The Board's mandate includes protection of a federally insured depository institution and the attendant safety-and-soundness objectives. As to a firm's insurance subsidiaries, the states' focus is on policyholder protection, while the Board serves as the overall firm's consolidated safety-and-soundness supervisor.
The Board's capital standard also must comport with federal law for insurance holding companies with depository institution subsidiaries, while the NAIC's GCC interfaces primarily with state laws. Moreover, because of the characteristics of the current population of insurance thrift holding companies, the BBA currently would only need to scale between two regimes: the NAIC's insurance risk-based capital regime and federal bank capital rules.