The Group Solvency Issues (EX) Working Group (the “Working Group”) (a working group of the Solvency Modernization Initiative (EX) Task Force) of the National Association of Insurance Commissioners (“NAIC”) held a meeting at the NAIC summer national meeting in Minneapolis to discuss changes to the Insurance Holding Company System Regulatory Act (the “Act”).  Prior to the meeting, the Working Group issued questionnaires to insurance regulators and interested parties requesting input on the Act and its effectiveness in addressing issues that can exist within insurance company holding company groups, including international insolvency.  The responses provided to the questionnaire by nine state insurance departments were reviewed at the meeting.  The regulators generally expressed a need to have greater authority over non-insurance affiliates of insurance companies, particularly where the business or activities of a non-insurance affiliate could potentially jeopardize the solvency of an insurance company.  Testimony was also provided by interested parties, including the American Council of Life Insurers, American Insurance Association, Property Casualty Insurers Association of America and the Group of North American Insurance Enterprises, encouraging the Task Force to take a coordinated approach with federal and international regulatory authorities to avoid redundant regulation of holding company groups.  The Task Force plans to hold a conference call in the next 30 days for interested parties to further discuss these issues.

We will continue to monitor this issue and provide updates as needed on