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  • Comment Detail

  • Date: 06/23/20
    First Name: Steve
    Last Name: Kinion
    Email: skinion@601w.com
    Organization Type: other
    Organization: Steve Kinion Individually

  • Comment

    My name is Steve Kinion and in my personal capacity, present the comments contained in an interview titled, “Delaware’s Kinion: Captives Should Remain Eligible for Fed Home Loan Bank Membership” provided to A.M. BestTV available for viewing at https://bcove.video/2BjJ9EK The interview was taped on August 28, 2019 at A.M. BestTV’s studio in Oldwick, New Jersey. I submit these comments for the Request for Input regarding Federal Home Loan Bank Membership. While the interview was recorded in my capacity as the Director of the Bureau of Captive and Financial Insurance Products, Delaware Department of Insurance, the comments are submitted by me personally. I am not speaking for, nor am I presenting the comments on behalf of the Delaware Insurance Department.

    While the entire interview contents are submitted, I note two parts for special consideration. First, at the 8:45 minute mark, the interviewer, John Weber, asks, “Do you think there is a way to regulate captive insurers to avoid a safety issue to the Federal Home Loan Banks?” In response I provide a number of regulatory safeguards to address financial and operational risks to ensure that captive insurance company members of the FHLB system do not create a risk for the system. Second, at the 13:00 minute mark of the interview, I discuss how the FHFA and state insurance regulators can cooperatively work on the Federal Home Loan Bank membership issue.

    A solution exists allowing captive insurers to be FHLB members while simultaneously addressing any safety and soundness concerns they may present. What needs to occur is for the interested parties to work together to find the solution. The foundation for such cooperative work already exists. I can personally attest to this based on my frequent and productive interactions with the Federal Home Loan Banks of Chicago and Pittsburgh.

    In closing, I hope the FHFA does not simply accept these comments and takes no action. Accepting these comments is the beginning. The next step is to make the effort to further research the membership question and I volunteer my time and expertise for this effort.