ACLI to NAIC

1970s

  • 1976-1, NAIC Proceedings – 1976 0909 – ACLI –  RE: Proposed Changes to the NAIC Model Variable Life Insurance Regulation – p623-
  • 1979-2, NAIC Proceedings – 1978 0613 – Letter – ACLI to NAIC (Life Insurance (C3) Subcommittee) – re: NAIC Proposed Regulation on Replacement of Life Insurance – p400-401 – 3p
  • 1979-2, NAIC Proceedings
    • To:  The NAIC Life Insurance (C3) Cost Disclosure Task Force
    • From:  The American Council Of Life Insurance (ACLI)
    • Date:  May 25, 1979
    • Re:  The Report of the Industry Advisory Committee on Policy Lapsation

1980s

  • 1980 0130 – Letter – ACLI to GOV (Senator Howard Cannon (D-NV), Chairman – American Council of Life Insurance, on The FTC Staff’s Responses to Criticisms of the Report on Life Insurance Cost Disclosure – (p130-136)
    • 1979 0710 and 1017 – GOV (Senate) – FTC Study of Life Insurance Cost Disclosure, Howard Cannon (D-NV)   —  [BonkNote]  —  [PDF-592p] 
  • 1982-1, NAIC Proceedings – 1981 0831 – ACLI – Statement of the American Council of Life Insurance Before the NASAA NAIC Joint Regulatory Insurance Products Study Committee – 10p
  • 1982-1, NAIC Proceedings – 1981 1215 – Letter – ACLI to NAIC – Cost Disclosure for Universal Life, by the Special Task Force of the ACLI Cost Disclosure Subcommittee to NAIC Task Force on Life Insurance Cost Disclosure – 4p

 

  • 1982-2, NAIC Proceedings – (p524-526) – 1982 0608 – ACLI – Statement on Behalf of the American Council of Life Insurance to the NAIC (A) Committee’s Manipulation, Lapsation, Dividend Practices and Annuity Disclosure Task Force
  • 1983-1, NAIC Proceedings – 1982 1129 – ACLI to NAIC (LCDTF-A) – Statement on Behalf of the American Council Of Life Insurance To The NAIC (A) Committee’s Life Cost Disclosure Task Force – p523
  • 1985-1B. NAIC Proceedings – ACLI to NAIC – Correspondence from the American Council Of Life Insurance (ACLI) concerning proposals for the Taxation of Life insurance companies. (Attachment One-B) –  18 Questions – p3.
  • 1985-2, NAIC Proceedings – ACLI to NAIC (LHATF-A) – 3. Correspondence from the American Council Of Life Insurance concerning proposals for the taxation of life insurance companies. (Attachment One-B)
    • 1985 0612 – Report of the Life & Health Actuarial Task Force to the Technical Services (EX5) Subcommittee
  • 1988-2, NAIC Proceedings, 1988 0613 – ACLI to NAIC (MCSTF-EX3) – Statement on Behalf of the American Council of Life Insurance to the NAIC Market Conduct Surveillance (EX3) Task Force (Attachment 2) – 3p

1990s

2000s

  • 2008 1111 – ACLI to NAIC – Re Reserve and Capital Relief for Certain Life Insurance Policies and Variable Annuity Contracts – 19p

2010s

  • 2017 1115 – Letter – ACLI to NAIC – LIBGWG, Redlined Draft – Life Insurance Buyer’s Guide – 12p
    • Unlike a term policy, which can end after a specified number of years, permanent life insurance will continue to the policy’s maturity age so long as premiums are paid.
      • (Note that this isn’t exactly accurate for UL, where policies can continue as long as the cash value is sufficient to pay the policy charges. We may want to make that distinction. )  –  [Bonk: ACLI Wording and Strikethrough]
      • [Bonk: Without Strikethrough = ]
        • (Note that this isn’t exactly accurate for UL, where policies can continue as long as the cash value is sufficient to pay the policy charges. We may want to make that distinction.)
    • Member Comment: I think the last sentence is too broad of a statement.
      • If the free look period ends, the amount you get back on the 11th day is far different than the amount you would get back 5 years down the road.
  • 2019 1115 – ACLI to NAIC – LIIIWG – RE: Revisions Considered for Life Insurance Policy & Narrative Summaries, Life Insurance Illustrations Issues (A) Working Group –  8p

