Federal versus State Regulation: A Thorny Issue

May 2001

In this article, IRMI Update editor Jack Gibson provides reader responses to the question of who should handle insurance regulation. Although no consensus is reached, the views expressed are both interesting and entertaining.

by Jack P. Gibson
IRMI

In my April 17, 2001, editorial, I discussed the inefficiencies caused by state regulation of insurance within the United States and asked if we might be better off with one regulator, the federal government. This drew more reader responses that any of my other editorials to date, which demonstrates the importance and controversial nature of this issue.

When you read the readers' responses below, one of the first things that will strike you is that there is no consensus on what should be done to solve the problems that practically every responding insurance or risk professional admits the industry faces. Frankly, I thought there would be more consensus among the various constituencies. For example, I expected local agents and insurers to favor state regulation, with risk managers, national brokers, and national insurers favoring federal regulation. However, there was less uniformity even among the constituencies than I expected. Of course, we must keep in mind that this not a scientifically conducted poll, and such a poll might demonstrate more uniformity among the various factions.


For Further Info on the NAIC's Initiatives

For more information on the NAIC's work to standardize regulations, visit these Web pages:

The National Insurance Producer Registry (NIPR) is the public-private partnership supporting the reengineering and streamlining of the insurance producer licensing process through uniformity for the benefit of consumers, industry, and regulators.

NARAB FAQs This page within the NAIC Web site provides information about the National Association of Registered Agents and Brokers (NARAB) provisions of the Gramm-Leach-Bliley Financial Modernization Act.

Coordinated Advertising Rate & Form Review Authority (CARFRA) This is a report from the NAIC's Speed to Market Working Group on the status of its recommendations to establish multi-state regulatory processes and procedures that are integrated with individual state regulatory requirements to provide a responsive regulatory environment for insurers and consumers.

What follows are most of the comments we received on this editorial. We have done some slight editing to enhance readability.


The Federal Government Can't Do Anything Right!

"Are you out of your mind? The last thing we need is to have the federal government regulate insurance. As a matter of fact the Mc. Ferg bill already gives the Feds the ability to regulate insurance if they see fit. I have been in this business since 1960 and I don't mind that states have different ideas

—Dick Holliday ARM, LUTCF, Fresno, CA

"I've never seen the federal government do anything right. Granted, the current system of having 50 different insurance commissioners is not very efficient, but I have less faith that the federal government can do it any more cost efficiently. One only need to look as far as the rates (and benefits) involved with the USL&H Act as opposed to state workers compensation and you see how inefficient and expensive a federally run program can become. I do agree that there should probably be two levels of regulation, one for personal lines and small commercial and one for larger more complex accounts where there is less need for form and rate regulation."

—Bill Hughs, Vice President, Willis of Louisiana, New Orleans, LA

"I agree that a single federal authority regulating insurance would benefit some insurers and some agents. But, the purpose of insurance regulation is not just to facilitate and smooth the road for insurers and agents but to make sure the citizenry of the various states are well served also. It would appear the issue of states rights to self-determination is acceptable as long as it does not affect corporate profit.

"The ink on GLB is barely dry and the states are already making major strides in standardization, where it makes sense. They will never agree on every issue, and I am thankful for that. The state's governance is supposed to reflect the uniqueness of the citizenry. What flies in California or Maine may not suit Virginians or Texans. Ultimately, independent agents, captives, and consumers would be the losers in a federally regulated environment and the only winners would by the national insurers and larger brokers."

—William D. Cundiff Jr., CIC, AAI, President, Wm. Cundiff & Associates, Inc., Fredericksburg, VA

"I strongly favor the efforts made by the NAIC to achieve uniformity of results and potentially a model or uniform act. However, I don't agree with your suggestion that we propose that the federal government step in. In general, it has appeared to me that the federal judiciary in many jurisdictions is less friendly to the insurance industry than state court judges. Moreover, the current partisan attitudes in Congress lead me to believe that any such bill would be flawed and poorly thought out. If there is a bad provision in a federal statute, the insurance industry would be stuck with it in all 50 states. Now, if the California legislature comes up with a loony statute, the industry only has to deal with it in California, not in the rest of the country."

—William McVisk, Shareholder, Johnson & Bell, Ltd., Chicago, IL

"Uniformity of statutes is great—witness the UCC. Federal regulation would be bad—too much power in one place."

