Any federal action aimed at improving the system, NAIFA said, must reflect certain guidelines.

With respect to agent licensing and continuing education requirements, NAIFA said that all insurance agents should be licensed, and that duplicative licensing requirements should be eliminated.

Each insurance agent, according to NAIFA, should be required to demonstrate to only one regulator that he or she is qualified to be licensed and represent either a state-chartered or federally-chartered insurer.

NAIFA said that uniform substantive and procedural licensing requirements should be established for each class of similarly situated agents, and that each insurance agent should need to satisfy only a single set of continuing education requirements for each line of business.

The uniform licensing requirement, NAIFA added, should include a mandatory criminal background check. NAIFA said that a database, which would be available only to financial services regulators, should be established to identify those who have committed fraud.

Turning to consumer protection, NAIFA said that the tax incentives supporting life insurance and other insurance products must be preserved. Uniform trade practices and consumer protection requirements should apply to all insurance sales and service activities, NAIFA said.

Insurance companies, according to NAIFA, must adhere to adequate solvency standards that include guaranty funds or similar fail-safe mechanisms.

Regarding rates and forms, NAIFA said that all duplicative filing and approval requirements should be eliminated, and uniform filing and approval requirements established. However, NAIFA added, "quality to market" concerns should not be sacrificed for "speed to market."

Regarding changes in regulatory rules and procedures, NAIFA said that current regulatory expertise should be preserved to the maximum extent possible consistent with efficient regulation.

Agents, NAIFA added, must be allowed a genuine option of whether to submit to any newly created regulatory authority. NAIFA said that agents should have an institutionalized role in the development and application of all new regulatory rules, structures and procedures.