Archives for Insurance

Letter to IAIS regarding insurance capital standards consultation (10/19/16)

Date: October 19, 2016

Issue: Capital Standards; Insurance

To: International Association of Insurance Supervisors

Filing Type: Comment letter

Description: The Chamber made several recommendations aimed at making IAIS’ work more effective, including recommendations designed to make an insurance capital standard (ICS) complementary to and adaptable for multiple jurisdictions, to ensure that it promotes capital formation for economic growth. Accordingly, the Chamber urges IAIS to undertake careful deliberation, avoid completion of an ICS on any artificial timetable, and most importantly develop an ICS that is principle based, providing the necessary flexibility to accommodate different jurisdictions.

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Letter to the Federal Reserve regarding Enhanced Prudential Standards for Systemically Important Insurance Companies (8/17/16)

Date: August 17, 2016

Issue: Systemic Risk; Insurance

To: Federal Reserve

Filing Type: Regulatory

Description: The Chamber emphasizes the importance of designing properly calibrated enhanced prudential standards for SIICs that are appropriate for the business of insurance and do not damage the capital markets. The Dodd-Frank Act requires the Federal Reserve to properly recognize the differences among bank holding companies and other nonbank financial companies designated as SIFIs by the FSOC. We believe that several of the requirements listed in the Proposal, particularly with respect to liquidity risk management, fail to make this distinction.

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Proposed Guidance on Deposit Advance Products,” and “Proposed Guidance on Deposit Advance Products; Withdrawal of Proposed Guidance on Deposit-Related Consumer Credit Products

Date: May 30, 2013

Issue: Corporate Governance

To: Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency

Filing Type: Regulatory

Description: CCMC submitted a letter to the FDIC and OCC requesting that the agencies withdraw the new proposed guidance relating to deposit advance products. We believe that this guidance circumvents the legal requirements of promulgating a consumer protection rule exemplifying our concerns about regulators using the supervision process to write “rules”.

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Federal Housing Finance Agency Notice Regarding Lender Placed Insurance: Terms and Conditions

Date: May 28, 2013

Issue: Insurance

To: Federal Housing Finance Agency

Filing Type: Regulatory

Description: The CCMC supports a pro-competitive approach to insurance regulation that leads to a uniform and efficient supervisory system with respect to product design, market conduct, and other oversight functions. Accordingly, we believe that the FHFA should not take any actions that may conflict with or overlap prevailing insurance law.

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