Support for Business of Insurance from CFPB Regulation

We, the undersigned U.S. trade associations, write to express our support for your legislation that would amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection (CFPB) with respect to the business of insurance. Collectively, we represent a majority of the U.S companies and agents offering property-casualty, title, and life insurance and appreciate your timely introduction of this legislation.

As you are aware, Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) exempted the business of insurance from the purview of the CFPB and reiterated that the regulation of insurance has been delegated to the states. We believe that additional revisions to the Dodd-Frank Act are needed to underscore the broad scope of the business of insurance exemption and to place parameters around the CFPB's regulatory actions.

The state-based system of insurance regulation has been effective in promoting consumer protection. By further clarifying the limits of CFPB's regulatory authority and affirming the presumption of exclusive authority of a state insurance regulator, this key legislation will create certainty for insurers, agents, and consumers that there will not be duplicative or conflicting consumer protection regulations in the future.

Thank you for your leadership on this issue and for the opportunity to voice our support for your bill. We look forward to working with you to move this legislation forward.

Respectfully submitted,

American Council of Life Insurers

American Financial Services Association

American Land Title Association

American Property Casualty Insurance Association

Consumer Credit Industry Association

Council of Insurance Agents and Brokers

Independent Insurance Agents & Brokers of America

National Association of Insurance and Financial Advisors

National Association of Mutual Insurance Companies

National Association of Professional Insurance Agents

The Surety & Fidelity Association of America

U.S. Chamber of Commerc