Date: September 12, 2016
Issue: Regulatory Reform
To: Mr. Robert de V. Frierson, Secretary, Board of Governors of the Federal Reserve System
Filing Type: Regulatory
Description: CCMC appreciates the opportunity to comment on the ANPR and commend the Federal Reserve in developing a thoughtful set of proposals for setting insurance capital standards for SLHC insurers and SIICs. However, CCMC reemphasizes the importance of the Federal Reserve to closely study the feedback received on the ANPR and develop multiple opportunities for notice and comment on future insurance capital rulemaking, given the novelty of these approaches and the significant impact the BBA or CA will have on SLHC insurers and SIICs and the American economy as a whole.