—Robert G. Mahan, Esq., PE, Managing Member, Mahan Insurance Brokers, LLC, Anaheim, CA

"I belong to the Professional Independent Insurance Agents of Illinois's commercial lines technical committee. I have seen several times that most states have agreed to accept changes in insurance forms that our state or some other states have refused as being against the interests of our clients. I think a great example is the 72-hour waiting period for business income coverage. When it came through, only one state, Louisiana, would not allow the change unless an endorsement was provided to allow the waiting period to be deleted. Once that endorsement was provided for Louisiana, the rest of us in the other states also wanted the same endorsement. Would the efficiency of a centralized system, have allowed that to happen?

"I also serve on the Mid America Technical Conference. We work with ISO to improve insurance forms to respond more to the needs of the insurance consumers. I have seen ISO decline to make certain changes that would benefit insurance consumers. Some of our members were then able to get their state to require the changes in their state. Would this be available under an efficient centralized system? It may seem to be an obstacle to efficiency, but I believe that we need checks and balances in the insurance industry to preserve the interests of all the parties. I have not seen any indication that a centralized efficient system will do that."

—Chuck Schramm, CIC, CPCU, ARM, AAI, Lamb, Little & Co., Rolling Meadows, IL

"I agree with your concern to the effect that it would be unlikely that 50 state jurisdictions would agree on reasonably similar legislation for the insurance industry. Perhaps it would help if some differentiation were made between personal and commercial insurance, thereby allowing greater freedom and liberty in offering flexible programs without inefficient and expensive regulation. Certainly another approach would be to pass federal legislation, but again there is no guarantee that each state would embrace the federal regulations.

"You seem to be implying that a singular, common regulation is the desired effect, which may not be feasible given the issue of state's rights versus federal regulation. I feel that an even better solution would be to allow the insurance regulations for the named insured's state of domicile to control. So, while a company may have operations in California, it insurer would be controlled by Illinois regulation because the parent company is based in Illinois. This would set up a competitive environment similar to what we have concerning captive insurers. One would try to out do the other so as to attract cooperate domiciles—and insurance tax revenues. I anticipate the NAIC could engineer such an agreement, given that their intent is for the common good as opposed to a more local agenda. While there may not be uniformity, there would certainly be a more accommodating environment to the advantage of commercial risks."

—Bruce J. Birney, Director of Risk Management, Midas Inc., Itasca, IL

"I still have more faith in the NAIC than I do the federal government. In my opinion, the only thing that the U.S. Government does well is collect taxes. The reason it is effective at tax collection is because the private sector, states, and local governments do it for them!

"I feel that we should give the states the opportunity time to pull their uniform policy together. It is my view that 50+ insurance commissioners can probably accomplish more in less time that 452 Congressmen and 100 Senators, given the make up of the two houses. While I agree that changes are needed, I don't feel that Washington is the place where equitable changes can be made."

—Fred Marshall, Director of Risk Management & Claims, City of Winston-Salem, Winston-Salem, NC

"I agree [that we should start over with a new centralized system], particularly in the arena of Licensing and Continuing Education. We should start over but not with Uncle Sam. I would suggest we subscribe to a system that provides qualified individuals with a universal application run under the auspices of the NAIC with the $$$$$ proceeds flowing to the applicant's state of residence. As one who resides in a state that has not required CE (which I secure in NY which will not certify same for nonresidents) let me tell you, the labyrinth is not easy to navigate.

"Again, we should have a universal standard licensing procedure with selected testing deferring to the peculiarities of the applicant's state of residence. The matter of Continuing Education and the thorny issue of reciprocity should be standardized. CE has to be ratcheted up. For a multi decade commercial producer to sit through a primary personal lines course simply to build up the required CE classroom hours is an exercise in futility, at best. I have floated a few ideas, but to date have found no subscribers!

"Again, using an individual's acquired Continuing Educational level weighted for experience ... I would like to see a graded "All-States" license. If one is a "certified" personal lines producer in their place of domicile, why not have access to all jurisdictions for personal lines? If one is a commercial producer, allow the same. The current state of affairs reminds me of a fishing reel backlash. One need go no further than the producer who receives a call from a major commercial account advising him/her that they are on the verge of acquiring a new subsidiary in a state the agent/broker only remembers faintly from a primary geography class."

