The past two years have seen a lot of regulatory action on the use of captives to finance XXX/AXXX “redundant” reserves. The inspiration for the NAIC actions focus on three sources of pressure. As part of Federal Insurance Office’s report on reinsurance, they singled out the use of captives in life reinsurance as . . . Read More
In a proposal put forth by the Senate Banking Committee on May 12, 2015, there are several provisions to modify the Dodd-Frank Act. The proposal includes an entire section dedicated to non-bank financial institutions, and calls for, among other items, “Notices and explanations of why . . . Read More
Each insurer’s risk-mitigation needs are unique to their enterprise. Jeremy was able to help one reinsurer come to market with a new product by making sure that the structure passed all regulatory requirements. One client needed to mitigate certain risks which could be provided by traditional reinsurance structures, but those […]
A client needed a feasibility study to determine the viability of entering a new market. Jeremy prepared a report, complete with a market survey, article review and economic review to provide enough background for them to make a decision. To answer their questions Jeremy conducted a market survey, using his […]
Hedge Funds often take calculated risks by investing in companies prior to their going public. Jeremy and his partner produced a report that both explained the market and how much this particular target was worth. As the Hedge Fund did not know the insurance business, part of the report was […]
The current level of statutorily required reserves for level term and universal life with secondary guarantees is widely viewed as redundant. In 2014, Jeremy worked with a client to place approximately $1 billion in redundant reserve capacity. Prior to 20151 the level of the redundancy was determined by the excess […]
The Senate Finance Committee had tasked the IRS to develop some form of asset-based bright line test to separate off-shore (re)insurance companies from Hedge Fund shelters. As noted in my prior post, last Thursday’s proposal does not have a bright line test, but has some other tests that may be . . . Read More
The proposal is meant to make sure that hedge fund sponsored offshore reinsurers are not using these vehicles as a way to shelter investment gains from US taxes rather than being true reinsurers. While the proposed rules are aimed at hedge-fund-sponsored offshore reinsurers, it seems clear that the proposal . . . Read More
One source of dispute between non-United States reinsurers and United States insurance regulators has been the amount of reinsurance collateral that must be established in order for their United States cedents to take full reinsurance credit. Various entities have been lobbying the National . . . Read More
The NAIC is in the midst of an all-out revision of the reinsurance of level term and secondary guarantee universal life policies. Activities include: creation of a new Actuarial Guideline (AG48), creating a new regulation that implements Rector recommendations, Risk Based Capital changes, . . . Read More