The proposal requests comment on 12 major issues, including solvency, consumer protection, international competitiveness and regulation.

Among specific issues, it asks for comment on the feasibility of regulating only certain lines of insurance at the federal level while leaving other lines of insurance to be regulated by the states. It also asks about the ability of any potential federal regulation or regulator to eliminate or minimize regulatory arbitrage.

It also seeks comment on the degree of national uniformity of state insurance regulation, including the identification of, and methods for assessing, excessive, duplicative or outdated insurance regulation or regulatory licensing process.

It asks for comment on capital standards and the relationship between capital allocation and liabilities, including standards relating to liquidity and duration risk, and on systemic risk regulation with respect to insurance.

On solvency issues, it asks about the consequences of subjecting insurance companies to a federal-resolution authority, including the effects of any federal-resolution authority on the operation of state insurance guaranty fund systems, such as the loss of guaranty-fund coverage if an insurance company is subject to a federal-resolution authority.

Consumer protection issues are also raised, with the FIO asking for comment on whether consumer protection for insurance products and practices is adequate. The FIO specifically asks whether there are gaps in state regulation and whether there is appropriate access to the purchase of insurance products by traditionally underserved communities and consumers.

The FIO also asks whether there is appropriate international coordination of insurance regulation, and the impact that developments in the regulation of insurance in foreign jurisdictions might have on the potential federal regulation of insurance.