—Jim Mulligan, Berg, Carmolli & Kent Inc., Barre, VT

"I am very opposed to federal regulation. If individual state regulation is less efficient, that is a small price to pay to have the benefits, such as the fact that having 50 departments innovating, deciding, analyzing results is a sort of best practices in the long run. Having only one results in a stagnant—way too powerful/bureaucratic— regulator. Not a good thing at all in the long run.

"If you recall the fiascos that have occurred over the years where insurers have had to withdraw from some states, you will understand the value of having multiple regulators. When a single state becomes irrational, business and insurers have the option of choosing not to do business in that state. The wayward state will get the message as businesses choose to do business elsewhere as tax receipts and population decline.

"We need to reduce the amount of influence the federal government has in all aspects of our lives as it does stifle the 'best practices innovation' (and often, common sense) component of having the 50 states develop what they believe to be in their best interest. Just think what this country would look like today if the federal government regulated electricity like the California regulators did!"

—Larry Andreano, The Campbell Agency, Inc., Byron Center, Michigan

"I probably should not comment because I am out of my league on many of the issues concerning regulation, and I know I probably do not have all the facts to have a truly educated opinion. However, because of my involvement in our local independent agent's association (currently the Austin local president), I have had a couple of occasions to visit with our current Texas Insurance Commissioner, Mr. Jose Montemayor. I found Mr. Montemayor to be very informed on most issues. He is a CPA by profession and I feel a trust level with him in the position. I could be wrong, but I feel that he would look out for the best interest of all parties concerned.

"I do understand and to somewhat agree with the concept of single license clearinghouse. At the same time, I have concerns about giving up another state right to a federal entity. With giving up regulation, do we also give up enforcement? I'm beginning to believe that we are giving up too many freedoms for the sake of security and safety and might end up in the long run with neither."

—Jim Sammons, VP, CIC, Vice President, Austin Branch Commercial Insurance Manager, Guaranty Insunance Services, Inc., Austin, TX

Surely the Feds Would Do It Better Than the States

"The present system of state regulation of insurance is as antiquated as the horse and buggy, and creates massive inefficiencies on the part of brokers, risk managers, and insurance companies. The only people who seem to gain are the various bureaucracies in each of the state capitals. Insurance, as part of interstate commerce, crosses state lines more so than staying within state boundaries. Just look at products, automobiles, WC, etc., where the exposure has become much more mobile and should not be limited to any specific state. While I'm leery of federal bureaucracy, can it be worse than what we are presently dealing with, not to mention the fact that some state Insurance Departments spend their time generating political funds for the ruling party, and others are just plain dishonest?"

—Luke Halley, Insurance Services Manager, Halliburton Company, Houston, TX

"I think your hearty praise for the great work of the NAIC is largely misplaced. For years, the NAIC championed the right of each state to run their insurance department as a private empire, with little regard for the impact it had on agents, brokers, and clients. Only after the broker community was able to push NARAB legislation through Congress did the NAIC sit up and take notice. NARAB would never have been passed, or even proposed, if the NAIC had shown even the slightest interest in seriously addressing the issues of multi-state licensing!

"Only when NARAB passed did the NAIC come to the table. Had NARAB died in committee, it would have been back to business as usual, and the NAIC would have resumed their fierce opposition to any licensing modernization!"

—Robert E. Joyce, Executive Vice President, The Harry A. Koch Co., Omaha, NE

"Large commercial accounts need regulatory protection like a fish needs a bicycle. Most accounts employing a broker and an in-house risk manager have a formidable skill set and access to counsel and consultants that regulators can only dream of. Greater minds than mine will need to determine exactly where the cut-off should be, but in the case of sophisticated commercial buyers, few if any have ever availed themselves of any protection from regulators, and most will complain that access to innovative products and rate reductions are sorely hampered by state regulatory requirements.

"Medium-sized, small commercial accounts, and household consumers who lack sophistication and who buy largely first-dollar insurance programs arguably need some protection from unscrupulous companies and agents. Perhaps it is worth examining a split system where the states retain the consumer protection aspect and the remainder of the regulatory scheme is federalized.

"Relieving states of the burden to examine the books and records of insurance companies and maintain financial oversight would allow them to focus on the market conduct examinations and fraud by agent, broker and company that arises from time to time. The issue would be making the information from the states and federal regulators available (via the Internet) so that all consumers could go and look up the insurer/agent/broker they are considering and get a good look down at the relevant information. An informed buyer is a happy buyer."

