PolicyBrief
H.R. 3354
119th CongressMay 13th 2025
Primary Regulators of Insurance Vote Act of 2025
IN COMMITTEE

This bill amends the Financial Stability Act of 2010 to establish the State insurance commissioner as a voting member of the Financial Stability Oversight Council (FSOC) while removing their previous nonvoting status.

Barry Loudermilk
R

Barry Loudermilk

Representative

GA-11

LEGISLATION

Insurance Regulators Get a Vote on Federal Financial Watchdog: What It Means for Systemic Risk

The Primary Regulators of Insurance Vote Act of 2025 is straightforward: it elevates the State insurance commissioner from a sideline observer to a full voting member of the Financial Stability Oversight Council (FSOC). The FSOC is the federal body created after the 2008 crisis to monitor the entire financial system for risks that could take down the economy—think of them as the ultimate financial safety crew. Historically, the insurance commissioner was there, but couldn't vote. This bill changes that, giving them a seat at the main table (SEC. 2).

Trading a Seat for a Vote on Financial Stability

Under current law, a State insurance commissioner serves on the FSOC in a nonvoting capacity. This bill scraps that nonvoting status (SEC. 3) and creates a new, powerful voting position. This is a big deal because it formally injects the state-level insurance regulatory perspective into federal decisions about systemic financial risk. If you’re a regular person, this matters because insurance—health, auto, home, life—is a huge part of your monthly budget, and state regulators are the ones who usually oversee those companies. Now, they get a direct say in how the federal government monitors massive, interconnected financial firms, including giant insurance companies.

The Appointment Process: Expertise vs. Politics

How does this new voting member get picked? The President makes the appointment for a four-year term. Crucially, the President must ask the National Association of Insurance Commissioners (NAIC) for a list of recommended candidates first. However, here’s the catch: the President is not required to pick someone from that list. If the NAIC doesn't send a list within 15 business days, the President can just move ahead and pick anyone they want (SEC. 2). This setup is important because while it respects the expertise of the NAIC, it also gives the executive branch significant discretion, potentially opening the door for a political appointment rather than a purely regulatory expert.

The Fine Print on Vacancies

Another detail that policy nerds will notice is how vacancies are handled. If the new voting insurance seat becomes vacant, the standard Federal Vacancy Reform Act will not apply. Instead, the other State insurance commissioners will decide on a process to pick a temporary, nonvoting replacement until the official successor is appointed and confirmed (SEC. 2). This means that for this specific seat, the usual federal rules for filling temporary spots are waived, putting the internal selection process completely in the hands of state regulators. This could be slow, contentious, or simply less transparent than the standard federal process.

What It Means for the Rest of the FSOC

By adding a new voting member, this bill slightly dilutes the relative voting power of the existing members, such as the heads of the Federal Reserve, the SEC, and the FDIC. It ensures that when the FSOC is discussing risks related to giant insurance firms—which have been designated as systemically important in the past—the voice of the state-level regulator is no longer just advisory, but carries a full vote. For the rest of us, this is a push to ensure that the unique risks posed by the insurance sector are fully considered at the highest levels of financial oversight, which, in theory, should lead to a more stable financial system overall. The bill also includes a temporary provision to keep the old nonvoting commissioner in place until the new voting commissioner is officially confirmed, ensuring no gap in representation during the transition (SEC. 4).