2000s

  • 2020 0821 – Letter – ACLI to NAIC (MCASWG – Market Conduct Annual Statement Blanks Working Group (D)) – re: RE: Accelerated Underwriting & TPAs/MGAs – 3p
    • TPAs and MGAs – We also question the usefulness of collecting information concerning MGAs and TPAs.
    • Insurers are ultimately responsible for the actions of these entities, who can provide a wide variety of services.
  • 2020 1104 – ACLI to NAIC – LIAC / LIIIWG – RE: Life Insurance Illustrations Issues (A) Working Group – 2p
  • 2021 0805 – ACLI to NAIC – LIAC / LIIIWG – RE: Life Insurance Illustrations Issues (A) Working Group – 3p
  • https://content.naic.org/sites/default/files/national_meeting/A%20Cmte%20materials.pdf

NAIC – Walker v. LSW – Life Insurance Company of the Southwest

  • (p29-30) – Dr. Patrick Brockett
    • Q When you were offering that statement, you don’t actually know what the NAIC regulations require or preclude in terms of what could be disclosed; do you?
    • MR. BROSNAHAN: Objection, Your Honor, as to what the NAIC —
    • THE COURT: Overruled. 
    • THE WITNESS: I don’t know what the NAIC says in …

2014 0415 – DOC 808 – Trial Transcript – Walker v LSW – 229p

  • (p97-98) – Matthew DeSantos – LSW’s Senior Vice-President of Distribution and Business Development (himself a former insurance agent) – DOC 792 p27
    • A Sure. The National Association of Insurance Commissioners created a model regulation designed to ensure that customers are not misled.
    • Q Then can you read the next slide. We will pull it up here.
    • A But life insurance illustrations are complex and still need further explanation.
    • A sound understanding of illustrations and how they are constructed is important in every sale.
    • Q Is this training material designed to provide that sound understanding?
    • A Yes.

2014 0423 – DOC 812 – Trial Transcript – Day 10 – Walker v LSW – 194p

Q: Should the Insurance Industry Be Looked At?

  • It is hard to fix a system that has not been analyzed.  (p14) 

—  J. Robert Hunter (CFA)

2003 0506 – GOV (House) – Increasing the Effectiveness of State Consumer Protection – [PDF-123p, VIDEO-?] 

  • My staff has conducted a major investigation of these issues.
    • I must say today that I was shocked when I saw its findings.  (p1)

—  Senator Metzenbaum

1979 – GOV (Senate) – Cost Disclosure in Life Insurance – Senator Metzenbaum – [PDF-279p-GooglePlay]

  • 2009 0924 – GOV (Senate) – Systemic Risk and Resolution Issues / Experts’ Perspectives on Systemic Risk and Resolution Issues –  [PDF-128p, VIDEO-CSPAN] 
    • Paul Volcker – “…..insurance companies, which I would say parenthetically I hope better regulatory systems will be developed, maybe not as part of this legislation but next year.”  (p7)
    • Paul Volcker – “I would hope this committee would look at the question of national charters for insurance companies and bring them under-at least the big ones-under a framework so that something like AIG with similar problems can’t arise in the future.”  (p19)
  • But nowhere has there been a serious, full dress attempt to re-define the modern American insurance transaction as a sui generis matter.
  • Perhaps the job is too big, or too dull.
    • [Bonk: sui generis ~ unique]

1950 – LR -The Special Nature of the Insurance Contract: A Few Suggestion for Further Study, by Franklin M. Schultz – 15p

  • 1939 0412 – SEC to President (Franklin D. Roosevelt) – Re: Insurance Investigation –  3p
  • 2009 0924 – GOV (Senate) – Experts’ Perspectives on Systemic Risk and Resolution Issues, (CSPAN) Systemic Risk and Resolution Issues, Barney Frank (D-MA) -[PDF-128p, VIDEO-CSPAN]
    • (p7) – Paul Volcker (former Chairman of the Board of Governors of the Federal Reserve System) – “…..insurance companies, which I would say parenthetically I hope better regulatory systems will be developed, maybe not as part of this legislation but next year.” 
  • 2009 0114 – COP – Hearing – Modernizing America’s Financial Regulatory Structure, Congressional Oversight Panel
    • [PDF-180p,  VIDEO-CSPAN]
    • (p72) – Statement of Joel Seligman, President, University of Rochester  
      • Second, the scope of any systematic review of financial regulation should be comprehensive.
        • This not only means that obvious areas of omission today, such as credit default swaps and hedge funds, need to be part of the analysis but also means, for example, our historic system of state insurance regulation should be re-examined as well as current securities laws exemptions for areas, including municipal securities.
        • The fact that the Federal Government provided over $100 billion to insurance giant AIG alone suggests that insurance regulation is no longer purely a state matter. 

