Forward look Top regulatory trends for 2016 in insurance

Forward lookTop regulatory trends for 2016 in insurance

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Foreword

This publication is part of the Deloitte Center for Regulatory Strategies’ cross-industry series on the year’s top regulatory trends. This annual series provides a forward look at some of the regulatory issues we anticipate will have a significant impact on the market and our clients’ businesses in the year ahead. For 2016, we provide our regulatory perspectives on the following industries and sectors: Banking, Securities, Insurance, Investment Management, Energy and Resources, Life Sciences & Health Care.

The issues outlined in each of the six reports provide a starting point for the crucial dialogue about future regulatory challenges and opportunities to help executives stay ahead of evolving requirements and trends. We encourage you to share this report with senior executives at your company. Please feel free to contact us with questions and feedback at [email protected].

Best regards,

Chris SpothExecutive Director, Center for Regulatory Strategies Deloitte AdvisoryDeloitte & Touche LLP +1 202 378 5016 [email protected]

Forward look Top regulatory trends for 2016 in insurance 5

Introduction

The regulatory landscape for insurance will continue to present significant challenges in 2016, with insurers facing new or modified rules and requirements that could significantly affect how they do business. In some regulatory areas, the requirements have been clarified over the past year and companies are now focusing on compliance and refinement. In other areas, regulations are still emerging or evolving and companies are looking for clues to help them prepare.

This report highlights 10 key regulatory trends in insurance for 2016:

1. Multiple regulatory influences

2. Own Risk and Solvency Assessment (ORSA)

3. DOL fiduciary standards

4. Cybersecurity and privacy

5. Acquisition from abroad

6. Corporate governance

7. Life insurer use of affiliated captives

8. Principle-based reserving (PBR)

9. Regulatory response to disruptive technology

10. Price optimization

The following pages offer practical insights and guidance for insurers as they prepare for the regulatory challenges ahead.

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The regulatory environment for insurers in the US has grown vastly more complex in the wake of the global financial downturn. In the past, insurance regulation was primarily the responsibility of the states. But now, insurance regulation is being influenced and defined by a complex mix of regulators and quasi-regulators at three different levels: state, federal, and international.

Internationally, we are seeing unprecedented levels of interaction among various insurance regulators—with a strong push for global standards in a broad range of areas from capital requirements to risk management. This trend is having a major impact on all US insurers, even those that don’t do business abroad. A perfect example is the Own Risk and Solvency Assessment (ORSA), which came directly from international discussions and ultimately was adopted by the National Association of Insurance Commissioners (NAIC) for US insurance companies.

At the federal level, laws such as the Dodd–Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) have given rise to a whole host of new regulators and regulatory influencers—including the Federal Insurance Office (FIO), the Financial Stability Oversight Council (FSOC), and the Office of Financial Research (OFR)—that are having a significant impact on the insurance business. These new entities are actively working to define their roles and establish their authority, creating uncertainty and confusion for many insurers. In some cases, they are prompting state regulators to become more proactive and aggressive in order to avoid possible encroachment from federal authorities, particularly in areas such as capital requirements, governance, risk management, and consumer protection.

One example of the expanding reach of federal regulators in the insurance business is the FSOC’s designation of non-bank SIFIs (Systemically Important Financial Institutions). Also, the bar is constantly rising on risk and regulatory standards for insurance companies, with insurers expected to gravitate toward leading practices over time. Another prominent example is the November 2015 decision by the FIO and the US Trade Representative (USTR) to negotiate a covered agreement with the EU on reinsurance. State regulators have expressed concern that this covered agreement could preempt state laws governing reinsurance transactions, most notably collateral requirements.

For many insurers, one of today’s biggest challenges is trying to comply with new capital regulations that were originally designed for banks and do not necessarily fit the insurance business model. Many of these rules strive to help the global financial system survive a crisis by requiring institutions to hold more capital in reserve. This makes sense for banks. But it may limit the ability of insurance companies to spread risk and build resiliency.

The combined impact of these multiple regulatory influences on the insurance industry is tremendous. Not only are there more regulators for some insurers to satisfy—and more regulations to comply with—but there is also a more aggressive tone in the air as various regulatory entities jockey for position and assert their authority. A prominent example (which is the focus of section 3 in this report) is the proposed Department of Labor fiduciary standards regulation, which is expected to impose stringent responsibilities and possibly increased liability when advisers provide retirement investment advice.