—Eric F. Ewing, Chairman, Commercial Insurance Associates, Inc., Pittsburgh, PA

"I share your concern over the vast difference between the states regarding insurance law and regulation. I, too, would like to see uniformity but am not sure that it is feasible, or even reasonable, to expect. Due to the vast difference in civil law between each state, and the varying exposures based on geographical areas, I do not believe that we will ever be able to achieve true uniformity. I am very interested in seeing what proposals come to the table and how the industry will continue to work to resolve this problem but hope that the industry uses great caution in what is done."

—Marti Dickman, CIC, Risk Analyst, Chesapeake, VA

"One of the issues not addressed by the Insurance Commissioners is regulation of insurance adjusters on a national basis. Currently, each state has its own licensing, with some exchange of privilege for out-of-state adjusters, often with substantially different requirements for the certification. Further, the issues and fees addressed in the license process are often not related to the actual performance of service to the public.

"The issue is further defined in that many of the carriers, and by that I mean most, are using 'regional offices' to adjust claims in multiple states. In four of the five carriers I queried on this issue, I was advised their adjusters and the managers were not licensed for all the states in which they were adjusting claims. It was assumed that if they were caught, this was simply a cost of doing business, and they would pay the fine and move on.

"Another issue is the licensing of carriers in multiple states and their ability to commingle assets to confuse state examiners regarding the viability of the carrier. One has only to look at the Reliance Nationals, et al., to see that their financial integrity has been a shell game for an extended period. And they are not the only carrier that has been doing this for an extended time either.

"This business has become so large and consolidated, that intervention by the federal government is the only manner in which the industry can be controlled. In addition, it is only with the clout of the federal government and the consolidation of the resources to actually do the job the Commissioners were intended to do, that appreciable intervention into the financial issues can be addressed. Just a thought or two."

—John M Beringer Jr., LPCS, RPA, Beringer & Associates, Inc., Orange, CA

"Speaking personally, not for any organization, I believe the several state commissioners and their respective legislatures and governors may do enough to forestall federal regulation temporarily, but they will implement only what minimum standardization they have to accept in order to retain their territories. That will not be enough to make the system an efficient one, and so the pressure for federal—or, arguably, dual—regulation will continue little abated. As was the case with banks in insurance, I believe the issues now are 'how and when,' not 'whether.' I'll be very interested in the results of your survey, especially if accompanied by a demographic profile of respondents."

—Don Way, CPCU, CLU, ARM, Chairman and CEO, Thoits Insurance, Mountain View, CA

"I too despair of the NAIC model being adopted. Having watched the progress of insurance regulatory oversight in my state for more than 20 years, it is my observation that despite NAIC and department intentions, it becomes politics. As Tip O'Neil is credited with observing, all politics are local. Insurance regulation is no different. Legislators have to tinker so that 'it fits the situation' when the reality is the tinkering is pressured by interest groups who feel their ox is about to be gored. (translate: lower commission revenue).

"As the full-time risk manager of a firm that spends mid-seven figures for a variety of risk management options, the current regulatory climate makes no sense to me. Even though the current archaic regulatory scheme in my state provides a partial exemption from oversight, I still pay surplus lines tax on risk transfer products exempt from oversight. No one has yet given me a straight answer on whose public interest is served other than revenue for the insurance department without any corresponding scintilla of service. I don't want protection from myself, anyway. My board of directors provides me all the oversight I need or want.

"Should there be different models of oversight? Absolutely. I think it ought to be aimed at personal lines and small (under $50,000) premium, and leave large sophisticated policyholders out, including taxation of premium no insurance department is able to regulate under current regulations. Sadly, probably uniform federally dictated standards will accomplish the task of uniformity. There will have to be sufficient incentive—either negative or positive—to motivate recalcitrant parochial legislative bodies to pass the standards."

—Evan Mandigo, CPCU, ARM, Risk and Insurance Administrator, Basin Electric Power Cooperative , Bismarck ND

"I'm sure many fixes and innovations have been/are being tried by NAIC to get all states into some type of general compliance with uniform standards. However, I agree that it's unlikely that the needed efficiency and standardization can be achieved through a 50-state network. Just in the last couple of years, our company has gone from a primarily single-state headquarters to a global corporation attempting to live by the laws and regulations imposed by all these entities (countries and states alike). The cumbersome reporting we are forced to develop just to comply with workers comp regulations that vary between states results in redundancies and prevents our standardizing more procedures in the United States alone, and for what purpose? We are providing the same benefits to all employees regardless of location. In welfare, disability, and retirement, these are all consistent, but we can't attest to that in each state even though the same carrier covers most, except for the monopolistic state funds.

