Mr. Mills met this summer with the top regulators of California and Illinois and members of the insurance industry for a Catastrophe Summit that drew the outlines for a national program.

In his talk he said that he was raising the program issue now "to set the table for the future," adding, "Any national catastrophe plan would mean changes to the National Flood Insurance Program, and that would not be easy."

He said the process of winning passage for a national catastrophe plan "will be a nasty, tough fight."

Mr. Mills in his talk went over the three-part plan that he and the other advocates of a catastrophe program previously outlined this summer. Its components include insurers assuming the primary risk through the formation of a maximum dedicated catastrophe reserve program. To do this, he said Congress will need to change the tax laws to allow tax deductible contributions to bolster reserves.

The second layer would involve the formation of regional catastrophe fund programs such as they have in Florida. A third and final leg would be the creation of a federal fund.

Although a measure proposing a New York catastrophe fund has been introduced in the Republican-controlled State Senate, Mr. Mills did not discuss the possibilities for its passage.

He said under the nation's current system for dealing with catastrophe risk, insurers are doing their part, but the federal government is "inefficiently pouring hundreds of millions of dollars into post-catastrophe events."

Critics of a national catastrophe fund, he noted, say that parts of the country do not have the same exposure to natural catastrophe as the nation's Gulf Coast and should not have to subsidize catastrophe-prone areas. But his response is those areas already do provide subsidies with post-disaster spending of tax dollars.

Mr. Mills, suggesting that a mega-catastrophe could tap out insurers' reserves, said, "There needs to be a better plan to ensure that the premium dollars policyholders pay will be there when needed."

In the wake of New York Attorney General Eliot Spitzer's probe that revealed broker bid-rigging of commercial insurance in exchange for hidden commission payments, Mr. Mills said his department is creating a corporate practice unit to deal with violations of insurance regulations and law in a way that it has not been able to do in the past.

The reason why Mr. Spitzer became the enforcer of insurance regulations instead of the department, he said, was because the department did not have the tools the attorney general's office has to investigate and deal with misconduct.

In an apparent swipe at Mr. Spitzer's wide-ranging investigation of the industry, Mr. Mills said the new unit will have investigators to deal with specific violations but will "not paint a black eye across an entire organization."

At the same time, he said the attorney general's investigation was one that needed to be undertaken.