The American Council of Life Insurers wants securities regulators and other regulators to think about the details when preparing for catastrophes such as major influenza epidemics.
Lisa Tate, a senior counsel at the ACLI, Washington, has emphasized the need both for flexibility and attention to detail in a letter commenting on efforts by the National Association of Securities Dealers, Washington, to plan for an influenza pandemic.
The NASD recently issued a request for comments about how it should prepare for a pandemic.
In the comment letter, Tate praises the NASD, the New York Stock Exchange, the U.S. Securities and Exchange Commission, the U.S. Treasury Department, state insurance departments and the National Association of Insurance Commissioners, Kansas City, Mo., for their efforts to plan for an influenza pandemic.
“While many business disruptions may not be predicted with any certainty, we have learned that it is important to plan ahead together,” Tate writes. “This is a responsibility that the life insurance industry takes seriously.”
Other commenters have asked the NASD about matters that might seem on the surface to pale in significance in comparison with the threat of a flu epidemic that could kill millions of people in the course of a few weeks.
One commenter, for example, asks what the NASD would do about exceptions for registered representatives and others who might be unable to meet continuing education requirements during a flu pandemic.
But Tate notes that regulators have had to make many fine adjustments to help financial services companies and representatives deal with the effects of Hurricane Katrina, and she says a severe flu pandemic could require similar types of changes.
Tate says she would like to see the NASD and other regulators consider the following issues:
- How life insurers would handle the pricing and redeemability of variable life insurance and annuity contracts during periods when market quotations were not readily available.
- Timing requirements for completing various transactions, such as disbursements, in the event of severe staff shortages.
- Licensing requirements for emergency call center staff who may not be NASD-licensed.
- Exemptions to allow liquidity loans between employee benefit plans and interested parties.
- Procedures facilitating orderly stock market re-openings following business disruptions.
- Relaxation of rules that require boards of mutual funds and separate accounts to meet regularly in person.
- Flexibility about the roles of registered principals and representatives during emergency situations.
- Streamlined review processes for firms that need to merge or acquire branch offices or relocate offices out of damaged areas.