WASHINGTON — The Property Casualty Insurers Association of America (PCI) submitted comments to the National Association Insurance Commissioners (NAIC) Group Capital Calculation (E) Working Group on several aspects of the Group Capital Calculation the NAIC is developing for U.S. insurance groups. The following statement can be attributed to Steve Broadie, PCI’s vice president, financial policy.
“PCI supports the NAIC’s efforts to develop a non-prescriptive group capital calculation tool,” said Broadie. “It will allow the NAIC to more effectively understand and assess group risk and permit our time tested and proven U.S. state based insurance regulatory model to continue to serve as the most effective insurance regulatory system in the world,” said Broadie. “The development of an effective and credible group capital assessment tool will enhance the primacy of state regulators’ roles as group-wide supervisors for U.S. groups and assist our domestic industry by avoiding intrusive group regulation by foreign insurance regulators.
“PCI strongly supports the NAIC’s Risk-Based Capital Aggregation Approach as the proper basis for this tool. It is critical, however, that the NAIC take the time necessary to get it right first, rather than developing a flawed tool quickly and rely on improving it as time goes by,” concluded Broadie.
PCI’s response to the Working Group’s questions is attached.