Leonardi assumes NAIC international regulatory mantle

Leonardi, along with other state regulators, has been a vocal opponent of the one-size-fits-all approach he believes the international regulatory solvency framework is taking with Solvency II. 

The NAIC is developing its own supervision requirement of Solvency II with ORSA, the proposed Own Risk and Solvency Assessment requirement for insurance holding companies, a U.S.-wrought Solvency II initiative.

Actual implementation of the ORSA manual won’t be sooner than an effective date of Jan. 1, 2014, if not later, because critical issues remain. The ORSA Manual, if adopted by the NAIC and then individual states, would apply the ORSA requirement to stand-alone insurers with premiums exceeding the manual’s exemption threshold.

Leonardi also said the ComFrame process should not create an unleveled playing field nor have unintended consequences with the IAIGs versus all other entities. Back in October at the IAIS meeting in Washington, Leonardi said a successful model was the NAIC model holding company act, which Connecticut passed in June, that gives the state insurance regulator the power to oversee all parts of the group, to participate in supervisory colleges, and to even ask for the financials of any part of the insurer, even if it’s “a railroad company in South Africa” or a company in an unrelated business in Japan and allows for confidentiality of data, which the state financial exams law do not.  

Also, in committee assignments given to state regulators by NAIC leadership every January, Leonardi has been given the chairmanship of the NAIC’s International Committee. He was formerly vice-chair.

Leonardi, who has been an appointed state commissioner for almost two years, is already a member of the IAIS’ Financial Stability Committee (FSC) and the only U.S. regulator on that committee. 

The IAIS, which is meeting now in Basel, Switzerland, has important decisions and work before it this year, work that directly affects, or possibly could, many U.S. insurers, and issues in which Leonardi is deeply involved..

Also a member of the U.S. Treasury Department’s federal advisory committee on insurance (FACI), Leonardi has been active on the states’ role and the IAIS role in oversight of large internationally active insurance groups.

In June 2012, the IAIS accepted Connecticut’s invitation to hold its FSC meeting in Hartford. In February 2012, Connecticut became the first U.S. insurance regulator to join the IAIS’ Multilateral Memorandum of Understanding, a framework that establishes a formal basis for global cooperation and information exchange among insurance regulators.

In a release issued by Connecticut’s insurance department, Leonardi stated, “It is essential that the U.S. insurance industry operate on a level playing field and that foreign-based carriers that do business here are financially stable enterprises. The end result is a robust, competitive market that provides greater consumer choice and a strong insurance sector that helps drive our economy.” 

Leonardi is a member of the bar of the state and federal courts of Connecticut and New Jersey. He earned a bachelor’s degree from Boston University with distinction in history, summa cum laude and Phi Beta Kappa. He earned a J.D. with honors from the University Of Connecticut School Of Law. Leonardi formerly led Northington Partners, Inc., an insurance specialty venture capital and investment banking firm founded in 1989.