Posts by Bill Hoisington

REGULATORY DEVELOPMENTS Banking Regulators Release Supervisory Guidance for Implementation of SSFA for Securitization Exposures under the Advanced Approaches On May 18, the Federal Reserve issued Supervisory Guidance for Implementation of the Simplified Supervisory Formula Approach (SSFA) for Securitization Exposures under the Advanced Approaches (“BCC 15-1”). The FRB worked closely with OCC to develop this guidance,…

LEGISLATIVE DEVELOPMENTS Tax Reform Update As we reported in our March LRA update, Senate Finance Committee Chairman Orrin Hatch (R-UT) and Ranking Member Ron Wyden (D-OR) announced a bipartisan effort to begin soliciting ideas from interested members of the public and stakeholders regarding tax reform. Five bipartisan tax working groups have been established to address:…

LEGISLATIVE DEVELOPMENTS Tax Reform Update On March 4, Senators Mike Lee (R-UT) and Marco Rubio (R-FL) released an overview of a tax reform plan titled Economic Growth and Family Fairness Tax Reform Plan. The plan would consolidate the corporate tax system into a single layer and lower the maximum rate to 25% on both corporate…

LEGISLATIVE DEVELOPMENTS Obama’s 2016 Fiscal Year Budget Proposal On February 2, the Obama administration released its Fiscal Year 2016 Budget Proposal. The Department of the Treasury also released its Greenbook. The proposal and general explanations include the same series of proposals relating to insurance and other financial products that we have highlighted in previous years,…

LEGISLATIVE DEVELOPMENTS Promoting Job Creation and Reducing Small Business Burdens Act On January 14, the House passed H.R. 37, which provides technical corrections to about a dozen provisions of the Dodd-Frank Act. Among other things, this bill would delay until July 21, 2019 the requirement to comply with the Volcker Rule for activities related to…

LEGISLATIVE DEVELOPMENTS Insurance Capital Standards Clarification Act On December 18, the Insurance Capital Standards Clarification Act was signed into law by the President. The Act, sponsored by Senator Collins (R-ME), amends the Dodd-Frank Act concerning establishment of minimum leverage and minimum risk-based capital requirements on a consolidated basis for a depository institution holding company or…

REGULATORY DEVELOPMENTS Agencies Propose Technical Corrections and Clarifications to the Advanced Approaches Capital Rules On November 18, the FRB, FDIC and OCC jointly released a Notice of Proposed Rulemaking (NPR) proposing technical corrections and clarifications related to the Basel III Advanced Approaches rules. The NPR does not appear to have any direct implications for BOLI/COLI…

TAX DEVELOPMENTS IRS Private Letter Ruling Regarding Assumption Reinsurance On October 24, the IRS publicly released a Private Letter Ruling (PLR-122451-14) relating to whether an assumption reinsurance transaction for life insurance policies would constitute a “material change” or require re-testing for compliance with section 7702. The PLR was obtained by a parent company of two…

LEGISLATIVE DEVELOPMENTS Insurance Capital Standards Legislation In early September, MetLife received preliminary notification from FSOC that it will be designated as a SIFI.  The insurance industry, including through ACLI and other associations, continues to lobby against FSOC determinations and the implementation of bank-centric capital rules to insurance companies under Dodd Frank. Legislative proposals titled Insurance…