WASHINGTON, D.C. – The Insured Retirement Institute (IRI) today urged the National Association of Insurance Commissioners (NAIC) to modernize market conduct regulation by emphasizing three priorities: standardization, consistency, and transparency, while aligning standards with modern digital processes.
IRI filed comments in response to questions posed by the NAIC Market Conduct Regulation Modernization (D) Working Group as it considers updates to market conduct examination practices.
IRI said current examination practices can discourage insurers from using faster, more secure digital processes because companies remain uncertain whether examiners will recognize electronic methods as satisfying existing regulatory requirements.
“Clear guidance recognizing electronic delivery, digital transmission of data and digital record-keeping as fully compliant with existing requirements would deliver immediate efficiency gains and strengthen consumer protection,” said Sarah Wood, Director, State Policy and Regulatory Affairs, IRI, in a comment letter to the NAIC Market Conduct Regulation Modernization (D) Working Group.
The association also expressed strong support for uniform data standards, including data definitions, standard style guides, common data models, and clear transmission specifications adopted consistently across states.
IRI said national data standards would allow insurers to develop a single, repeatable compliance process rather than generating separate data for each state examination.
IRI pointed to its Digital First for Annuities (DFA) initiative as one example of how greater standardization could work in practice. IRI suggested that the NAIC might explore work advanced by the initiative, which is facilitating more consistent and efficient communication between industry firms when transmitting and receiving data.
DFA is helping drive the industry towards a “common language” through promoting the standardization of data and a build-once-use-many approach that can be implemented across industry participants.
“If such an approach were considered by the Working Group, it could reduce friction in data requests and support a more streamlined and efficient communication and data transmission process for market conduct requests that aligns with the other data requests across the industry,” Wood noted.
She concluded, “We appreciate the opportunity to provide input into this critical effort. IRI supports the Working Group’s efforts to enhance market conduct regulation and consumer protection and looks forward to continued engagement on these issues.”
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Contact: Dan Zielinski
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