Receivership

  • UILA – Uniform Insurers Liquidation Act
  • 1940 – LR – Legislation: The Uniform Insurers Liquidation Act – 12p
    • Although there has been a vast improvement in national bankruptcy legislation, with the passage of the Chandler Act in 1938,2 so that the receivership device has been abandoned to a large degree by most corporations, insurance companies have been excluded from the Act.3
      • Consequently, they must still rely upon receivership and local statutory substitutes for insolvency proceedings
  • 2021 – NAIC – Legislative Priorities – 1p
  • Support Legislation to Help Protect Policyholders During an Insurance Receivership
    • Current law provides no deadline to the federal government for filing claims in an insurance receivership, causing proceedings to drag on for years and reducing recoveries for insurance consumers.
    • Congress should support NAIC proposed legislation that would require the federal government to file claims it may have against insolvent insurance companies within a specified time consistent with bankruptcy proceedings.
  • Privide State Insurance Regulators a Vote on the Financial Stability Oversight Council (FSOC) (H.R. 3099)
    • The insurance sector is the only financial services sector whose primary regulator is not a voting member of the FSOC.
    • The Primary Regulators of Insurance Vote Act (H.R. 3099) would grant state regulators full participation on FSOC by allowing them to vote.
  • Oppose Preemption of State Insurance Data Privacy and Data Security Standards
    • Federal data privacy and security legislation should acknowledge the state insurance regulatory framework and not undermine state laws and regulations to protect the best interests of insurance consumers.

Q: Are Life Insurance Policies Being Sold For a Death Benefit or an Investment Vehicle?

  • Current
    • Be Your Own Bank
    • LIRP – Life Insurance Retirement Plan
    • Curtis Ray
    • Dout Andrew
    • Tom Hegna
    • etc
  •  MetLife
    • 1990s – Nurses 50 /50
    •  FSOC
  • I didn’t buy a Life Insurance Policy – Horton
  • College Funding
  • Looks like an Annuity
    • SOA
    • 1994 0213 – The Washington Post – Beware of Life Insurance Firms Selling Policies as Annuities, By Jane Bryant Quinn – [link]
  • 2010’s – Walker vs. LSW – 
  • 2025 – LC – Kyle Busch vs. Pacific Life Insurance Company  —  [BonkNote]
  • (p232) – Q:  And why did you decide at that time that you were ready to apply for the policy?
  • A: Because I was satisfied that this would meet my retirement needs, receiving $93,000 a year for tax-free retirement, turning that money that I had targeted for my nest egg into this $93,000-a-year income.
    • It sounded like a good product for me.

2014 0416 – DOC 809 – Trial Transcript – Walker v LSW – 236p

  • While we recognize that there are meaningful differences within life insurance products and within annuity products, we also observe as a general matter that policies that provide coverage against death are likely to be viewed by the policyholder as serving primarily a protection purpose rather than primarily a savings purposes. 

— 239. Northwestern Mutual 

2021 06 – IAIS – Liquidity Metrics Phase 1 – Resolution of Comments_(PUBLIC) – 106p

  • Ed FEIGHAN (D-OH):  Well, if insurance is viewed as an investment by the majority of Americans, that’s the result of its portrayal over several decades by the industry.
  • Robert HUNSTAD (ACLI):  I can’t respond to that.  (p301)

1984 0411, 0503, 0510, 0628, 0913 – GOV (House) – Competition in the Insurance Industry – [PDF-759p-GooglePlay]

⇒  Robert Hunstand, senior vice president and actuary, Minnesota Mutual Life Insurance Co., on behalf of the American Council of Life Insurance, ACLI

Q: What is the NAIC – National Association of Insurance Commissioners?

  • “I do not think it is too much to ask that the $80 million trade association define who it is and what it can do…but of course tough questions draw criticism,” Royce said.

