Sabrina Miesowitz
General Counsel
March 22, 2021
Michele Estrada
Office of Research, Rules and Appeals
Department of Insurance and Financial Services
PO Box 30220
Lansing, Michigan 48909
Re: Proposed Changes to Michigan Credit for Reinsurance Rules - Rule Set 2020-132 IF
Dear Ms. Estrada:
This letter is submitted on behalf of Underwriters at Lloyd’s, London in response to the proposed
changes to Michigan’s credit for reinsurance rules. Lloyd’s is one of the largest providers of
reinsurance capacity in the world. In 2019, Lloyd’s assumed approximately $83 million in
premiums from Michigan domiciled insurance companies
Lloyd’s fully supports the proposed changes which track closely to the revisions to the NAIC
Model Credit for Reinsurance Regulation that were unanimously adopted in June 2019 by state
insurance regulators.
Reinsurance is a vital tool in helping to significantly reduce the economic impact of catastrophic
events, such as natural disasters, both on those most immediately affected and for taxpayers at
large. In the US, international reinsurers pay around 60% of total catastrophe losses and are
therefore important to both the US insurance market and the overall economy. By diversifying
US natural catastrophe risks to global markets, the US domestic insurance market is more likely
to remain healthy and robust following even the most significant catastrophe losses.
The proposed updates are an important step in reinsurance collateral modernization which
Lloyd’s believes is critical in order for the US to maintain a competitive and secure insurance
market. We commend the Department of Insurance & Financial Services for advancing
collateral reform in Michigan.
Very truly yours,