Statement of Charles M. Chamness
RE: Dodd-Frank Act/The Volcker Rule
“We are encouraged that the House Financial Services Subcommittees decided to hold a joint hearing this morning on the implementation of Section 619 of the Dodd-Frank Act, the so-called ‘Volcker Rule.’ Although only 11 pages in the legislation, the proposed rule by several agencies consisted of 300 pages and posed more than 1,300 questions on 400 different topics. Clearly this is a complex rule and therefore the utmost care ought to be taken throughout the implementation process.
“At the hearing it was reiterated that Dodd-Frank provides for a statutory exemption from the Volcker Rule for an insurance company acting on behalf of its general account. We believe this is appropriate to accommodate the unique nature of the property/casualty insurance industry, which is already subjected to state investment laws.
“While it is clear that the statutory intent was not to impact insurers, the proposed rulemaking demonstrates that there remain ambiguities and potential problems for members of our industry that are affiliated with an insured depository institution. We are working to provide comments on the Volcker Rule to the relevant agencies that will make clear that the insurance exemption should be widely construed and that with it in place, no new compliance structures be required by these insurers.”
Contact: Matt Brady