"I don't know where you would draw the line on what NAIC should oversee, but I believe there is more in common with personal lines and small business accounts than with large multi-state and global corporations. These would derive much greater efficiency from being able to look at the big picture and live with less rigid regulations that allow a variety of solutions to meet the spirit rather than the letter of law."

—Mari-Jo Hill, CPCU, ARM, Risk Manager, Finance Division, SAS Institute Inc., Cary, NC

"Standard insurance regulations throughout the country would be wonderful. But making it a federal agency may not help and only give the industry a new set of problems. We won't know, though, until we try, so I'm in favor of starting over on a federal level, maybe even having some non-governmental people sit on a board or something like that."

—Leslie Kazmierowski, Insurance Programs Manager, National Roofing Contractors Association, Rosemont, IL

"I can appreciate the industry's frustration in the maelstrom that now exists for filings. However, I'm not sure if rebuilding with a federal system is the best solution. The turf battles could be bloody! It would be like watching Congress discuss the new OSHA ergonomic standards that were just recently killed. Having said that, the state-versus-federal bickering might actually be entertaining.

"To begin, I'm not 100% knowledgeable about the subject matter but I'd like to add this: I do like the idea of some federal regulations but only on those issues most if not all states would agree with. I suspect it would mostly be administrative. In this fashion, you introduce federal laws in any violation, and that would hopefully make any violator's life that much more difficult. This will require a federal office, however. The arrangement could be similar to the federal EPA and the state EPA . I'm not sure whether federal extradition treaties with other countries have more weight than the states, but if they do, it's an added weapon in enforcement and punishment.

"On the state level, what about seeing what the states have in common and try and build from there? Would state groupings, such as 'these regulations are acceptable in these states, and these regulations are acceptable in those states' be an option? Or are all 50 states at odds with each other? I could be wrong, but there appears that the possibility exists for at least reducing the number of forms from 50 to maybe a more manageable number. This view just might be too simplistic, but I thought I'd say it anyway."

—Sonny Chan, Director, Risk Management, Blyth, Inc., Greenwich, CT

"My view is and always has been that a uniform set of regulations would make the insurance industry far more efficient. States' rights are important, and where there are demonstrable reasons to deviate from a national standard, they should be given due consideration. Having said that, I believe there are very few areas where differentiation is warranted.

"I certainly cast my vote for pressing for national standards pertaining to consumer protection and regulation of the insurance industry. I believe this will only come about through federal regulation as I concur that each state will deviate from any guidelines established to the point where the effect is nil."

—Duane K Ludwig CPCU ARM, Senior Vice President, Marsh Risk & Insurance Services, San Francisco, CA

"In response to your request, I must say no matter how much I may not like it, going with national legislation will be far quicker, and I do believe easier, to control in the long run that 50 different versions state-wise. As to the split, personal lines should stay independent from commercial, be it small or large. Small commercial lines can become large commercial accounts and small accounts do not necessarily translate into 'low-risk' exposures. Therefore, I would comment that personal lines and commercial lines stay separated. I don't see any reason, however, not to split the commercial section between small and large for ease of handling."

—Margie K. McBride, Risk Management Administrator, City of Seattle, Department of Finance Contracting Services Division, Seattle, WA

"I definitely feel that nationwide uniformity is needed. I've worked in 6 different states in my career and have had to take a written test 6 different times. Other than a few minor changes, I am taking the same test time and again. I also firmly believe in continuing education and there are some states (Arizona for one) that do not require CE. Standardization could/should make CE a requirement in all states.

"I also would have preferred to not have had to learn personal lines. I have never been involved in personal lines or life/health, and spending my time learning these lines for various state tests was a waste. I would like to see commercial, personal, life/health, and surety all as separate options.

"I do not believe 'small' and 'large' commercial should be separated. Although I work on relatively larger accounts, on occasion I need to place a BOP-type program as an accommodation.

