Insurers said that offering a roadmap is a good first step, but that the framework needs much more in the way of details.

NAIC President and South Carolina Director Ernst Csiszar said that it is an "evolving document" and details will be incorporated as the document develops.

Mr. Csiszar said that even if insurance reform is not addressed in the few remaining days of the current Congressional session, the issue is going to come up again in Washington. Consequently, he said, regulators have to develop a plan to respond to a request by House Financial Services Chairman Michael Oxley to assist the committee in modernizing state insurance regulation.

Points he made on the model include the importance of being able to access FBI fingerprints to advance uniformity of producer licensing and the possibility of making the market conduct process an accreditation standard at some point in the future.

According to Mr. Csiszar, if NAIC had had access to FBI fingerprints, state insurance regulators could have been alerted earlier to the $200-million-dollar fraud scheme perpetrated by Martin Frankel.

On the issue of market conduct, Mr. Csiszar said that, ultimately, when the program is further along, it could become an accreditation standard.

The NAIC needs to continue to be engaged with Congress, said Jim Poolman, NAIC vice president and North Dakota insurance commissioner.

He added that a market conduct accreditation process is a reasonable goal since NAIC's financial accreditation process has worked so well.

The roadmap states that market conduct uniform standards are based on five preliminary elements including: centralized data collection, structured and uniform market analysis, uniform examination procedures, and interstate collaboration.

Work is underway, according to the roadmap, to streamline company licensing through the NAIC's ALERT system and producer licensing through a central electronic licensing system based on 100 percent reciprocity if states have direct access to FBI fingerprint data and if they can share information on a confidential basis.

Life insurance reform would include adoption of an interstate compact and its accompanying set of product standards.

For commercial lines, NAIC would establish a use-and-file system for rates and rating systems, a file-and-use system for policy forms with a 30-day waiting period, and a requirement that a state's policy form requirements would apply only to insurance written for individual commercial risks in the state.

Among the points dealing with the framework's handling of personal lines is a filing review standards checklist and recognition that state legislatures should determine the appropriate regulatory framework for personal lines.

Dave Snyder, a representative with the American Insurance Association, Washington, said that the roadmap suggests that the momentum for reform is growing and that NAIC wants to be part of that reform. But, he added, "they need to use interstate highways rather than streets to get there."

There has been legislation introduced in four states, including South Carolina, Oklahoma, Massachusetts and Rhode Island, to modernize regulation such as flex rating for automobile insurance, said Robert Zeman, a representative with the Property Casualty Insurers Association of America, Des Plaines, Ill. But more reform needs to be introduced in the states, he continued. And, the roadmap must better address reforms on personal lines, he added.

Roger Schmelzer, representing the National Association of Mutual Insurance Companies, Indianapolis, said that he told regulators that if reform is introduced, then it must be a state based solution.

Michael Lovendusky, a representative with the American Council of Life Insurers, Washington, commented, "I regret to say that after a cursory look at the 20 pages, it seems that NAIC has failed to take full advantage of the opportunity that the House of Representatives is offering to the states?We do not see an urgency for reform."

He added that "there is a slow motion erosion of the insurance base to banks and securities firms."