The Dodd-Frank Act requires the involvement of three persons with insurance expertise in its implementation:
- The Director of the Federal Insurance Office;
- A voting member of the Financial Stability Oversight Council (FSOC) with insurance expertise (to be appointed by the President and confirmed by the Senate); and
- A non-voting member of the FSOC, to be a state insurance commissioner.
Michael McRaith, Director of the Illinois Division of Insurance, was recently appointed in March as Director of the Federal Insurance Office, but he will not assume his post until June 1, 2011. The NAIC appointed the current Missouri Insurance Director, John Huff, to be the nonvoting member of the FSOC, but his effectiveness has been questioned since the Treasury Department has taken the position that he represents only the State of Missouri, and has blocked him from sharing information with other insurance regulators. The third slot has yet to be filled.
The result: only modest insurance expertise is being brought to bear in the implementation of Dodd-Frank until at least June 1, 2011.