Re: Lloyds of London and Neil D. Levin

Dear Mr. Seifert:

The Insurance Department is a large and diverse organization. Until Neil D. Levin was appointed Superintendent of Insurance, the professional staff was always encouraged to review matters coming before the Department on their respective merits. Levin does not care to rely upon the professional staff. It appears that he thinks he and his inner circle can make all determinations based upon their alleged superior Knowledge and experience. It matters little to Levin that he has no background or experience in the business of insurance or in the regulation of the business of insurance.

Copies of your letters of September 1 and September 23, 1998 addressed to Levin have been circulating within the Department. Don't hold your breath while you wait for responses. None will be forthcoming. Understand that Levin has no duty to respond to the questions you have raised. Also understand that he has no clue on how to respond to you, because the Lloyds deal was made so that Lloyds would remain competitive. If the funding requirements that Lloyds operated under since the 1995 Report on Examination was filed had continued, Lloyds would not have been able to compete for new business. Never mind that the American and dollar payable liabilities were found to be underfunded; the main objective of the operators at Lloyds was to get out from under the 100% funding requirement. And with Levin's help they have obtained their goal.

The questions you raised should be addressed to Levin in a public forum where he would be under an obligation to respond. We suggest that you contact the Chairmen of the Senate and Assembly Insurance Committees and ask them to convene public hearings where your questions could be put to Levin and where he would be under a duty to respond thereto. We are sure that Chairman Grannis would welcome another opportunity to allow Levin to explain the reasons for the actions he has taken as Superintendent.