Federal Insurance Office and CISA took comments on whether a federal response to catastrophic cyber incidents should be created.

I've read a few of the submissions, and I'm not convinced by any of the justifications so far.

https://www.regulations.gov/document/TREAS-DO-2022-0019-0001

Regulations.gov

I enjoy the cybersecurity vendors piling in to recommend their products.

Reinsurers' comments most interesting. Broadly, they want enough of a backstop to cover the losses that they worry about, but not too much backstop in case it reduces demand for reinsurance.

Haven't come across any ILS focused comments yet.

I'll be writing more about this soon, but I think a federal backstop at this stage is premature. There's still a lot of evolution the cyber insurance market and cat models need to go through first. A premature backstop creates moral hazard.

The Lloyd's of London comment is pretty funny.

The govt should keep out of it apart from for events that the private sector has "little to no appetite" to underwrite. The govt are welcome to explore covering those risks.

https://www.regulations.gov/comment/TREAS-DO-2022-0019-0026

Regulations.gov