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In this submission, the GIAJ applaud the Reinsurance Task Force’s efforts carefully to review industry comments and reflect them in the revised draft.
However, the GIAJ asked that, to the extent the NAIC/States choose to evaluate the level and quality of reinsurance supervision of a foreign jurisdiction, a separate and respective evaluation process for individual reinsurers (domiciled in that jurisdiction) should be just a formality and made short and simple.
Any outcome under any future evaluation process for "Qualified Jurisdictions" should not prejudice the interests of reinsurers who have already gone through a vetting process and operate as "Certified Reinsurers" in New York and Florida, for instance. (The ‘grandfathering rule’ should apply.)