The regulatory environment for insurers in the US has grown vastly more complex in the wake of the global financial downturn. In the past, insurance regulation was primarily the responsibility of the states. But now, insurance regulation is being influenced and defined by a complex mix of regulators and quasi-regulators at three different levels: state, federal, and international.

1. Multiple regulatory influences

One of today’s biggest challenges is trying to comply with new capital regulations that were originally designed for banks and do not necessarily fit the insurance business model.


formal feedback or guidance. Until then, it is not clear what the output of these reviews will be or whether regulators will use the information as a point of intervention.

Although the ORSA standard continues to evolve, it is clearly here to stay. Despite a broad spectrum of insurers and degrees of preparedness, ORSA is in the process of being adopted nationwide and will remain an area of examination and focus for the foreseeable future.

A key question is whether regulators will eventually attempt to establish and enforce industry-wide standards based on leading practices gleaned from ORSA filings. For example, will regulators define standardized stress tests that companies will be required to use, analogous to the standardized testing the Fed imposes on large banks? The broader concern is that regulators might make the ORSA more prescriptive and thus less of an “own” risk and solvency assessment.

Another key question is the ultimate use for ORSA. Regulators are still analyzing and synthesizing the ORSA filings, and it may be some time before they issue any

The year 2016 will see many insurers continuing to enhance their enterprise risk management (ERM) frameworks and build out their quantitative assessment of risks and capital. While the ORSA document is a point-in-time filing, state regulators have been clear that they expect the ORSA to be an embedded process that helps support ongoing risk- and capital-based decision making.

2. Own Risk and Solvency Assessment (ORSA)

A key question is whether regulators will eventually attempt to establish and enforce industry-wide standards based on leading practices gleaned from ORSA filings.

Possible negative impacts from this trend include reputational damage, heavy fines, and higher cost of capital. Other significant impacts include the need to invest more time, money, and effort in the areas of risk management, compliance, and governance. To stay ahead of the curve, insurance companies should closely monitor

regulatory developments at all three levels: state, federal, and international. This is true even for small insurers that only operate domestically, as the high degree of interplay that is currently taking place means that developments in one area will likely find their way into other areas very quickly.

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The amended rules are designed to provide further protection to the public from “questionable retirement investment advice” by requiring retirement advisers to follow strict “fiduciary” standards. The rules also prohibit certain types of compensation arrangements unless exemption requirements are met. However, many industry participants believe the rule proposal poses significant operational, compliance, and businesses challenges—and have suggested that the DOL revise, clarify, re-propose, or altogether rescind the rule proposal to address these challenges.1

Public hearings held in Washington, DC, from August 10-13, 2015, offered some clues about how the DOL might respond to concerns in the future. Although we did not see indications that the DOL will likely re-propose or rescind the rule, there were signs that it is willing to engage with industry participants to understand their concerns. The DOL may also seek to address some of those concerns in the final rule proposal, which is expected to be released by the end of the first or second quarter in 2016 and enacted prior to the new Presidential administration.

Many of the operational implications and impacts specific to insurance companies were highlighted in a Deloitte report for the Insured Retirement Institute (IRI).2 While certain details may be modified in the final rule, there are several key themes highlighted in the IRI report on the original proposal:• The expanded definition of who is considered a

“fiduciary” creates operational risk considerations and obligations that may cause insurers to restrict or end certain types of communications, products, and services

On April 20, 2015, the Department of Labor (DOL) issued a re-proposed rule that would expand the definition of “fiduciary” under the Employee Retirement Income Security Act (ERISA) by requiring retirement investment advisers—including broker-dealers, registered investment advisers, and insurance agents—to abide by a fiduciary standard and address conflicts of interest in providing retirement investment advice.

3. DOL fiduciary standards

• Current customer service models—such as call centers and wholesalers—that provide information, education, and guidance to consumers might become unfeasible under the new requirements

• For many insurers, significant and lengthy updates, changes, and bifurcations to systems, processes, and oversight functions across organizations will be required to comply with the rule proposal

• The rule proposal is unclear about the requirements and responsibilities for insurers with non-captive distribution channels

• Absent final changes, the different exemption requirements for fixed annuities and variable annuities will lead to further system bifurcations and modifications to sales, operations, and oversight processes

Deloitte continues to monitor the DOL's rule-making process3 and actively engage with industry participants to help them understand and prepare for the final rule. However, organizations that will likely be affected by the proposed rule should start planning now rather than waiting until the rule is finalized. Begin by identifying how and where your organization will be affected and what changes will likely be required—and what it may cost. Assess the implications of who is deemed a fiduciary, where conflicts exists, and how your overall business strategy and operations will likely need to be modified in light of the final rule. Organizations that don’t start planning until the rule is actually finalized may find themselves overwhelmed and short on time given the budget requirements and all of the compliance, operations, technology, and process changes that will likely be required.