"Can this be accomplished separately with each state? I doubt it — at least not as quickly as if the process was consolidated. My guess is there would be too many politics involved and too many personal agendas affected to pull consolidation off in a timely manner if left up to the individual states to come to terms with each other.

"Standardization and uniformity??—You've got my vote!!"

—Lisa D. Jacobson, CIC, Marketing Specialist, Willis Insurance Services of California, Inc., San Francisco, CA

"I fear that we have little choice, for federal regulation appears to be dual regulation —making the cure worse than the 'disease'. I believe that the answer is uniformity dictated at the federal level, but I do not know how to get there. However, my prediction is that it will be done piecemeal by the states, and some day it will be federal, with or without duality."

—Frank Cooke, CPCU, Retired, Park Ridge, IL


But Let's Not Wind Up with 51 Regulators!

"I agree with your hope for a single, national, insurance administration. There should be no hope that the federal government could regulate the insurance industry any better than the current state regulation. The goal is to have one consistent administration, not 50 separate bureaucracies. We have seen the Insurance Commissioner's Office used in many states as a politician's training ground. Often, there is abysmal management, while the politicians promote their own self-interests toward being elected to another office. If we could trade 50 of these for one federal post, the simplicity itself would be a big improvement.

"The only downside is that unless there is a true and complete transfer of authority, this will only add the 51st bureaucracy. As you noted, we cannot get all 50 to agree on model acts now. How are we going to get all 50 to agree to disband in favor of a national administration? If the negotiations leave some token control within the states, then we are all faced with dealing through two factions in every state. We want to win this, but if we can't accomplish a knockout, we are better off never starting the fight."

—Jim Chambers, CPCU ARM, Producer, Redmond General Insurance Agency, Redmond, WA

"If we could substitute one regulatory body for 50, it should be more cost effective for everyone, assuming the activities and requirements of the one body were 'reasonable.' Currently, some states seem to lack the talent, interest, or resources to provide a significant safeguard to the public in evaluating the financial condition of insurance companies. Once a company is actually dead, most state regulators can detect a complete lack of pulse. But they are better at issuing death certificates and administering the disposition of the estate assets than doing diagnostics on the living patient. Perhaps this could be improved on with one regulatory body, using a common yardstick, and having resources to police the financial situation at each company.

"Unfortunately, state regulators abolishing their own empires requires more imagination than I possess. And, from an insurer perspective, my concern is that we will have 51 hoops to jump through in lieu of the current 50. And, for product filings applicable to just one state, we may have 2 hoops to jump through in lieu of 1. Certainly, if that is the outcome, it wouldn't be an improvement. For the short term, let's see if the devils we know can get their act into some semblance of alignment. If they can't, we can always opt to start over with 'big brother' from DC.

"Finally, deregulation of insurance form and rate filings for commercial operations that are larger than the 'mom and pop' operations (a 25+/- employees, or sales over $2-3mm +/-, account premium of $10,000.+) seems a reasonable idea. It would better reflect the reality of the individual risk judgment and negotiations that go into final coverage program and pricing in the marketplace. Thanks for the opportunity to share opinions."

—Robert W. Whitman, Division V.P., Great American Insurance Company, Cincinnati, OH


Let's Try Something Different

"Based on virtually everything it has touched so far, the federal government as an insurance regulator is a scary thought, no matter which party is in power. In theory, a centralized regulator at the federal level would simplify and streamline the process. In practice, it will become another way for the federal government to generate taxes, manipulate businesses and consumers and create a gigantic bureaucracy whose prime mission will be to grow and intrude with no offsetting benefits.

"As you point out, state regulation of insurance from multiple jurisdictions is no picnic either. I favor state regulation of personal lines and no regulation of commercial lines. Rating agencies, other independent watch groups, good faith and fair dealing principles of common law, and free market supply-and-demand factors should be adequate checks on the commercial insurance marketplace. Will this approach produce an environment where no one will be hurt? No. But the current approach doesn't either. In fact, one could argue that the inefficiencies and ineffectiveness of insurance market regulation guarantee that all consumers pay more and receive less."

—Michael M. Kaddatz, Managing Director, ARM Tech, Lake Forest, CA

"More protection through disclosure and uniformity needs to be afforded to the individual than the corporation. I would prefer to see the industry set guidelines and regulations than have the government do it."

—Mary E. Donato, ARM, Director of Risk Management, Albuquerque, NM