To Michael Byrne, a partner with the law firm of Dewey & LeBoeuf in New York, a particularly interesting aspect of the Nonadmitted and Reinsurance Reform Act is the fact that there is no federal agency to interpret the federal law.
The Act, which passed as part of the signed into law as the Dodd-Frank Wall Street Reform and Consumer Act in July, does create a Federal Insurance Office charged with studying the insurance industry and collecting data, according to Libby Baney of B & D Consulting in Washington.
"The FIO would not interpret these laws. So you have a federal law that likely will be interpreted by states," Mr. Byrne said.
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