Centers for Better Insurance

CBI makes available unbiased analysis and insights concerning key public policy and regulatory issues facing the insurance industry.

CBI makes available unbiased analysis and insights concerning key public policy and regulatory issues facing the insurance industry.

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72

issues

#72・

Federal Insurance Office's Climate-Related Data Call

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 for major disruptions of private insurance coverage …

 
#71・

Climate Risk, Parametric Insurance, and Dodd-Frank

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. These comments focus on the rapidly unfolding incursion into the CFTC’s juri…

 
#70・

Cyberterrorism Daunting Challenge for TRIA

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 cyber-related losses.Question…

 
#69・

Two Decades of the Terrorism Risk Insurance Program

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 SummaryAfter nea…

 
#68・

TRIA Program Falls Short on NBCR

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 the risk of nuclear, biological, chemical, and ra…

 
#67・

Time to Update Property & Casualty Exemption from Money Laundering Rules

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 …

 
#66・

A Framework for Defining a Role for Insurers in “Uninsurable” Risks: Insights from COVID-19

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 …

#65・

FinCEN Turns Blind Eye to Captive Insurance Reporting Loophole

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…

#64・

CBI Files Comments on Terrorism Risk Insurance Program Data Call for Captive Insurers

Every year the Federal Insurance Office (FIO), as administrator of the Terrorism Risk Insurance Program, requires participating insurers to respond to a detailed data call.Among other changes, FIO recently announced its intention to improve the data it collec…

 
#63・

Pandemic Risk Insurance Act of 2021 – The Numbers Don’t Add Up

Representative Carolyn Maloney (NY) recently announced the reintroduction of the Pandemic Risk Insurance Act. The first version of this proposal (PRIA 2020), introduced in May 2020, largely borrowed from the Terrorism Risk Insurance Act (TRIA). A short summar…

#62・

Latest Iteration of Pandemic Insurance Program Runs Headlong into Dodd-Frank

Representative Carolyn Maloney (NY) recently announced the reintroduction of the Pandemic Risk Insurance Act. The first version of this proposal, introduced in May 2020, largely borrowed from the Terrorism Risk Insurance Act. This latest iteration boldly rede…

 
#61・

Louisiana Citizens Property Insurance Company’s Resources to Pay Hurricane Ida Claims

Louisiana Citizens Property Insurance Company is the state’s residual market providing property insurance to homeowners and businesses that have been unable to procure insurance in the private market. Louisiana Citizens came out of the 2005 hurricane season n…

 
#60・

CBI Files Comments on Washington State’s Captive Insurance Registration Program

In the United States, insurance is largely regulated at the state level. In most cases, property and casualty insurance is provided by “admitted insurers” which are insurance companies licensed to do business in the state in which the policyholder resides or …

 
#59・

11th Circuit Affirms Dismissal of COVID-19 Business Interruption Claim

During the Spring of 2020, the Governor of Georgia ordered residents and visitors to “shelter in place” where they lived. People could leave their homes to attend to essential services, including necessary medical care. The Centers for Disease Control (CDC) i…

#58・

Centers for Better Insurance - Issue #58

Executive SummaryCalifornia’s Commissioner of Insurance convened a Working Group to explore the role innovative insurance solutions may be able to play in helping communities and families manage the risk of climate change. One of the Working Group’s recommend…

 
#57・

The Regulatory Environment for Parametric Insurance

Parametric insurance proposals have emerged as potential solutions for managing a growing list of cutting-edge risks including pandemic, climate change, and even urban crime. For example, Chubb has proposed a $750 billion Pandemic Business Interruption Progra…

#56・

Pricing the Pandemic Risk in Workers Compensation Insurance

Each year NCCI revises its jurisdiction-specific loss cost filings by incorporating claims data from the last experience period. In plain-speak, NCCI updates the amount of expected claim payouts for the next year based on updated claims loss data from prior y…

#55・

U.S. Treasury Okay with $0 Terrorism Premium Disclosures (For Now)

The Terrorism Risk Insurance Act requires participating insurers to provide “clear and conspicuous disclosure to the policyholder of the premium charged for insured losses covered by the Program.”[1] An insurer that fails to disclose the terrorism premium cha…

#54・

Insights from Latest TRIA Regulations

On June 9, U.S. Treasury released updated regulations reflecting the extension of the Terrorism Risk Insurance Program through 2027. While many of the changes are straight-forward, Treasury’s reactions to public comments offer a few valuable insights.Economic…

#53・

First Decision from a Federal Appellate Court Favors Insurers

Earlier today the United States Court of Appeals for the 8th Circuit released the first federal appellate decision considering a business interruption claim arising out of COVID-19.In this case, the policyholder is an oral surgery practice with four offices i…