Comment letter on Financial Services Modernization Act (March 11, 1999)

March 11, 1999The Honorable Phil GrammUnited States SenateWashington, DC 20510 Dear Senator Gramm: The American Academy of Actuaries recognizes your efforts to develop a sound legislativeproposal for financial services modernization. Based on our review of the amended draft of the Financial Services Modernization Act of 1999,we have prepared the enclosed report documenting our key concerns about this legislation. TheAcademy neither supports nor opposes the bill, but believes that policymakers should adequatelyaddress the implications for the public in expanding the federal agencies’ role in the regulation ofinsurance activities. With or without financial services modernization legislation, there are clearly trends towardblurring traditional distinctions among various types of financial risk (insurance risk included).As companies and products mix elements of banking, investment, and insurance, it is importantto ensure that companies provide adequately for their risk exposure. If adequate provision forrisk exposure is not required, a company might not be able to meet its obligations, exposing thecompany to possible bankruptcy, and the resulting serious consequences for the company’scustomers and the public. We would be happy to work with you and your staff as the Senate develops the financial servicesmodernization legislation to ensure that adequate protections are provided for the public and thefinancial services industry. The American Academy of ...