Colorado Access President & CEO Annie Lee Added to Annual Meeting Program

Annie Lee, JD, President and Chief Executive Officer of Colorado Access, will discuss the state of the health insurance market with NOLHGA President Katie Wade at NOLHGA’s 2026 Annual Meeting in Santa Fe, NM, next month.

As President and Chief Executive Officer, Lee is responsible for advancing Colorado Access' corporate mission and providing executive oversight for all its programs. Prior to joining Colorado Access in 2022, Lee served as Executive Director of Community Health and Medicaid Strategies at Children’s Hospital Colorado for over five years. She also served as Senior Director of Medicaid and Charitable Coverage Programs at Kaiser Permanente Colorado. Prior to that, she worked at the Colorado Department of Health Care Policy and Financing on both the Child Health Plan Plus (CHP+) and Medicaid programs.

The Annual Meeting agenda has been posted on the meeting website, and an agenda for the October MPC meeting is expected to be posted next week. Attendees can use the meeting website to register for the Annual Meeting (October 21–22; in-person only) and MPC meeting (October 20 and the morning of October 21; in-person and virtual attendance):

• Annual Meeting registration is $725 for GA members (GA Board Members, Administrators, and staff) and $800 for non-members.
• Registration for the MPC meeting is free for GA members and $299 for non-members.
• The guest fee is $99 and includes all receptions and meals.

Additional information, including hotel reservations and speaker bios, can be found on the meeting website. Updates on both meetings will be posted in the next few weeks.

International Developments

On August 26, 2026, the International Association of Insurance Supervisors (IAIS) held a public session to discuss the final versions of its Application Papers on recovery and resolution. The Federal Insurance Office’s (FIO) Alex Hart (Chair, IAIS Resolution Working Group) provided a high-level overview of the final papers and answered stakeholder questions (none of which touched on the guaranty system). Hart indicated that no new or updated recovery or resolution standards are planned in the near term. However, internal discussions are underway, with the reinsurance dimensions of resolution identified as a potential area for further work.

Also, on August 26, AM Best released its market segment report on global life/annuity reinsurers. The report finds that the industry is well capitalized and positioned for steady growth, noting that offshore annuity reinsurance has averaged roughly 31% annual growth over the past decade and that ceded life and annuity reserves have more than doubled since 2018. AM Best notes that competition is intensifying as private equity–backed platforms and alternative capital providers continue to enter the space. AM Best identifies a handful of concerns in the report:

• Bermuda and (to a lesser extent) the Cayman Islands have become increasingly favored reinsurance domiciles, in part because their regulatory frameworks permit reinsurers to select from multiple accounting standards for statutory reporting. AM Best warns that capital and reserve requirements in these jurisdictions are often less stringent than onshore standards and that collateralization gaps persist, raising questions about whether cedents can recover assets in stress events.
• Private equity–backed reinsurers are concentrating portfolios in higher-yielding, less-liquid asset classes—including private credit, structured products, and alternatives—which AM Best notes is shifting the sector’s risk profile and may introduce additional vulnerabilities if market conditions deteriorate.
• AM Best cautions that “the level of excess capitalization may be insufficient to support claims in stress scenarios” and has raised concerns about the visibility of capital positions across the sector. On the regulatory front, AG 55 now subjects asset-intensive reinsurance to enhanced asset adequacy testing, an area AM Best is closely monitoring with a focus on capital sufficiency and policyholder protection.

On August 21, the Bermuda Monetary Authority (BMA) published a Consultation Paper on Proposed Insurance (Internationally Active Insurance Group Supervision) Rules 2026 for comment through September 30. The proposed rules are designed to give effect to the qualitative IAIS ComFrame standards applicable to Internationally Active Insurance Groups (IAIGs) and would operate as an overlay to Bermuda’s existing group supervision framework. The BMA notes that implementation of the insurance capital standard (ICS) and development of a resolution framework for IAIGs are being addressed in separate workstreams and are not addressed in this consultation. Consistent with ComFrame, the proposed rules place responsibilities on the Head of the IAIG and the IAIG Board across governance, enterprise risk management (ERM), intra-group transactions, investment risk, liquidity risk, and supervisory reporting. Although the proposed rules are generally aligned with ComFrame, they go beyond ComFrame’s baseline in a few areas, introducing additional supervisory reporting obligations and more prescriptive operational requirements for IAIGs.

