The American Council of Life Insurers is continuing to raise questions about the process Japan is using to privatize its mammoth postal life insurance system.

Japan Post Corp., Tokyo, a holding company that will start out owning the postal service’s insurance, banking, mail and network operations, released an “implementation plan” for privatization Monday.

ACLI President Frank Keating has praised Japan Post for releasing the implementation plan and trying to make the implementation effort transparent.

But Keating has repeated the ACLI’s concerns, which have been expressed many times during the long Japan Post privatization planning process, that the privatized Postal Insurance Corp. must abide by the same requirements that apply to private Japanese life insurers, and that the company must avoid from using its vast size to smother private competitors during the transition to full privatization.

The new implementation plan “does not clarify how the PIC will become fully compliant with all of the same legal and regulatory requirements that already apply to private sector insurance suppliers,” Keating says in the statement.

The Postal Insurance Corp. “should not be unleashed to compete with the private sector until it is first required to play by the same rules and the longstanding advantages it has enjoyed as a protected government-entity are completely eliminated,” Keating says.

Up till now, the Japanese government has restricted the types of products that the postal life insurance operation could write but guaranteed the coverage. The postal life insurance company should not be able to compete on an equal footing with private insurers while the government guarantees its policies, Keating says.

The ACLI says the General Agreement on Trade and Services National Treatment requires Japan to create a level playing field before letting the Postal Insurance Corp. expand its product offerings.

If Japan wants to make the insurance company more attractive to private investors, then it could do so by having the company distribute life insurance products written by private life insurers, rather than by having the company introduce new products of its own, Keating says.