2013 1004 – ThinkAdvisor – Rep. Royce again questions NAIC’s authority – [Ed Royce (R-CA)], By Arthur D. Postal – [link]

  • It is unprecedented that the Federal Government would give such power to a private trade association-I repeat, a private trade association-or to what NAIC immediate past resident Walter Bell of Alabama in an April 9, 2007, letter called: ”a 501(c)(3) nonprofit corporation with voluntary membership and not a State government entity.”
  • This NAIC president went on to say that: ”When individual insurance commissioners gather as members of the NAIC, they are not considered a governmental entity or a public body as defined by the various open meeting laws, but rather are a private group.
  • As an organization, the NAIC does not have any regulatory authority.”  (p14)

—  Brian P. Kennedy, Representative, Rhode Island House of Representatives, and President, National Conference of Insurance Legislators (NCOIL)

2008 0610 – GOV (House) – H.R. 5840, The Insurance Information Act of 2008, Paul Kanjorski (D-PA)  — [BonkNote]

  • James Schacht (IL):
  • 1. NAIC History and Purpose
    • For 110 years, the NAIC’s original objects of promoting uniformity were carried forward and remained virtually unchanged.
    • With the adoption of a new Constitution in 1981, however, the NAIC’s purposes were restated in the form of the following three summary statements:
      1. Maintenance and improvement of state regulation of insurance in a responsive and efficient manner.
      2. Reliability of the insurance institution as to financial solidity and guarantee against loss.
      3. Fair, just and equitable treatment of policyholders andclaimants.
    • (See NAIC Proceedings 1981 Vol. I pp. viii and xx.) (p174)
  • 2. NAIC As A Legal Entity
    • Until it changed its Bylaws in June 1989, the NAIC considered itself a quasi-governmental, non-Section 501(cX3) organization.
    • Moreover, in the past, the Internal Revenue Service has consistently viewed the NAIC as an instrumentality of state government for the purpose of federal tax exemptions under FICA and federal excise and unemployment taxes.
    • Likewise, in the past, the states of New York and Wisconsin did not recognize the NAIC as a 501(cX3) organization for unemployment tax purposes.
    • The only recorded reason for the 1989 Bylaw changes was that they were “technical changes we need for IRS … clarification relative to the taxation status of some of our activities.” (NAIC Proceedings 1989 Vol. II p. 10.)

1995-1, NAIC Proceedings

Resolution Authority

  • 2008 0710 – GOV (House) – Systemic Risk and the Financial Markets, CSPAN – Transformation of Financial Markets
    • [PDF-86p, VIDEO-CSPAN] – <mp3, mp4>
    • Paulson, Bernanke
    • 1:17:30 – Paulson – need resolutions authority like FDIC
  • The lack of an appropriate regulatory regime and resolution authority for large nonbank financial institutions contributed to this crisis and will continue to constrain our capacity to address future crises.  (p7)

— Timothy F. Geithner, Secretary, U.S Department of the Treasury 

2009 0324 – GOV (House) – Oversight of the Federal Government’s Intervention at American International Group – [PDF-91p, VIDEO-CSPAN] – <mp3, mp4>

  • Geithner and Bernanke Testimony on AIG Bonuses 
  • House – Committee on Financial Services
  • Fed Window
  • Richard Scott, FCIC MP3 Interview
  • 2014 04 – Book – Modernizing Insurance Regulation – John H. Biggs, Matthew P. Richardson – 304p
  • 2020 0825 – FSB – Key Attributes Assessment Methodology for the Insurance Sector – 72p
  • NAIC
    • GUARANTY FUNDS
    • NAIC Insurer Receivership Model Act
  • 2009 0924 – GOV (Senate) – Systemic Risk and Resolution Issues / Experts’ Perspectives on Systemic Risk and Resolution Issues – [PDF-128p,  VIDEO-CSPAN]
    • (p7) – Paul Volcker – “…..insurance companies, which I would say parenthetically I hope better regulatory systems will be developed, maybe not as part of this legislation but next year.”  
    • (p19) – Paul Volcker – “I would hope this committee would look at the question of national charters for insurance companies and bring them under-at least the big ones-under a framework so that something like AIG with similar problems can’t arise in the future.”  
    • (p49) – Ed PERLMUTTER (D-CO) – How do we resolve insurance companies?
      • Do you know?
      • We liquidate them through the insurance commissioner.  
  • (p25) – Senator Bob CORKER (R-TN) –  Well, it may not-I think this whole issue of authority is pretty incredible, and I think all of us realize that the Fed nor anyone else has the authority not only to deal with AIG but Citigroup or Bank-there is nobody.
    • I mean, I think that is an amazing thing that for some reason only hits my alarm bell, nobody else’s.
    • But there is no entity in our country that has the ability to deal with an AIG, a Citigroup, a Bank of America, anybody.
    • I find that pretty incredible. 

