In 2016, MetLife’s international business operations accounted for more than 40 percent of our revenue.

Our investments in foreign markets allow us to serve customers we otherwise could not through our U.S. operations. The growth of our business relies on new market opportunities.

Mexico is MetLife’s 3rd largest market globally, after the United States and Japan. Since MetLife entered the Mexican market in 1992, our business has grown dramatically, thanks in large part to our 2002 acquisition of the formerly state-owned insurer, Aseguradora Hidalgo. We are now the largest life insurer in Mexico and serve nearly 10 million customers, the vast majority of whom work for the government. Many of our customers are low-income government employees, including some who lack a basic bank account. MetLife provides them financial education and protection at their worksite. For MetLife, the more our business grows in Mexico, the more we are able to use dividends from foreign earnings to fund investments in the United States, which helps the U.S. economy.

NAFTA has provided a strong foundation for MetLife’s business model in Mexico. As a result of NAFTA, Mexico substantially liberalized its financial services industry, opening the banking sector to foreign competition, and eliminating its 30% foreign equity limitation on foreign insurers. The Mexican government’s privatization of Aseguradora Hidalgo, the state-owned insurance company, was a consequence of commitments made under the agreement, and paved the way for MetLife’s acquisition. Furthermore, NAFTA’s binding rules on government procurement enable us to sell employee benefit products to the Mexican government and its employees under a fair and transparent process. Similarly, NAFTA provides for strong investor protections supported by a binding investor-state dispute settlement mechanism that protects firms from unfair treatment.

MetLife supports the effort to modernize NAFTA, with updates and additions, particularly to address instances where financial services have been carved out of provisions in other agreements. It is critical that negotiators take a “first, do no harm” approach to modernization. NAFTA’s provisions on government procurement, investor protections, market access, and national treatment underpin our operations in Mexico and create a level-playing field based on core trade principles of non-discrimination, transparency and rule of law. From MetLife’s perspective, any modernizing reforms to NAFTA should be achieved while simultaneously preserving and keeping in force the benefits of the agreement. In this regard, MetLife is particularly focused on aspects of the NAFTA negotiations that would impact our business in Mexico. We do not do business in Canada.

There are four areas within which MetLife believes NAFTA should be modernized: Government procurement; investment; cross-border data flows and data localization; and regulatory cooperation.

The first area is government procurement. Because MetLife insures nearly two-thirds of all Mexican government employees, we believe the U.S. government should seek to preserve NAFTA’s existing commitments on government procurement, both in its NAFTA renegotiation and in the review ongoing through EO 13788.

Second, MetLife believes a modernized NAFTA should preserve and build on existing investor protections and access to investor-state arbitration. These rules provide a legal framework for ensuring that investments are not subject to discriminatory treatment, and in the event of expropriations or nationalizations, that investors are compensated.

Third, MetLife urges the United States to seek to reaffirm existing commitments on cross-border data flows and prohibit data localization requirements for all sectors, including financial service suppliers.

Finally, we believe NAFTA should include a formal consultative mechanism on regulatory cooperation. This will ensure integrated cooperation on regulatory matters to work toward harmonized rules will help avoid costly regulatory inefficiencies that result from different rules in different markets.

MetLife supports the above-referenced modernizing reforms to NAFTA, but with a strong recommendation that such reforms be achieved while simultaneously preserving and keeping in force the benefits of the existing agreement. Specifically for MetLife, provisions on government procurement, investor protection and financial services are paramount.