The Financial Stability Oversight Council has been receiving comments on the implementation of the systemic risk provisions of the Dodd-Frank Act. Many property and casualty companies and trade associations for both property and casualty and life insurers (e.g., the Property Casualty Insurers Association of America and the American Council of Life Insurers) have submitted comments contending that companies in that industry should not be subject to such regulation. The Reinsurance Association of America has submitted a comment supporting those submissions, and arguing that the reinsurance industry does not present a potential for systemic risk to the economy, and hence should be exempted from such regulation. The RAA bases its argument, in part, on analyses from the Group of 30 and the International Association of Insurance Supervisors, which have been the subject of posts to this blog. The popular wisdom seems to be that the regulators, being concerned of being under inclusive, are erring on the side of being over inclusive in this definition effort, which will make any industry-wide exemption difficult to obtain.