On June 17, 2009, the U.S. Treasury Department released the Obama Administration’s framework for financial regulatory reform. As part of the larger effort to strengthen the regulation of the financial services market, the Financial Reform Plan proposes certain reforms applicable to the insurance industry, including establishment of an Office of National Insurance (the “ONI”) within the Treasury Department, modernization of insurance regulation in accordance with six fundamental principles, special treatment of large systemic insurance conglomerates (known as “Tier 1 FHCs”), and the creation of a Consumer Financial Protection Agency (the “CFPA”)...