2009 0305 – GOV (Senate) – American International Group: Examining What Went Wrong, Government Intervention, And Implications for Future Regulation – CSPAN- Government Intervention and Regulation of AIG – [PDF-72p]

AIG – Securities Lending – Insurance Regulators

  • (18) – Baxter: When you look at what happened with AIG’s securities borrowing program, in a nutshell, AIG’s insurance companies held Treasury securities, which they lent out for cash.
    • Then they used that cash to buy MBS, knowing that in the future they would have to sell the MBS to then redeem their Treasuries.
      • No supervisor stepped up and said, “Wait a minute. You’re making a play for yield, you’re putting yourself at risk of being illiquid,” which is exactly what happened.
    • But we didn’t feel free to discuss this supervisory failure.
      • We felt freer to talk about Financial Products.
    • If you’re a federal official and it looks like you’re being critical of the state official, that can be a bad position to be in. 

2018 1120 – Lessons Learned Oral History Project Interview: Thomas Baxter – 19p

  • (p9) – Susan Voss: And perhaps the greatest single source of concern for the insurance regulators during the financial crisis was securities lending activities by AIG. 
    • Commissioner, Iowa Insurance Division, and President, National Association of Insurance Commissioners (NAIC), on behalf of NAIC

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-?]

  • Eric Dinallo – New York
  • Terri Vaughan – CEO NAIC / Iowa
  • Michael Mcraith – Illinois
    • Insurance and Systemic Risk – [PDF-181p, VIDEO-CSPAN]
  • Sandy Praeger
    • Kansas Insurance Commissioner
    • 2008 – NAIC President
  • Doug Slape – Texas – AIG Lead Regulator
  • content.naic.org/sites/default/files/capital-markets-primer-securities-lending.pdf
    • While this insurer is most known for significant losses that occurred within its credit default swap (CDS) program, the onset of an overwhelming demand for returned cash by its securities lending counterparties compounded the insurer’s liquidity constraints.
  • 1:08-cv-05722 – American International Group, Inc. ERISA Litigation II
    • 2012 – Document 137 – Consolidated Second Amended Complaint – 230p
  • 2008 1010 – WSJ – AIG Increases Borrowings While Racing to Sell Assets, By Liam Pleven, Carrick Mollenkamp and Craig Karmin –  Oct. 10, 2008 – [link]
    • Securities Lending
    • 2009 0305 – GOV – Perspectives on Systemic Risk
  • As early as July 2006, we were engaged in discussions about the securities lending program with AIG.
  • In 2007, we began working with the company to start winding down the program.

2010 0526 – COP – Testimony – Michael Moriarty, Deputy Superintendent of the New York State Insurance Department – 7p

  • In December 2006, AIG’s lead state insurance regulator for the company’s domestic life insurers (“lead life insurance regulator”) began a routine examination of AIG in coordination with several other state regulators.19
    • During the examination, the state regulators identified issues related to the company’s securities lending program.
    • Prior to mid-2007, state regulators had not identified losses in the securities lending program, and the lead life insurance regulator had reviewed the program without major concerns.

2011 09 – GAO – Review of Federal Reserve System Financial Assistance to American International Group, Inc – 152p

  • 2008 0721 – Circular Letter No. 16 (2008) – [link]
  • TO: All Authorized Insurers, RE: Securities Lending
  • STATUTORY REFERENCE: N.Y. Insurance Law §§ 201, 301, 1409 and 1411
    • It has come to the Department’s attention that some insurers engaged in securities lending activity have experienced significant losses in the last six to twelve months.
      • Specifically, cash received as collateral was reinvested into securities whose value has significantly declined.
      • As we see increased volumes in securities lending activity, we are concerned that some insurers may not be maintaining adequate collateral and effectively managing the risks associated with the securities lending function.

Universal Life – Premium – Consumer Advocate

  • The personalized information in the Policy Overview is the premium for the policy – based on information known to the producer or insurer at the time and subject to change based on additional or revised information – and that information can be provided prior to purchase.
  • If an insurer can produce an illustration for a complex, investment type life insurance product prior to the consumer purchase, it is clearly possible for an insurer to provide the premium for a policy prior to purchase.

