American Insurance Association

COMMENTS OF AMERICAN INSURANCE ASSOCIATION ON DOCKET NO. FMCSA-2006-26262 AND RIN 2126-AB05 The American Insurance Association represents more than 300 insurers that provide 28% of the commercial auto insurance in the U.S. In addition, many of these companies have international experience and have long supported the enhancement of trade in general and between the three NAFTA countries. Insurance is essential for the free flow of commerce. We have advocated mutual recognition of insurance between the NAFTA countries, because in so doing we would be assisting in economic development, easing the flow of commerce and reducing its costs. In addition, by recognizing more companies eligible to provide insurance coverage, we might also be preventing any potential insurance coverage shortages. Consistent with those objectives, we have supported mutual recognition of insurance on commercial vehicles not only between the U.S. and Canada but also between the U.S. and Mexico. We know of no reason why the proposed amendments to Part 387 should not be made and therefore support them. We also call on Canada to make whatever changes are necessary on its side of the border to create the same mutual recognition of insurance written in the U.S. Especially now, when economic recovery is so much needed by our respective peoples, we should do everything we can to encourage and support beneficial trade, not stand in its way. For this fundamental reason as well, we support the proposed rule. Respectfully submitted, David F. Snyder, Vice President and Associate General Counsel, Public Policy American Insurance Association, Suite 400 2101 L St. NW Washington, D.C. 20037