Although we did not see indications that the DOL will likely re-propose or rescind the rule, there were signs that it is willing to engage with industry participants to understand their concerns.


Notably, there were legislative efforts to include a provision in the FY 2016 appropriations bill that would have either blocked funding for the rule or required the DOL to re-open the comment period for 30 days. Although the appropriations bill does not include either of these amendments, the ongoing legislative pressure on the DOL

The NAIC has moved swiftly to address the issue of cyberthreats, forming an executive task force and taking other measures to raise awareness and increase regulatory oversight. In 2015, the NAIC Cyber Security Task Force issued two foundational documents. One is a set of principles for effective cybersecurity. The other—a draft cybersecurity Bill of Rights—is intended to alert consumers to the protections they should expect for their data and implicitly instruct both regulators and insurers of the protections they should offer. Many industry officials have expressed concern that the adopted bill provides rights in excess of those available to most consumers under applicable state laws.

A major challenge with cyberthreats is their diffuse nature. Some may come from external sources such as highly sophisticated state actors, cyber activists, or plain vanilla criminals. Those external threats can be difficult to guard against, but not as difficult as internal threats such as employees who do not practice proper cybersecurity or related actors (e.g., contractors) that have access to a company’s systems. Adding to the challenge is the fact that today’s customer-centric insurers must protect themselves against cyber-barbarians at the gate while at the same time making new and existing customers feel welcome.

will likely require it to carefully consider the multitude of public comments and suggestions received in response to its proposal. We continue to actively monitor events as they unfold, and will provide updates on significant developments through our Reg Pulse blog.

Insurers looking for a holistic, principles-based approach to cybersecurity may want to consider using the NAIC’s principles for effective cybersecurity, which are based on the National Institute of Science and Technology’s standards.

Cybersecurity is at or near the top of just about every list of threats facing insurers, and for good reason. A number of recent cyber intrusions against insurance companies have been costly, both to reputations and bottom lines. Such attacks also raise concerns about privacy and confidentiality, since insurance companies hold vast amounts of personal and sensitive data about their customers.

4. Cybersecurity and privacy

Cybersecurity has now been fully integrated into regulatory examinations. According to the NAIC, everything covered by the Federal Financial Institutions Examination Council (FFIEC) Cyber Assessment Tool is now included in current insurance examinations. Insurers looking for a holistic, principles-based approach to cybersecurity may want to consider using the NAIC’s principles for effective cybersecurity, which are based on the National Institute of Science and Technology’s standards.

The NAIC’s principles include a very basic but sometimes misunderstood and overlooked concept: that cybersecurity transcends the information technology department and must include all facets of an organization and be a part of an enterprise-wide risk management process. Cyber war games, systems, assessments, and periodic employee training are just some of the tools insurers are increasingly using to discover and reduce vulnerabilities. In addition, the NAIC believes it is essential for insurers and producers to use an information sharing and analysis organization to stay up to date on emerging threats or vulnerabilities.

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This summer’s announced purchase of a US-based life insurer—one of three acquisitions by Japanese insurers announced around that same time—was characterized by the insurer’s CEO as a “tremendous opportunity” that included a “substantial cash premium.”

The desire for growth and diversification are key drivers for most acquisitions. Growth of the US economy—despite being sluggish in historical terms—is extremely attractive relative to most other national economies. Also, the US insurance market offers companies from other regions a diverse revenue source that might be more stable than their own. Plus, the sheer size of the US market provides an opportunity for significant revenue growth even from small increases in market share.

Despite requests from small insurers, the NAIC’s disclosure requirements will apply to all companies regardless of size. In contrast, the SEC rule does allow for some exemptions based on size and other factors.

The SEC rule is designed to shine a light on compensation practices by publicly comparing CEO compensation

Acquirers from abroad are likely to be large, international insurers. As such, new capital measures aimed at the largest and most internationally active insurers—such as the proposed Higher Loss Absorbency requirements for Global Systemically Important Insurers (G-SIIs), and the Insurance Capital Standards (ICS) for internationally active insurance groups—might disproportionately affect them and prompt a reassessment of capital needs.

