• Moratorium
  • Stay
  • Contractual 
  • State
  • Courts
  • I question the argument that insurance organizations should have weaker bank/thrift holding company protections because their insurance policy holders can’t easily cash out if they make bad investments.

2014 0310 - Letter - Sheila C. Bair to Sherrod Brown

  • Senate Committee on Banking, Housing and Urban Affairs Subcommittee on Financial Institutions and Consumer Protection
  • Re: Subcommittee Hearing: “Finding the Right Capital Regulation for Insurers”
  • The very nature of insurance significantly reduces the potential of a run-on-the-bank scenario for property/casualty, health and most life insurance products.
  • For those limited products sold by insurers that could be subject to some level of run risk, mitigating factors exist such as policy loan limitations, surrender/withdrawal penalties, and additional taxes.

--  Kevin M. McCarty - NAIC Testimony- Commissioner, Florida Office of Insurance Regulation and President of the National Association of Insurance Commissioners

2012 1129 - GOV - Examining the Impact of the Proposed Rules To Implement Basel III Capital Standards 

  • [PDF - 439p, Video?]
  • Committee on Financial Services - Joint Hearing Before the Subcommittee on Financial Institutions and Consumer Credit and the Subcommittee on Insurance, Housing and Community Opportunity
  • The IAA notes that the exercise of any power to implement a stay on surrenders may have a cost to the reputation of the insurance industry and may result in conflicting positions between the prudential and conduct supervisors if they are separate.  (Page 180 of 264)

2018 - IAIS - Compiled Comments on Holistic Framework for
Systemic Risk in the Insurance Sector 14-Nov-18 to 30-Jan-19 - 264p