We also appreciated the opportunity to meet with Commissioner Nichols on April 20 th , to discuss the NAIC s efforts to achieve greater efficiency and uniformity in the regulation of insurance. Commissioner Nichols and the NAIC are to be commended for undertaking this effort. For the insurance industry, the next step is to look at how uniform regulation can be achieved to provide greater efficiency in today s national and international marketplace. National treatment, if it could be accomplished, should be able to serve that end. Of the six issues the NAIC has raised in its request for comments, the threshold issue is the legal structure that would enable national treatment of insurance companies.
Legal structure affects the jurisdictional rules.
Although the states have been the principal regulators of insurance companies, differences in state regulation, especially in licensing and eligibility requirements and approval of policy forms and rates, make operating on a multistate basis very difficult. The legal structure chosen to provide for national treatment should minimize jurisdictional differences. Legal structure also impacts costs and benefits. A legal structure that provides the regulated entity with uniformity in licensing and eligibility requirements and in approval of policy forms and rates would benefit the insurance industry by reducing the regulatory burden and costs associated with multistate operations. It would serve consumers by providing more competition, by lowering costs and by moving products to market faster than today.