With interest rates remaining historically low, prospective acquirers have an extra incentive to move quickly, perhaps mitigating concerns about possible regulatory changes. Low interest rates also put pressure on some US insurers that need higher investment returns. In this context, consolidation through acquisitions could be considered an appropriate response.

with the median compensation of all other employees. Although the SEC rule provides some flexibility about how the calculations are made and reported, publicly held insurers should be prepared to justify compensation levels far more openly than before. The SEC rule will go into effect on or after January 1, 2017.

Although acquisition of US insurers by non-US companies is no longer a novelty, the market factors that drove this trend over the past few years remain in place, especially for Asian companies, making it likely such deals will continue.

Corporate culture is often seen as a leading indicator of corporate behavior, prompting regulators in the insurance industry and elsewhere to push for improved oversight of corporate governance. To this end, the NAIC’s Corporate Governance Annual Disclosure Model Act has been enacted and is currently being considered. Also, the US Securities and Exchange Commission (SEC) has proposed new compensation disclosure rules, which might affect some insurers.

5. Acquisition from abroad

6. Corporate governance

With interest rates remaining historically low, prospective acquirers have an extra incentive to move quickly, perhaps mitigating concerns about possible regulatory changes.

The SEC rule is designed to shine a light on compensation practices by publicly comparing CEO compensation with the median compensation of all other employees.


The NAIC model requires a broad disclosure, including discussion of and justification for an insurer’s board and committee structure. Issues related to board composition—including independence, diversity, and the nomination and selection process—all must be disclosed. Other areas to be examined in detail include suitability of management and directors, ethics code, performance evaluations, and risk oversight. One major concern with the NAIC model is the confidentiality of reports to the states. Some industry representatives are worried that some states may not adopt the strict confidentiality rules the representatives deem optimal and necessary to protect their companies’ sensitive information.

The proposed effective date for the NAIC disclosure is in 2016, with the first filings to begin in June. As of mid-July 2015, four states had already adopted the model act, with two others—including California—actively considering it. The NAIC rule requires a far more intensive and in-depth examination of corporate governance than previously undertaken by regulators. To prepare themselves, insurers should review affected processes and make the required modifications before the act takes effect in their jurisdiction.

Affiliated captives are primarily used to finance what insurers may consider redundant statutory reserves on life and certain universal life policies. The NAIC recently adopted Actuarial Guideline 48 (AG48) to cover these reserves, commonly referred to as “XXX” or “AXXX” reserves. Also, if regulators get their way, the consistency and uniformity that AG48 is meant to provide will also be accompanied by increased clarity. Even more recently, the NAIC’s Financial Condition Committee has been moving toward having life insurance companies disclose the impact of these captives on their risk-based capital (RBC) calculations.

Regulators intend for the adoption of principle-based reserving (PBR) for life insurance companies to reduce the need for these captives. But until PBR is fully in place,

insurers may continue to view captives as the best vehicles for managing the costs of statutory reserves in excess of the required economic reserves.

Governance of these captives is an important issue for regulators and, as such, should be actively reviewed by insurers. With regulators continuing to seek insight into the assets held by these captives, insurers may wish to evaluate those assets to make sure the asset quality and availability are sufficient to meet regulatory requirements.

Concern about the use of affiliated captives by life insurers continues to grow among both federal and international insurance regulators. For example, in its 2015 annual report, the FSOC cited certain captive transactions as possibly posing a systemic threat to the stability of the US economy.4 To help alleviate such concerns, the NAIC has been moving toward increased disclosure for captives.

7. Life insurer use of affiliated captives

Regulators intend for the adoption of principle-based reserving (PBR) for life insurance companies to reduce the need for these captives. But until PBR is fully in place, insurers may continue to view captives as the best vehicles for managing the costs of statutory reserves in excess of the required economic reserves.

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report presented at the August 2015 NAIC meeting made clear that some insurers may still have a ways to go in preparing for PBR. Although the survey itself was conducted in 2014, meaning the insights might be a bit dated, the overall finding at the time was that few insurers considered themselves prepared in areas such as training and systems.6

The implementation of PBR will likely have ripple effects throughout the insurance business, starting with the actuarial, product design, and pricing functions. To avoid getting blindsided, insurers should already be examining the potential impacts and adjusting their products and processes accordingly. A pilot test for PBR will take place in 2016 with up to 10 volunteer companies—along with their associated domiciliary states. If the experience of insurers that participated in the ORSA pilots is a good guide, participation in the PBR pilot might be a useful step that helps insurers prepare themselves for implementation.

Principle-based reserving for life insurers is a centerpiece of the NAIC’s Solvency Modernization Initiative (SMI) and a high priority for that organization. Most insurers share this priority, seeing PBR as a way to right-size required reserves.

