CBI responds to FIO’s request for public comment. A pdf of CBI’s comments is available here → link. The Centers for Better Insurance, LLC (CBI) is an independent organization committed to enhancing the value the insurance industry delivers to all stakeholders (including policyholders, employees, and society at large). CBI does…

CBI proposes a more focused approach to measure availability and affordability of insurance in the context of climate related catastrophes. The President’s Executive Order 14030 (Climate Related Financial Risk) directs the Secretary of the Treasury to “direct the Federal Insurance Office to … assess, in consultation with States, the potential…

Response to CFTC’s Request for Information on Climate Products Here is link to the comments I submitted today to the Commodity Futures Trading Commission (CFTC) in response to its request for information about climate related financial products. …

Complex determinations and conflicts of interest present serious risks to program effectiveness. These comments respond to Treasury’s Notice appearing at 87 FR 18473 (March 30, 2022) seeking comments in advance of its 2022 Report on the Effectiveness of the Terrorism Risk Insurance Program with a focus on issues presented by…

Opportunity to Evaluate Effectiveness of Program Administration These comments respond to Treasury’s Notice appearing at 87 FR 18473 (March 30, 2022) seeking comments in advance of its 2022 Report on the Effectiveness of the Terrorism Risk Insurance Program with a focus on program administration. Executive Summary After nearly two decades…

Treasury should advise Congress that TRIA is ineffective in helping small and medium businesses manage nuclear, biological, chemical, and radiological terrorism risks. These comments respond to Treasury’s Notice appearing at 87 FR 18473 (March 30, 2022) seeking comments in advance of its 2022 Report on the Effectiveness of the Terrorism…

FinCEN’s BSA Exemption should Modernize and Reflect Captive Insurance Risks Treasury’s Financial Crime Enforcement Network (FinCEN) recently sought information and comment on how to improve existing Bank Secrecy Act regulations and guidance. Bank Secrecy Act regulations provide that “each insurance company shall develop and implement a written anti-money laundering program…

Howard Kunreuther and I recently collaborated to develop a decision-making framework for evaluating strategies for dealing with the impacts of risks traditionally considered uninsurable — such as COVID-19. This article is available here from the NAIC’s Center for Insurance Policy & Research. While many have viewed insurability as a binary…

Corporate Transparency Act Exempts Member of the IRS Dirty Dozen List The Corporate Transparency Act (CTA) “requir[es] entities to submit beneficial ownership and company applicant information to FinCEN [Treasury’s Financial Crime Enforcement Network] … to help prevent and combat money laundering, terrorist financing, tax fraud, and other illicit activity.” …