The National Conference of Insurance Legislators is circulating a draft of a model act (Model Act) that would have the adopting states regulate credit default swaps under provisions patterned on New York State’s current regulation of financial guaranty insurance.  The Model Act would provide that “credit default insurance may be transacted in this state only by a corporation licensed for such a purpose,” and it imposes a variety of requirements upon the licensees.  This article reviews the draft, analyzes how it would operate and then discusses the conflict between an approach to regulation that would empower the insurance departments of 50 states and one that would employ a single regulatory policy.