Witness Takes Issue

With Unit's StanceI read with interest James Nolan's account (JofC, Dec. 5) of Donald Greene's testimony at the insurance department's public hearing on Regulation 41 (concerning the excess lines insurance market.)

As one of the 14 other witnesses who joined Mr. Greene in criticizing the proposal, I must disagree with the department's assertion that everyone at the hearing had "an ax to grind." We opposed and continue to oppose the proposed

revision because it would place unreasonable and unnecessary regulatory burdens on excess line brokers, effectively restricting the access of New York insurance buyers, i.e. the policyholders, to the important excess line market.

The buyers' representative at the hearing, Jon Harkavy of RIMS, described the excess line market as "the large commercial insured's lifeline to the world insurance marketplace." Our members, he said, "are sophisticated enough to understand the greater risks posed by the reduced regulatory safeguards existing in the surplus lines market."

With regard to the Ambassador Insurance Co., I do not recall any of the witnesses objecting to those provisions of the proposal that would increase the financial standards imposed on foreign and alien excess line carriers. Notwithstanding the department's reference at the hearing to "marginal" excess line carriers, the financial standards prescribed in both the proposed and current Regulation 41 prohibit an excess line broker from placing business with a less than financially sound insurer.

James W. March Executive Director & Counsel The Insurance Brokers Assn. of the State of N.Y. Inc. New York.

Amtrak Provides

Necessary Service

Here we go again. Just a few months ago, the Congress rejected President Reagan's proposal to eliminate Amtrak and he is back again with the same idea. For whatever reason, the president seems obsessed with the elimination of Amtrak. However, the Congress does not agree and has so expressed itself.

Amtrak provides a necessary and vital service to our country and should be continued in its present form. Amtrak and its employees have continuously, since its inception, improved their service and productivity as well as meeting the legislative mandates placed upon them by the Congress - such as reducing their dependence upon government funding. Likewise, rail unions have met their obligations to the government and public by negotiating wage concessions and work rule changes to help offset Amtrak's funding dependency.

The public and the Congress are in sync to continue Amtrak, and that's a mandate the president should follow!

Robert A. Scardelletti General Chairman Conrail System Board of Adjustment 86 Brotherhood of Railway, Airline and Steamship Clerks Philadelphia

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