The NAIC’s Reinsurance Task Force in late March exposed draft federal legislation titled the “Reinsurance Regulatory Modernization Act of 2009” as one of the vehicles to implement the NAIC’s Reinsurance Regulatory Modernization Framework. The exposure draft drew many comments critical of the proposed bill. Some comments strongly opposed the basic regulatory principles set forth in the proposed bill. A number of comments criticized the proposed bill as being unconstitutional. The Reinsurance Association of America submitted one of the strongest oppositions to the proposed bill, asserting among other things that reliance on individual states to adopt NAIC model laws as a means to implement the objective of single-state regulation is “unnecessarily cumbersome and unworkable.” At the NAIC’s summer meeting, the Task Force placed this proposal on hold pending the receipt of a legal opinion regarding the proposed bill’s constitutionality.

All of the comments submitted to the NAIC on the proposed bill can be found on the NAIC’s website. A “Special Focus” article discussing these comments in greater detail can be found on Jorden Burt’s reinsurance blog at