The consultation also references ERM and liquidity evidence packs—supervisory documents that the Head of the IAIG may be required to prepare in a form and at a frequency specified by the BMA. These would consolidate key risk indicators, stress outputs, management actions, liquidity positions, contingency funding effectiveness, and related information into dedicated reporting packages. Although the own risk and solvency assessment (ORSA) and annual liquidity report under ComFrame cover much of this content, the evidence packs are intended to go further by creating standalone documents subject to discretionary timing requirements. The proposed rules also introduce two notification obligations without direct ComFrame equivalents: a proactive duty to notify the BMA as soon as practicable of significant intra-group transactions or risk concentrations, and a requirement to promptly inform the BMA of material developments affecting the IAIG’s risk profile that may not be fully captured through existing reporting.

NAIC Updates

The Life Risk-Based Capital (RBC) Working Group held a short call on August 26, 2026, focused on the Financial Condition Committee’s referral directing the working group to develop a reinsurance recapture RBC charge for reserves ceded to entities in non-Reciprocal Jurisdictions. The referral contains two directives: (1) create a charge that accounts for the additional capital a ceding company would need if it had to recapture business ceded to reinsurers in non-Reciprocal Jurisdictions (this was the focus of the call); and (2) modify the Life RBC reinsurance methodology for recoverability risk by aligning the Life formula with the P&C RBC approach for lower-rated reinsurers. Ben Slutsker (Chair, MN) emphasized that the working group’s role is limited to implementing the directives for year-end 2027 reporting, not revisiting them. In light of the referral’s directive, the working group will have a tight timeline, with the structural changes needing to be adopted by the Capital Adequacy Task Force by May 15 and the factor proposals adopted by June 30.

The working group is seeking feedback until September 23 on the appropriate methodology for implementing the first directive. Two primary options were presented: (1) a factor approach, applying a flat or tiered charge to ceded reserves/modco balances (reduced for overcollateralization); or (2) a non-allowance of RBC credit approach, which would reverse the RBC impact for in-scope transactions. The exposure document also invites stakeholders to propose an alternative methodology.

The exposure document raises the question of whether certain items (e.g., excess of loss reinsurance, letters of credit, parental guarantees) can be approved as collateral to offset the new RBC recapture charge. The proposal suggests two options to address the concern, which involve comparing permitted assets to either the U.S. statutory reserve credit or a principle-based reserving (PBR) type of calculation for ceded reserves and charging the difference as RBC. Matt Cheung (IL) raised the question of how the proposed charge should account for situations where the assuming party holds an appropriate amount of capital to support the ceded business. Tom Sullivan (Sullivan Strategy & Advisory Services) challenged the process leading to the referral, questioning the lack of exposure of the referral at the E Committee level and the absence of data supporting a capital-based solution. Slutsker reiterated that the working group’s mandate is to implement the referral.

The Macroprudential Working Group (MWG) is soliciting volunteers to serve on a drafting group tasked with reviewing the Liquidity Stress Test (LST) framework. Bob Kasinow (Chair, NY) previewed this workstream during the Summer National Meeting, noting that the working group will review the appropriateness of prescribed assumptions and the adequacy of the overall framework. The drafting group will consist of regulators and industry representatives. Interested volunteers should contact Tim Nauheimer ([email protected]).

Federal Updates

The House Financial Services Committee has scheduled the following hearings for September:

• September 15 at 10:00 a.m. ET: The Annual Testimony of the Secretary of the Treasury on the State of the International Financial System (Full Committee)
• September 18 at 10:00 a.m. ET: Main Street Capital Access Act: Empowering Community Banks to Drive Economic Growth (Subcommittee on Financial Institutions)
• September 23 at 10:00 a.m. ET: Oversight of Prudential Regulators (Full Committee)
• September 23 at 2:00 p.m. ET: Examining the Future of Central Banking (Task Force on Monetary Policy, Treasury Market Resilience, and Economic Prosperity)