Section 313(p) of Title 31 of the United States Code, as codified by the Dodd-Frank Wall Street Reform and Consumer Protection Act, requires the Federal Insurance, or FIO, to conduct a study on how to modernize and improve the system of insurance regulation in the United States. The study must be submitted to Congress not later than 18 months after the date of the Dodd-Frank Act’s enactment. To assist the FIO in conducting the study and formulating its recommendations, the FIO has issued a  request for comment.

Commenters are invited to submit views on:

  • Systemic risk regulation with respect to insurance;
  • Capital standards and the relationship between capital allocation and liabilities, including standards relating to liquidity and duration risk;
  • Consumer protection for insurance products and practices, including gaps in State regulation and access by traditionally underserved communities and consumers, minorities, and low and moderate-income persons to affordable insurance products;
  • The degree of national uniformity of State insurance regulation, including the identification of, and methods for assessing, excessive, duplicative or outdated insurance regulation or regulatory licensing process;
  • The regulation of insurance companies and affiliates on a consolidated basis;
  • International coordination of insurance regulation;
  • The costs and benefits of potential Federal regulation of insurance across various lines of insurance (except health insurance);
  • The feasibility of regulating only certain lines of insurance at the Federal level, while leaving other lines of insurance to be regulated at the State level;
  • The ability of any potential Federal regulation or Federal regulators to eliminate or minimize regulatory arbitrage;
  • The impact that developments in the regulation of insurance in foreign jurisdictions might have on the potential Federal regulation of insurance;
  • The ability of any potential Federal regulation or Federal regulator to provide robust consumer protection for policyholders; and
  • The potential consequences of subjecting insurance companies to a Federal resolution authority.  

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