The Federal Insurance Office issued a request for comments on October 17, 2011, to solicit input on fulfilling its duties under Section 313(p) of Title 31 of the United States Code, which codifies the 2010 Dodd-Frank Act. That subsection requires the FIO to conduct a study and submit a report to Congress by January 21, 2012, on how to modernize and improve the system of insurance regulation in the United States. The statute requires the director of the FIO to consult with state regulators, consumer organizations and industry representatives as FIO conducts the study, and the request for comments published on October 17, 2011, seeks that input. Comments are due December 16, 2011, as outlined in the Federal Register notice at Fed. Reg. 64174 (Oct. 17, 2011).

The Federal Insurance Office is a new entity created under the 2010 Dodd-Frank Act, which tackled banking and financial services reform in the aftermath of the 2008 financial meltdown in the United States. The FIO's role is to monitor the insurance industry and to make recommendations to other federal bodies, including the new Financial Stability Oversight Council which deals with systemically significant entities. Michael McRaith came from his position as head of the Illinois Department of Insurance and assumed the FIO director position in June 2011. For a Q&A with Director McRaith about FIO’s new role, see http://www.treasury.gov/connect/blog/Pages/Five-Questions-with-Michael-McRaith.aspx.

Under 31 U.S.C. § 313(p), the FIO is statutorily required to take a look at several "considerations" as it studies insurance regulation and puts its report together for Congress. The request for comments seeks input on each of those Considerations. It also has a section on "additional instructions" that says responses should include: "(1) The data or rationale, including examples, supporting any opinions or conclusions; (2) approaches and options toward improvement or modernization, if any; and, (3) any specific legislative, administrative or regulatory proposals for carrying out such approaches or options."