BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 1448
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          SENATE THIRD READING
          SB 1448 (Calderon)
          As Amended  June 27, 2012
          Majority vote 

           SENATE VOTE  :39-0  
          
           INSURANCE           8-3         APPROPRIATIONS      17-0        
           
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          |Ayes:|Solorio, Fong, Carter,    |Ayes:|Fuentes, Harkey,          |
          |     |Feuer, Hayashi, Olsen,    |     |Blumenfield, Bradford,    |
          |     |Skinner, Wieckowski       |     |Charles Calderon, Campos, |
          |     |                          |     |Davis, Donnelly, Gatto,   |
          |     |                          |     |Hall, Hill, Lara,         |
          |     |                          |     |Mitchell, Nielsen, Norby, |
          |     |                          |     |Solorio, Wagner           |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Beth Gaines, Miller,      |     |                          |
          |     |Torres                    |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Conforms California law to recent changes in the 
          National Association of Insurance Commissioners (NAIC) model law 
          relating to insurance holding company regulation.    
          Specifically,  this bill  :   

          1)States legislative intent to improve interstate and 
            international regulation of insurance holding company systems, 
            by conforming to and to maintaining standards consistent with 
            the NAIC revised model act.

          2)Makes findings and declarations regarding the need for 
            improvements in the regulation of insurance holding company 
            systems.
           
          3)Defines "enterprise risk" as any activity, circumstance, or 
            event that, if not remedied promptly, is likely to have a 
            material adverse effect on the financial condition of the 
            insurer or its insurance holding company system.

          4)Defines "security holder" as a person that owns a security 
            (e.g., common stock, preferred stock, debt obligations) in a 
            company.








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          5)Defines "voting security" to include any security that may be 
            converted into a voting security.

          6)Permits the Insurance Commissioner (commissioner) to hold a 
            public hearing after the filing of a notice that a non-insurer 
            seeks to acquire a controlling interest in a domestic 
            insurance company.  Permits interested parties to participate 
            in this hearing by presenting evidence, examine and 
            cross-examine witnesses, and offer both oral and written 
            arguments.

          7)Permits the commissioner to consolidate the hearing with 
            hearings held by insurance regulators in other states.

          8)Requires notice to the commissioner if a person seeks to 
            divest itself of control of a domestic insurer.  

          9)Requires the commissioner to determine if a party seeking to 
            divest itself of control of a domestic insurer must obtain the 
            commissioner's approval of the transaction.

          10)Provides that the notice of divestment is confidential until 
            the transaction is concluded unless the commissioner 
            determines that confidentiality would interfere with the 
            enforcement of the Insurance Holding Company System Regulatory 
            Act (act).

          11)Requires insurers in a registered insurance holding company 
            system (IHCS) to provide the commissioner with financial 
            statements upon request.

          12)Requires the board of directors of an insurer in an insurance 
            holding company system file a statement with the commissioner 
            that the board is responsible for overseeing corporate 
            governance and internal controls and that the officers and 
            senior management have implemented and maintain corporate 
            governance and internal control procedures.

          13)Permits the commissioner to disallow a disclaimer of 
            affiliation if the information in the disclaimer application 
            is incomplete or inaccurate.

          14)Requires the controlling person in an insurance holding 








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            company system to file an annual enterprise risk report.  
            Specifies that the first enterprise risk report must be filed 
            after July 1, 2013.

          15)Requires notice of amendments to or modifications of 
            affiliate agreements between members of an insurance holding 
            company system to be filed with the commissioner.

          16)Requires notice of a projected change reinsurance premiums or 
            increase in liabilities of 5% or more in any of the next three 
            years to be filed with the commissioner.

          17)Permits the commissioner to examine any insurer to ascertain 
            enterprise risks to the insurer posed by members of the IHCS.

          18)Permits the commissioner to order the production of records, 
            books, or other information from members of an IHCS.

          19)Permits the commissioner to participate in a "supervisory 
            college" composed of other state, federal, and international 
            insurance regulators for a domestic insurer that is part of an 
            IHCS with international operations to determine compliance 
            with the act. 

          20)Permits the commissioner to share confidential information 
            with other state, federal and international regulatory 
            agencies (including NAIC) if those agencies agree to preserve 
            the confidentiality of the information.

          21)Provides that a violation of the registration requirement for 
            IHCS is an independent basis for the commissioner to 
            disapprove dividends, distributions, or seek an order of 
            supervision.

           FISCAL EFFECT  :  According to the Assembly Appropriations 
          Committee, the Department of Insurance workload associated with 
          this legislation should be minor and absorbable within existing 
          resources. 


           COMMENTS  :  According to the sponsor, holding company systems are 
          large and complex and this bill will provide the commissioner 
          with much needed new tools to evaluate the activities of 
          non-insurance entities within a holding company system that 








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          could pose a financial risk to the insurance company owned or 
          otherwise financially affiliated with the holding company.  This 
          bill will help to ensure effective insurer group regulation and 
          oversight.  It is anticipated that enacting these provisions 
          will be an accreditation issue with NAIC and passing this bill 
          conforms California law to the Model Law prepared by the NAIC.

          In December 2010, the NAIC adopted significant revisions to the 
          model law for insurance holding company systems in response to 
          concerns that insurance regulators lacked the necessary 
          authority to adequately understand the risks and activities of 
          non-insurance entities within a holding company system that 
          could pose a risk to an insurer.  The argument for new tools to 
          evaluate risks within insurance groups was intensified by the 
          financial difficulties experienced by certain affiliates of the 
          American International Group insurance holding company system 
          during the 2008 financial crisis.  This bill modifies current 
          law governing insurance holding company regulation to conform 
          with recent revisions to the NAIC model law.  


           Analysis Prepared by  :    Paul Riches / INS. / (916) 319-2086 


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