Letter Concerning the Completion of the “Covered Agreement” between the United States and the European Union on Prudential Insurance Regulatory Matters

SUMMARY

The Insurance Law Committee (Jill M. Levy, Chair) prepared a letter to the U.S. Treasury Dept. and U.S. Trade Representative concerning the “Covered Agreement” between the U.S. government and the European Union. The Covered Agreement, which arose out of the Dodd-Frank Wall Street Reform and Consumer Protection Act, is intended to impose reciprocity on aspects of insurance regulation affecting insurers doing business in both jurisdictions. While not taking a position on the agreement as a whole, the Committee identifies certain provisions of the Covered Agreement that, in its view, either require further clarification, possibly by means of amendment, or appear to lack a compelling rationale or purpose in light of the objectives set forth in Dodd-Frank.