Gary Hughes

  • ACLI
  • 1982-, NAIC Proceedings - Design their own
  • 199x - GOV - Gary Hughes - pre-GLB - mergers, ratings---Eric Dinallo-
  • Functional Regulation
  • 2014 0520 - GOV (House) - Legislative Proposals to Reform Domestic Insurance Policy - [PDF-128p, VIDEO-youtube] 
  • Gary E. Hughes, "Market Conduct: Short-Term Crisis or Long-Term Problem?" 
  • 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
  • 2011 0728 - GOV - Insurance Oversight: Policy Implications for U.S. Consumers, Businesses and Jobs
  • 2014 0204 - The Federal Insurance Office’s Report on Modernizing
  • 2014 0520 - GOV - Legislative Proposals to Reform Domestic Insurance Policy
    • [PDF-128p, VIDEO-youtube]
    • Hughes, Schwarz, Ross, Wisconsin Guy - I'm very productive
    • question: would the case of Executive Life created a Systemic Risk?
  • 2015 0325 - GOV - FSOC Accountability Nonbank Designations CHRG-114shrg95892 - [PDF-165p,  VIDEO]
  • 2015 0325 - GOV (Senate) - FSOC Accountability Nonbank Designations
    • [PDF-165p,  VIDEO-CSPAN -todo]
    • (p34) - 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? 
  • 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.....
  • Again, we have expressed our concerns to the NAIC and State regulators, but again we have been advised that they are not in a position to give us substantial help.

-- Gary Hughes (ACLI)

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-?]

  • 2015 0325 - GOV - FSOC Accountability Nonbank Designations CHRG-114shrg95892 - [PDF-165p,  VIDEO]
    • (p78) PREPARED STATEMENT OF GARY E. HUGHES - EXECUTIVE VICE PRESIDENT AND GENERAL COUNSEL, AMERICAN COUNCIL OF LIFE INSURERS - MARCH 25, 2015
    • (p127) - Roy Woodall and John Huff dissents on Prudential
    • (p140) - Roy Woodall and Adam Hamm dissents on MetLife

--  Gary Hughes - ACLI since 1977 and has served as general counsel since 1998. (p26)

Statement (p31)

  • 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....
    • <Companies> are not sure of the exact steps they could take if they wished to become de-designated. (p33)
  • 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>. (p34)
  • 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 to why a goal of this entire process should not be to have a system where there are not systemically important institutions. (p41)
  • With all due respect to the members of FSOC, there is not a whole lot of deep insurance expertise on the Council. (p41)
  • PREPARED STATEMENT OF GARY E. HUGHES - EXECUTIVE VICE PRESIDENT AND GENERAL COUNSEL, AMERICAN COUNCIL OF LIFE INSURERS - MARCH 25, 2015 (p78)