June 27, 2025

Rhode Island GA’s Margaret Sperry Retiring

Margaret Sperry, Executive Director of the Rhode Island Life & Health Insurance Guaranty Association since 2011, has announced her retirement effective July 1, 2025. Brooks R. Magratten, outside counsel to the Rhode Island guaranty association since 2011, will succeed Sperry as the association’s new Executive Director.

Margaret participated in all facets of the guaranty system during her time with the Rhode Island association, serving on a wide variety of NOLHGA committees and task forces. She served as Chair of the Members’ Participation Council (MPC) from 2021 to 2024 and was a member of the NOLHGA Board of Directors from 2018 to 2024. She also served on the Board of the Guaranty Association Benefits Company (GABC). She co-Chaired the Administrators Education Committee and was a member of the Audit, Coverage/Claims, and GA Laws Committees. She also chaired the MPC Executive Committee’s Model Plan of Operations Subgroup and Pandemic Study Group. In addition, she served on the Global Bankers Insurance Group Task Force.

Prior to joining the Rhode Island guaranty association, Margaret was Senior Vice President and Chief Compliance Officer (CCO) for the MassMutual Financial Group (MMFG). She oversaw ethics and compliance programs in MMFG’s domestic and foreign operations, which included insurance, broker-dealer, investment adviser, investment management, mutual fund, trust, and employee benefits management companies.

We’re sure that everyone in the guaranty community will join NOLHGA in thanking Margaret for her many years of service and wishing her a happy retirement.

  Staff Contact - Sean McKenna

NAIC Updates

After years of work, the Life Actuarial Task Force (LATF) adopted APF 2025-11, which incorporates the current version of VM-22 into the Valuation Manual. Nevertheless, the VM-22 Subgroup and LATF still have to address outstanding items associated with full implementation of VM-22. To that end, Ben Slutsker (MN – VM-22 Subgroup Chair) exposed the following items during LATF’s call last week:

  • Initial questions for discussion regarding retroactive application of VM-22. New Jersey teed up the conversation, suggesting that the department does not want companies to hold redundant reserves on existing business once VM-22 becomes effective. That said, regulators recognized that retroactive application would materially increase their workload. This item is exposed for 30 days and will be discussed further at the NAIC Summer National Meeting in Minneapolis.
  • APF 2025-12, which adds new language in VM-22 and VM-31 regarding the Standard Projection Amount (SPA). The changes are designed to address regulators’ concerns focused on inserting the SPA as a floor mechanism with limited or no credibility supporting the actuarial assumptions and concerns if the SPA serves only as a disclosure item. This item is exposed for 60 days.
Neither of these items will be included in the January 1, 2026, Valuation Manual.

In other NAIC news, during discussions of possible changes to the Life Risk-Based Capital (RBC) formula stemming from the American Academy of Actuaries’ Covariance work, Brian Bayerle (ACLI) encouraged the Life Risk-Based Capital Working Group to consider the impact that the Generator of Economic Scenarios (GOES) would have on the formula and questioned how this work would fit with the new RBC Model Governance Task Force’s efforts. Phil Barlow (DC – Chair) noted that the working group has been told not to pause any existing work. Ultimately, Barlow asked the Academy to consider two items: (1) whether GOES will have an impact on its initial proposal; and (2) whether the proposal, as submitted, would warrant the consideration of changes to any existing RBC charges.

The working group also adopted Item 2025-10-L, which implements the Statutory Accounting Principles Working Group’s (SAPWG) previous changes. It clarifies in the RBC instructions that if any portion of a modified coinsurance (modco)/funds withheld asset has been concurrently used as a pledged asset for a purpose specific to the ceding company at any time of the year, the RBC for the ceding company shall not be reduced. The working group did not receive any comments on this proposal.

The working group received a referral from SAPWG requesting consideration of updated asset valuation reserve (AVR) (for life companies) and RBC factors for collateral loans (for all companies). SAPWG previously adopted revisions requiring more granular reporting of collateral loans based on the type of collateral backing the loan. The working group sent a referral to SAPWG in response to an ACLI comment letter on AVR equity reporting lines for common stock in Subsidiary, Controlled, or Affiliated companies or other affiliates. The referral requests that SAPWG consider updates or clarifications to SSAP No. 97 and the AVR instructions, as needed. Finally, the working group received the 2024 Life RBC statistics, which show that 11 companies triggered some type of action or control-level event.

  Staff Contact - Sean McKenna

IAIS Update

On June 19, 2025, the International Association of Insurance Supervisors (IAIS) launched a public consultation on the review of the Individual Insurer Monitoring (IIM) assessment methodology, a key component of the Global Monitoring Exercise (GME). The GME seeks to assess insurance market trends and determines any potential build-up of systemic risk in the global insurance sector, including at the individual insurer level. The consultation will be open until August 18. A virtual public background session will be held on June 27 from 1:00 to 2:30 p.m. Eastern to present the consultation material and answer questions from stakeholders.

  Staff Contact - Sean McKenna

Privacy Updates

The Connecticut legislature amended the Connecticut Data Privacy Act, specifically narrowing the Gramm-Leach-Bliley Act (GLBA) entity-level exemption to a data-level exemption, but the amendments also introduced an exemption for bona fide financial institutions, like insurers, so insurance companies remain exempt from the law.

While the majority of state legislative sessions have ended for the year, Michigan remains in the running to get a comprehensive privacy law passed. The Michigan Personal Data Privacy Act was refiled as SB 359 and currently exempts financial institutions and data subject to the GLBA.

In California, AB 566, now known as the “California Opt Me Out Act,” has been amended and passed the Assembly with a 48-1 vote. This legislation aims to simplify the process for individuals to send Opt-Out Preference Signals (OOPS) and exercise their rights to opt-out of the sale and sharing of personal information under the California Consumer Privacy Act (CCPA). It mandates that certain platforms, such as web browsers, offer built-in OOPS settings to facilitate these preferences.

On June 12, 2025, a Texas federal judge vacated the Biden-era HIPAA Reproductive Health Rule from the HHS that aimed to protect the privacy of patients seeking abortions and gender-affirming care. In his ruling, the judge found that the rule exceeds HIPAA’s statutory authority and violated the federalism barriers laid out in the U.S. Constitution and affirmed by the Supreme Court, stating that “HHS lacked clear delegated authority to fashion special protections for medical information produced by politically favored medical procedures.”

  Staff Contact - Sean McKenna

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