The letter was sent to Wisconsin Insurance Commissioner Sean Dilweg, chairman of the NAIC's Consumer Participation Board of Trustees.

In the letter, Robert Detlefsen, NAMIC vice president of public policy, said "There are many entities not regulated by insurance departments that nevertheless have a considerable financial interest in insurance regulation."

He cited such entities as trial attorneys, realtors, homebuilders, automakers, banks and lending facilities, rating agencies, and risk modeling firms.

"NAMIC believes that the potential for a conflict of interest would be every bit as great if an NAIC consumer representative accepted funding from one of these entities as it would be if he or she received funds from a state-regulated insurance entity or insurance trade association," the letter continued.

Mr. Detlefsen said that NAMIC also believes that funded consumer representatives should be required to disclose any form of financial assistance received from "any entity that is known to have, or could reasonably be expected to have, a material interest in insurance regulation," including third-party nonprofit groups.

The NAMIC letter also urged that disclosures be made public "to enhance the transparency of the Consumer Participation Program."

The new policy will be voted on at a joint meeting of the NAIC Executive Committee and Plenary on Sunday.

An NAIC staff official said there was an open comment period on the draft conflict of interest statement, but that the only response was from NAMIC.

The NAMIC statement voiced particular concern that Birney Birnbaum, executive director of the Center for Economic Justice, Austin, Texas, an accredited consumer representative, also received grants in 2005 and 2006 from the Rockefeller Family fund to educate NAIC members about the impact of climate change on insurance companies and insurance consumers.

Mr. Birnbaum said he is aware of the proposed policy, and has "no problems with it." Moreover, he said, "none of the consumer representatives have any problem disclosing any funding we get from the insurance industry or any other regulated entity."

He added that, "I am not concerned with this policy, and I wish it were stronger."

He said the NAIC has always had a policy requiring disclose of funds received by an accredited consumer representative, as part of the application to be a consumer representative.

It is already disclosed as part of the process [of being a consumer representative]," he said.

The only thing new about the proposed policy is that it requires a consumer representative to disclose any new funding, or plans to receive any new funding, during the year.

Regarding the funding from the Rockefeller family foundation, he said the Rockefeller Family fund is not a "regulated entity" subject to the proposed rule, and has provided funds for his group for several years "for general support, and for work on insurance-related climate change issues."

This article updated Dec.1, 2:54 p.m.