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,  
Lloyd’s America, Inc. www.lloyds.com/us Telephone +1 212 382 4081 Email: Sabrina.Miesowitz@lloyds.com  
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