When the landmark Dodd-Frank Wall Street Reform and Consumer Protection Act passed in 2010, it was widely assumed that the following year would entail some regulatory uncertainty as the rule-making and implementation processes unfolded. For the insurance industry, the regulatory landscape in 2012 looks to be a sequel nobody wanted to see. "It's rather unfortunate that more than a year has passed since the passage of Dodd-Frank, and things are still very uncertain," says Howard Mills, director & chief advisor, Insurance Industry Group, Deloitte LLP.

Which is not to say that 2011 was devoid of progress. To the contrary, one of the most significant aspects of Dodd-Frank, the establishment of the Federal Insurance Office (FIO) within the Treasury Department, began operating in earnest. Envisioned as a repository of insurance expertise at the federal level, the FIO is tasked with presenting a harmonized national voice on international insurance matters and also with working closely with the state insurance departments, which remain the functional regulators over the business of insurance. Nonetheless, significant questions remain about what exactly the FIO is doing and what it may ask from insurers. "The FIO is statutorily required to have a report to Congress on the efficiency of the state regulatory system in early 2012," Mills says. "Beyond that, we don't know what they are doing."

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