8. Principle-based reserving (PBR)

Opposition to PBR by two key states—New York and California—initially created doubts about its viability. But over time, the landscape has changed. California now seems to be moving toward adoption of PBR. Also, as of mid-November 2015, 39 states representing 71.78 percent of premium have officially passed legislation adopting PBR. Massachusetts is still in session, and if it adopts (as expected) it would bring the total to 40 states representing 75 percent of premium. Threshold for national adoption is passage in 42 states representing 75 percent of premium.5

Eight states will consider PBR in short sessions in 2016, which could lead to adoption early in the calendar year for states that approve it. This is important because if Massachusetts and any other two states adopt PBR by July 1, 2016, it will go into full effect on January 1, 2017 (presuming state statutes adopted pass the equivalency test).

For life insurers, the implementation of PBR will provide certainty around reserving and may reduce requirements for some. However, a Society of Actuaries (SOA) survey

To avoid getting blindsided, insurers should already be examining the potential impacts and adjusting their products and processes accordingly.


To date, disruptive technologies have gained the most traction in property and casualty. For example, regulators have been very receptive to the idea of user-based insurance through automotive telematics: allowing auto insurance customers to pay for only what they use by voluntarily having their driving monitored with in-car devices that track critical metrics such as speed, mileage, and driving habits. The fact that such offerings are voluntary has been crucial to acceptance. Regulators like the fact that consumers have the option to save money through voluntary use of the technology, yet also have the option to skip the technology and simply accept the standard rate.

In contrast, regulators have been much more resistant to disruptive technologies that are involuntary or hidden. For example, many life insurance companies are interested in using big data and predictive analytics to write policies and set rates based on lifestyle factors such as diet, exercise habits, daily activity, purchase history, and television watching. This kind of predictive analysis would arguably enable insurers to do a much more accurate job of pricing policies based on risk. However, regulators have generally been reluctant to embrace this kind of disruptive innovation because it isn’t voluntary and raises concerns about sensitive issues such as privacy and discrimination.

If permitted by regulators, technology disruptions such as these could lead to new and improved products that create significant value for insurers and their customers. However, the full potential for technology disruption in the insurance industry actually cuts much deeper. Today, countless smart, well-funded innovators are actively looking for ways to reinvent how insurance is sold and delivered, analogous to how Uber and AirBnb are transforming business models in their respective industries. And when such innovations hit the marketplace, it can be surprising how quickly they are embraced by regulators and the public. In New York City, for example, Uber and AirBnb initially faced huge roadblocks from highly regulated industries (taxis and hotels) and deeply entrenched incumbents with strong political ties. Yet the power and value of the innovations quickly grabbed the attention of the public and media—and the resulting groundswell of popular support swept away the regulatory barriers in record time.

To avoid falling prey to someone else’s disruption, insurance companies need to adopt a disruptive mindset of their own—actively looking for ways that technology can be used to transform their business models and boost efficiency. They can then use the resulting insights to strengthen their defenses or grab first mover advantage and become their own disrupters.

The insurance industry is ripe for technology disruption and regulators have already embraced a number of innovations, particularly on the property and casualty side. While some insurers might feel protected from disruption because the insurance industry is so highly regulated, many of the regulators we work with seem very interested and receptive to technology breakthroughs—especially if the resulting innovations create clear value for consumers.

9. Regulatory response to disruptive technology

To avoid falling prey to someone else’s disruption, insurance companies need to adopt a disruptive mindset of their own—actively looking for ways that technology can be used to transform their business models and boost efficiency.

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The fundamental idea behind price optimization is adjusting prices based on a customer’s ability and willingness to pay. If a company charges too much, it might lose the customer. But if it charges too little, it sacrifices profit margin. Supermarkets, for example, have long been known to charge different prices in different neighborhoods, depending on what they think customers in that neighborhood will pay for a particular product.

In the era of big data, price optimization is easier and more pervasive than ever, which has sparked new controversy. One highly publicized example is the uproar caused by a major online shopping site that charged different customers different prices depending on which brand of computer they were using. Yet airlines routinely charge different prices for the same seat with few complaints.

