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Matt Brady

Matt Brady
Public Affairs Director
Federal Affairs

Telephone: 202.580.6742

Lisa Floreancig

Lisa Floreancig
Public Affairs Director
State Affairs

Telephone: 317.876.4246

NAMIC on Front Lines of Dodd-Frank Implementation

Yesterday marked the deadline for public comment on two different proposed rulemakings by regulatory agencies tasked with the implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act. NAMIC submitted comments on the potential prohibitions and restrictions on proprietary trading by financial institutions – commonly known as the “Volcker Rule” – as well as on a rule aimed at clarifying that any mutual insurance holding company would be treated as an “insurer” under applicable state law in the event of an insolvency.

NAMIC has long been engaged in efforts to ensure that the Volcker Rule was not broadly construed to inappropriately prohibit insurers from proprietary trading. NAMIC submitted comments on Friday to the various agencies that are responsible for implementing the Volcker Rule, including the Federal Reserve, the Office of the Comptroller of the Currency, the Security and Exchange Commission, and the Federal Deposit Insurance Corporation.

NAMIC has long argued that property/casualty insurance is unique within the financial services sector, and during the legislative debate Congress recognized this fact and provided an exemption from the Volcker Rule for insurers trading on behalf of their general or separate accounts. As it was clearly the intent of lawmakers to not needlessly sweep the insurance industry into this new regulatory regime, NAMIC’s comments urged the various regulatory agencies to construe this exemption as broadly as possible when constructing the final rule.

The FDIC also had a recently published request for public comment on its proposed rule that would ensure that the liquidation and rehabilitation of mutual insurance holding companies be conducted in the same manner as an insurance company. In the submitted comments, NAMIC expressed an appreciation that the FDIC recognized the need to ensure proper treatment of mutual insurance holding companies and offered our support for the proposed rule.

NAMIC has long stressed the need for vigilance and oversight over the regulatory implementation process of Dodd-Frank. Constant engagement with the agencies is one of the key ways that we can protect our industry from the threat of federal overreach. We will continue to fight at every level and use every avenue so that the property/casualty insurance industry can continue to flourish in the United States.

Direct questions to NAMIC Federal Affairs Director Jonathan Bergner.

Posted: Tuesday, February 14, 2012 9:34:30 AM. Modified: Tuesday, February 14, 2012 2:50:21 PM.

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