), Judy Biggert (R-IL) – [PDF-285p, VIDEO-?]

2014 0520 – GOV (House) – Legislative Proposals to Reform Domestic Insurance Policy, Randy Neugebauer (R-TX) — [BonkNote]

1983 – Gary E. Hughes and Paul J. Mason, “Universal Life Insurance: State and SEC Considerations,” in 1983 Conference on Life Insurance Company Products: Current Securities and Tax Issues 209 (American Law Institute-American Bar Association Course of Study Materials) – <WishList>
Gary E. Hughes, “Market Conduct: Short-Term Crisis or Long-Term Problem?”
- 1994 – Conference on Life Insurance Company Products: Current Securities, Tax, ERISA, and State Regulatory Issues 95, (American Bar Association-American Law Institute Course of Study Materials) – <WishList>
  - imms.com/members/3rdparty/AmerCol/regbook/regulatebibli.htm

1995 0606/08 – GOV – Financial Services Competitiveness Act of 1995, aka Financial Services Regulation – HR 1062
- [PDF-329p-GooglePlay, 0606-VIDEO-CSPAN] ->not on govinfo.org
20110728 and 1025 – GOV (House) – Insurance Oversight: Policy Implications for U.S. Consumers, Businesses and Jobs – Part 1 (2011 0728), Part 2 (2011 1025), Judy Biggert (R-IL) – [PDF-285p, VIDEO-?]
2014 0204 – GOV (House) – The Federal Insurance Office’s Report on Modernizing Insurance Regulation, Randy Neugebauer (R-TX) — [BonkNote]
- Mcraith, Leonardi, Ben Nelson, Gary Hughes
2014 0520 – GOV (House) – Legislative Proposals to Reform Domestic Insurance Policy, Randy Neugebauer (R-TX) — [BonkNote]
- question: would the case of Executive Life created a Systemic Risk?
2015 0325 – GOV (Senate) – FSOC Accountability Nonbank Designations, Richard Shelby (R-AL) — [BonkNote]

2015 0325 – GOV (Senate) – FSOC Accountability Nonbank Designations, Richard Shelby (R-AL) — [BonkNote]
- (p34) – 1:58:00 – Chairman SHELBY. Mr. Hughes, insurance products-you know this well-especially long-term insurance contracts such as life insurance, face a much different probability for runs and, thus, failure than one would typically fear with banks.
  - We have heard concerns that FSOC’s designation process treats these insurance contracts similar to bank assets, but they are different.
  - Would you discuss the likelihood of a so-called run on insurance products such as life insurance and what such a run would have to look like in order to cause systemic risk?
- Gary Hughes, ACLI – I know one of the dissents to one of the designations pointed out, quite correctly, that insurance regulators have the absolute authority to prevent people from turning in their policies, if that is warranted.
  - But I think the experience of the recent economic crisis is very telling in this respect.
  - In fact, it was just the opposite of a run.
  - The products were so desirable in terms of the guarantees they made that, notwithstanding the crisis, people were holding onto those products no matter what.

2015 0325 – GOV (Senate) – FSOC Accountability Nonbank Designations, Richard Shelby (R-AL) — [BonkNote]
- (p78) PREPARED STATEMENT OF GARY E. HUGHES – EXECUTIVE VICE PRESIDENT AND GENERAL COUNSEL, AMERICAN COUNCIL OF LIFE INSURERS – MARCH 25, 2015
- — Gary Hughes – ACLI since 1977 and has served as general counsel since 1998. (p26)
- p31 – Statement
- Third, as is the case with asset managers, we believe FSOC should be required to pursue an activities-based approach with respect to insurance, focusing on the specific activities and practices that may pose systemic risk.
- …there is not clarity on the specifics of why a company got designated.
  - ….very high degree of frustration among the companies….
  - p33 – [Companies] are not sure of the exact steps they could take if they wished to become de-designated.
- p34 – Well, I think you are absolutely correct that the dynamics of a insurance company are much different than those of a commercial bank, certainly in terms of the types of products and the likelihood of money going out the door [Run on the Bank].
- p41 – Yeah, I heard the same thing when the Secretary <Lew> testified, and I guess I am sitting here scratching my head a little bit as p41to why a goal of this entire process should not be to have a system where there are not systemically important institutions.
- With all due respect to the members of FSOC, there is not a whole lot of deep insurance expertise on the Council.
- p78 – PREPARED STATEMENT OF GARY E. HUGHES – EXECUTIVE VICE PRESIDENT AND GENERAL COUNSEL, AMERICAN COUNCIL OF LIFE INSURERS – MARCH 25, 2015