Liberty Mutual Insurance Issues Public Comments to U.S. Trade Representative – InsuranceNewsNet

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WASHINGTON, April 18 — Liberty Mutual Insurance, Boston, MAmade a public comment to Office of the United States Trade Representative. The comment was written on April 11, 2022and posted on April 14, 2022:

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Since: Liberty Mutual Insurance

For: Office of the United States Trade Representative

Subject: Comments on the Indo-Pacific Economic Framework

Liberty Mutual Insurance (LMI) appreciates the opportunity to comment Biden-Harris Administration proposed Indo-Pacific Economic Framework (IPEF). By way of introduction, LMI is the largest WE global property and casualty insurer and the world’s sixth largest property and casualty insurer. We supply a range of consumer and commercial products in the WE and globally, and we have significant existing business operations in Australia, India, Malaysia, Singapore, Thailandand Vietnamfocused on serving customers in this region.

General negotiating objectives of the proposed agreement

* Due to the highly regulated nature of the insurance industry and the importance of proximity to customers, WE insurers wishing to operate in a foreign market often have no choice but to establish a local presence in the market. For this and other reasons, binding rules subject to dispute settlement are of crucial importance to WE insurers.

* We understand that consideration is being given to allowing States to choose a la carte which IPEF modules they wish to join. In this scenario, it will be important to ensure that a state joining any module – including the Fair and Resilient Trade module – agrees to negotiate and be bound by high-level rules, and moreover, that all the rules negotiated in the module apply to all States participating in this module. In addition, there should be on-ramps for states that are not ready to agree to join a module on these terms only to join later – for example, provisions calling for future negotiations.

* Based on past trade-related initiatives we have observed, it seems important to incentivize states to agree to join the trade module – which is a major priority for the WE government and stakeholders – as some States might otherwise be inclined to join other modules and omit the trade module.

Labor issues

* The IPEF trade module should recognize and support meaningful labor rights protections that raise living standards and ensure a level playing field.

Environment and climate issues

* P&C insurers like LMI are at the forefront of managing the risks associated with climate change. By facilitating the removal of barriers to WE insurers in the Indo-Pacific region, the IPEF trade module can enable consumers and businesses to better protect themselves from the disruptions resulting from climate change.

* The IPEF business module should facilitate public-private coordination to improve the collection and monitoring of climate-related data. This could include joint efforts to help build databases of physical climate in the region, which are important for resilience efforts, but which are often lacking or weak in countries with low uptake. insurance and for risks that are not insured.

* Finally, the IPEF trade module can and should support a just climate transition.

Issues related to the digital economy

* The IPEF Business Module is expected to establish high-level digital disciplines based on the USMCA and the WE-Japan Digital Trade Agreement, including disciplines related to data flows and cybersecurity. United States should also leverage the innovative provisions of the Digital Economy Partnership Agreement, the Singapore-Australia Digital Economy Agreement, the UK– Singapore Trade Agreement and other recent agreements which, for example, deal with artificial intelligence and other emerging technologies.

* Above all, these digital rules should fully apply to the insurance sector.

Transparency and good regulatory practice issues

* The IPEF trade module should include binding rules to promote transparency and accountability in the development and implementation of service and technology regulations. It should also provide adequate notice and consultation periods to encourage strong stakeholder engagement.

* It would be prudent to use the provisions of the transparency and good regulatory practices chapters of the USMCA (and the provisions adapted to the insurance industry and the broader financial services industry in the chapter on financial services of the USMCA) as a starting point.

Customs and trade facilitation issues

* Many insurance products facilitate trade, including export credit insurance. The IPEF Trade Module has a role to play in shaping a regulatory environment in the Indo-Pacific region conducive to these types of products.

* United States should also consider new approaches to trade facilitation, including the negotiation of rules or principles supporting electronic signatures and electronic invoicing.

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Thank you for considering these initial comments on IPEF. We look forward to engaging with the Office of the United States Trade Representative on an ongoing basis regarding this important initiative.

TARGETED NEWS SERVICE (founded in 2004) provides nonpartisan news and information on “edited journalism” for news organizations, public policy groups and individuals; as well as “collected” public policy information, including press releases, reports, speeches. For more information, contact MYRON STRIPPEDeditor, [email protected], Springfield, Virginia; 703/304-1897; https://targetednews.com