Baribeau Flashcards
Insurers were likely included in the scope of Dodd Frank because the “Financial Products” division of the insurer AIG was heavily involved in the crisis. List 2 reasons that this may have been inappropriate
- This division was a banking division which was unrelated to AIGs insurance operations.
- When the crisis started, the Financial Products division was actually already under federal regulation by the Treasurys Office of Thrift Supervision (OTS)
List some impacts of the Dodd Frank act
- provided the Federal Reserve System (Fed) limited regulatory authority
- established the Federal Insurance Office (FIO), part of the US Treasury, to monitor the insurance industry
- allows the Fed & FIO to influence/ be influenced by the International Association of Insurance Supervisers (IAIS)
2 types of insurers that the Fed is authorized to regulate
- Systematically Important Financial Institutions (SIFIs): institutions that could cause a national systemic economic disruption if they fail.
- Insurance holding companies that own banks or thrifts
Reasons that the classification of insurers as SIFIs turned out to be quite controversial
- Designation results in significant additional regulation
- The business models between insurers & banks are very different
- It has been acknowledged that insurers made minimal contribution to the crisis
- The criteria to be classified as a SIFI is unclear: there have been no guidelines published that would allow insurers to get off or stay off the list
List some functions of the Federal Insurance Office
- aggregates insurance information from various sources
- monitors the insurance industry:
- Identifies insurance activities that could contribute to a financial systemic crisis
- Develops federal policy about nationally or internationally important insurance issues
- Consults state government on insurance matters
- monitors the availability and affordability of insurance
- work with the US Trade Representative to negotiate covered agreements with foreign regulators
Requirements of insurers regulated by the Fed
- Develop living wills (resolution plans) to be used if there is a bankruptcy
- Meet liquidity requirements
- Undergo stress testing
- Meet capital standards
Lost some of the most significant effects on P&C “actuaries”
- Dual regulation: there could be regulations impacting accounting and solvency standards that could result in an inconsistent & non-level playing field
- Dual regulation: due to the additional federal regulatory body, regulations would be overly restrictive & expensive to follow
- Increase in capital requirements
- Standardization requirements drive commoditization
- significant increase in compliance costs for insurers that own banks
List issues if the international standards do not reflect the current state based regulation
There could be:
* Less product innovation
* Higher costs
* Few options for consumers
* Insurers could be forced to consolidate, resulting in fewer insurance options; and larger insurers that are more likely to become systemically important.