The National Association of Insurance Commissioners takes a subdued, fact-based approach in its comments on how federal agencies should provide consolidated regulation of insurance companies which operate savings and loans.
The comment letter responds to specific questions asked by federal regulators regarding separate accounts, the general treatment of insurance underwriting, surplus notes and policy loans.
The letter also offers comparison information on the substantive differences between generally accepted accounting principles and the statutory accounting principles used by state regulators to evaluate the financial health of insurance companies.
The letter said the specific information might be useful to federal regulators in gaining a "better understanding the relative conservative nature of SAP" and the risk-based capital process used by state regulators to evaluate the health of insurance companies.
"We hope these comments and the appended information will be helpful as further consideration is given to more suitable standards for insurance enterprises with thrifts and banking entities," the letter says.
It adds that the NAIC's "technical experts stand ready to answer additional questions in person or by telephone."
The letter was signed by Therese Vaughn, NAIC retiring CEO, and Kevin McCarty, Florida insurance commissioner and current NAIC president.
"We are confident once a better understanding of the existing financial standards required of such insurers is reached, more progress can be made toward developing a regulatory approach that captures the complete risk profile of an insurance enterprise," the letter said.