What’s different about insurance is that it is a highly regulated industry and prices must be actuarially justified. Given that fact, how can an insurer justify charging different prices to different customers who are actuarially equivalent? This is a concern many consumer groups have raised and some regulators seem to share.One justification is that an actuarially determined rate is in fact a rate band, not a single magic number. This allows an insurer to charge at the high end of the band for a

Endnotes1 http://www.bloomberg.com/news/articles/2015-12-08/wall-street-mounts-final-push-to-kill-tougher-u-s-broker-rules2 “Anticipated Operational Impacts to the Insured Retirement Industry of the Department of Labor’s Proposed Rules for the Definition of Fiduciary Advice,” © 2015 Deloitte Development LLC.3 For updates on the DOL proposed rule, visit the RegPulseBlog.com4 2015 Annual Report, Financial Stability Oversight Council, available at https://www.treasury.gov/initiatives/fsoc/studies-reports/ Documents/2015%20FSOC%20Annual%20Report.pdf.5 “NAIC Update Fall 2015,” © 2015 Deloitte Development LLC. 6 “NAIC Update Summer 2015,” © 2015 Deloitte Development LLC.7 http://regpulseblog.com/

customer who seems less likely to leave due to pricing, while an identical customer who seems more likely to shop around could be offered a price on the low end of the band.

In reality, the issues and concerns that revolve around price optimization probably have less to do with economics and management theory and more to do the public perception of fairness. At least 10 states have already banned price optimization in insurance, and others are reportedly considering it. Despite its potential merits for reducing churn—thereby lowering marketing and other costs and arguably saving money for all policyholders—the practice of price optimization can be difficult to defend.

What’s more, the same big data that makes price optimization effective could boomerang into a disruptor. For example, a major search engine could use big data to offer a service that makes it easy for customers to shop around, thus negating the benefits of price optimization. Given the regulatory issues and other obstacles, insurers that currently use price optimization might want to review the net costs and goals of their price optimization strategies and perhaps look for other less controversial ways to improve stickiness and customer retention.

In economics, elasticity is a measure of how one variable responds to changes in another. Demand elasticity is a measure of how much customer demand for a product changes in response to changes in price, and it is a basic tool for setting the price of a competitive product. Price optimization is one common example of how businesses use the concept of elasticity to improve their performance.

10. Price optimization

In the era of big data, price optimization is easier and more pervasive than ever, which has sparked new controversy.


Moving forward

The regulatory landscape for insurance continues to evolve, making it imperative for companies in the industry to keep a watchful eye on new and modified requirements. For updated information about the latest regulatory trends and developments, please visit the Deloitte Center for Regulatory Strategies’ Reg Pulse blog.7

Kevin McGovernNational Managing Partner, Regulatory and Compliance ServicesDeloitte AdvisoryDeloitte & Touche LLP+1 617 437 [email protected]

Richard GodfreyPrincipal | Deloitte Advisory Advisory US Insurance LeaderDeloitte & Touche LLP+1 973 602 [email protected]

Chris SpothExecutive Director, Center for

Regulatory StrategiesDeloitte AdvisoryDeloitte & Touche LLP+1 202 378 [email protected]

Howard MillsDirector | Deloitte AdvisorAdvisory Global Insurance Regulatory LeaderDeloitte & Touche LLP+1 212 436 [email protected]

George HanleyDirector | Deloitte AdvisoryDeloitte & Touche LLP+1 973 602 [email protected]

Andrew MaisSubject Matter SpecialistDeloitte Center for Financial ServicesDeloitte Services LP+1 203 761 [email protected]

David VaccaIndependent Senior Advisor toDeloitte & Touche [email protected]

David SherwoodSenior Manager | Deloitte AdvisoryDeloitte & Touche LLP+ 1 203 423 [email protected]

Acknowledgements Alex LePore, Senior Consultant | Deloitte Advisory, Deloitte & Touche LLP

Zach Dressander, Senior Marketing Specialist, Deloitte Services LP

Bre McCarthy, Marketing Manager, Deloitte Services LP

Lara Hamilton, Senior Manager | Deloitte Advisory, Deloitte & Touche LLP

Leaders

Contacts

Alok SinhaPrincipal | Deloitte AdvisoryUS Advisory Financial Services Leader Deloitte & Touche LLP+1 415 783 [email protected]

About the Deloitte Center for Regulatory StrategiesThe Deloitte Center for Regulatory Strategies provides valuable insight to help organizations in the financial services, health care, life sciences, and energy industries keep abreast of emerging regulatory and compliance requirements, regulatory implementation leading practices, and other regulatory trends. Home to a team of experienced executives, former regulators, and Deloitte professionals with extensive experience solving complex regulatory issues, the Center exists to bring relevant information and specialized perspectives to our clients through a range of media including thought leadership, research, forums, webcasts, and events.

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