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4 J. Ins. Regul. 7 (1985-1986)

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POINT


             The   Insurance Agent and the Bank Lobby:
                                 A   Tale   of Dual Regulationf
                                             William   R.  Anderson*
           Counsel,   National   Association of Life Underwriters









 THE  RULING

 Many  visitors to Washington  often wonder  why the Treasury  Building
 sits in the middle of Pennsylvania Avenue, or more precisely what would
 be the middle of that august block, were it to travel the straight path as
 laid out by Washington's original architect Pierre L'Enfant to provide an
 unbroken  view from the White  House  to the Capitol. The answer lies in
 the presidential term of Andrew Jackson, one of the more colorful gentle-
 men to inhabit the White House. It was during Jackson's presidency that
 the Treasury Building was being planned. The architects had delayed and
 delayed, constantly discussing and bickering over the building's location
 to the despair of the President. One day, while more than usually agitated,
 the President marched out of the White  House, threw  his walking stick
 on the ground and  declared, Build the damn  thing there!

   More  than a century later, in a manner as arbitrary as that of President
   Jackson, present Comptroller of the Currency, C. Todd Conover, issued a
   ruling which will be the subject of this article. Although Mr. Conover is
   part of the Treasury Department, in an ironic twist of fate, his office, from
   which the ruling originated, is not in the Treasury Building, but rather in
   L'Enfant Plaza, the building named for Washington's original planner, whose
   design was so thoroughly thwarted by Jackson.

      t William R. Anderson is Counsel of The National Association of Life Underwriters
and has a major responsibility in the area of banking and insurance. He currently is a
member of the Industry Advisory Committee to the Integrated Financial Services Task
Force of the NAIC.
     *  This article first appeared in slightly different form in On the Legal Side, Life
Association News 61 and 59 (February and March, 1985, respectively). It appears here by
permission of LAN, the official publication of the National Association of Life Underwriters.