NAIC – Testimony

1970s

  • 1973 / 1974 – GOV (Senate) – The Life Insurance Industry, Senator Hart (D-MI) – 4 Parts — [BonkNote]
    • 1973 0221 and 0222 – Part 2 of 4 – [PDF-733p-GooglePlay]
      • 1973-2,  NAIC Proceedings – GOV (Senate) – Testimony – NAIC – Stanley DuRose (Wisconsin Insurance Commissioner) – p107-131 – 25p
      • 1972 0221 (Typo – 1973, not 1972 – Testiomony – NAIC – TILI – Stanley Durose – 64p
      • 1972 0221 – Testimony – NAIC – TILI – Stanley Durose – 56p

1980s

  • 1981 0811 – Testimony – NAIC – National Association of Insurance Commissioners Task Force on Cost Disclosure – HG 8755 N38 C6 1981 –  https://naic.soutronglobal.net/Portal/Public/en-GB/RecordView/Index/5517 – <WishList>
  • 1986 0618 – Testimony – NAIC – Insurance company solvency [draft], dward Muhl (MD) and John Washburn (IL) – 53p
  • 1986 0619 – Testiomony – NAIC – Reliability of the Institution of Insurance as to Financial Solidity and Solvency, Edward Muhl (MD) – 20p
  • 1986 – Testiomony – NAIC – Reliability of the Institution of Insurance as to Financial Solidity and Solvency – 8p
  • 1987 – Testimony – NAIC – Banks and Insurance – James P. Corcoran (NY) – 13p
  • 1988 0420 – Testimony – NAIC – Earl Pomeroy (ND) – 10p
    • Long-Term Care Insurance

1990s

  • 1991 0227 – Testimony – NAIC – Insurance Solvency Regulation – John Donaho, (MD) – 17p
    • 1991 0227, 0507, 0509 and 0523 – GOV (House) – Insurance Company Solvency, (CSPAN) Insurance Company Insolvencies, Cardiss Collins (D-IL)  —  [BonkNote]
  • 1991 0409 – Testimony – NAIC – Model Law Process,  Earl Pomeroy (ND) – Testimony – 99p   
  • 1991 0717 and 0724 – GOV (House) – Life Insurance Solvency Issues, (CSPAN) – Insurance Insolvencies, (NAIC) – The Impact of Junk Bonds, Real Estate and Mortgages on the Life Insurance Industry – Cardiss Collins (D-IL)  —   [BonkNote]   
    • 1991 0717 – Testimony of Terence Lennon (New York Department of Insurance) – 17p
  • 1991 0729 – GOV (House) – Regulation of Insurance Companies and the Role of The National Association of Insurance Commissioners – [PDF-286p-GooglePlay]
    • (p13) –  William McCartney, Director of Insurance, State of Nebraska and Vice President, National Association of Insurance Commissioners (NAIC)
      • We are seeing a real crisis in confidence:
      • That, in my mind, is probably the worst thing that could happen.   
      • There is not a company in the country that can stand runs that Commissioner Weaver was talking about, where people ask for $1 billion in policy loans and surrenders in a 2-week period. 
  • 1998 0625 – Testimony – NAIC – HR 10 and Financial Modernization – George Nichols, III (KY) – 10p
  • 1999 0505 – Testimony – NAIC – HR 10 and Financial Services Modernization – George Nichols, III (KY) – 24p

2000s

  • 2007 0307- Testimony – NAIC – The McCarran-Ferguson Act and Antitrust Immunity: Good for Consumers? – Susan Voss (IA) – 7p

  • 2008 1007 – Testimony – NAIC – The Causes and Effects of the AIG Bailout  – Eric Dinallo (NY) – 8p

  • 2009 0318 – Testimony – NAIC – American International Group’s Impact on the Global Economy: Before, During, and After Federal Intervention – Joel Ario (PA)  – 12p
  • Insurance and Systemic Risk – – 16p

2010s

  • 2011 1116 – Testimony – NAIC – Insurance Oversight and Legislative Proposals – Joseph Torti, III (RI) – 26p
  • 2015 0325 – Testimony – NAIC – FSOC NonBank Designations – Richard Shelby (R-AL) and Sherrod Brown (D-OH) – 3p
  • 2014 12 – re: FSOC SIFI Designation of MetLife, Woodall / Hamm – Views of the Council’s Independent Member Having Insurance Expertise  —  [BonkNote] —  13p
  • 2015 0929 – Testimony – NAIC – Domestic Insurance Regulatory Issues – John Huff (MO) – 12p
  • 2019 – Testimony – NAIC – Testimony – Eric Cioppa, (ME) – 7p
    • 2019 0912 – GOV (Senate) – Developments in Global Insurance Regulatory and Supervisory Forums – [PDF-109p,  VIDEO-Senate Page]