To support this study and Report, FIO has consulted extensively with various stakeholders. On October 17, 2011, FIO published a notice in the Federal Register asking the public to submit comments on the considerations and factors listed in Title V:
• Systemic risk regulation with respect to insurance.
• Capital standards and the relationship between capital allocation and liabilities, including standards relating to liquidity and duration risk.
• Consumer protection for insurance products and practices, including gaps in State regulation.
• The degree of national uniformity of State insurance regulation.
• The regulation of insurance companies and affiliates on a consolidated basis.
• International coordination of insurance regulation. In addition, Title V states that the Report must also examine:12
• The costs and benefits of potential Federal regulation of insurance across various lines of insurance (except health insurance).
• The feasibility of regulating only certain lines of insurance at the Federal level, while leaving other lines of insurance to be regulated at the State level.
• The ability of any potential Federal regulation or Federal regulators to eliminate or minimize regulatory arbitrage.
• The impact that developments in the regulation of insurance in foreign jurisdictions might have on the potential Federal regulation of insurance.
• The ability of any potential Federal regulation or Federal regulator to provide robust consumer protection for policyholders.
• The potential consequences of subjecting companies to a Federal resolution authority, including the effects of any Federal resolution authority -
o On the operation of State insurance guaranty fund systems, including the loss of guaranty fund coverage if an insurance company is subject to a Federal resolution authority;
o On policyholder protection, including the loss of the priority status of policyholder claims over other unsecured general creditor claims;
11 31 U.S.C. § 313(p).
12 31 U.S.C. § 313(p)(3).
Federal Insurance Office, U.S. Department of The Treasury
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How To Modernize And Improve The System Of Insurance Regulation In The United States
o In the case of life insurance companies, on the loss of the special status of separate account assets and separate account liabilities; and
o On the international competitiveness of insurance companies.
• Such other factors as the Director determines necessary or appropriate, consistent with the principles set forth in the prior paragraph.

FIO received nearly 150 written comments, which are available online at treasury.gov/initiatives/fio.

In November and December 2011, FIO had an initial round of consultations with nearly 40 different insurance sector participants, ranging from insurance regulators, to insurers, to consumer advocates.

On December 9, 2011, FIO hosted a conference at the Treasury where participants representing the interests of consumers, insurers and reinsurers, producers, and academics discussed regulatory modernization

• 2013 - FIO - How To Modernize And Improve The System Of Insurance Regulation In The United States - 71p