METLIFE RESPONSE FOR NYT BLOG
Stephen J. Lubben makes two arguments for why MetLife is a SIFI. Neither are grounds for designation
under the Dodd-Frank Act. First, he points to our large corporate bond portfolio, but Dodd-Frank makes
clear that size alone does not make a company systemic. Congress set forth 11 factors that FSOC must
consider in making a SIFI designation, and only one of them refers to size. As Sen. Christopher Dodd
himself said, "The size of a financial company should not by itself be determinative." Second, Lubben
tries to link MetLife to AIG. Everyone knows it was not AIG's insurance business that led the company to
ruin. It was AIG's non-insurance Financial Products division, which was regulated by the federal Office of
Thrift Supervision. MetLife has never had such a business and has no intention of creating one. We are a
traditional life insurance company, with virtually all of our assets and liabilities residing in regulated
insurance entities - a far different business model from the pre-crisis AIG. Lubben worries that an
insurance company might "slide into activities commonly associated with broker-dealers or hedge
funds." But FSOC is not permitted to designate MetLife based on what the company might become
tomorrow. It must make its decision based on the company we are today. As Ben Lawsky, New York's
superintendent of financial services, wrote to FSOC: "MetLife does not engage in any non-traditional,
non-insurance activities that create any appreciable systemic risk."