The NAIC held its 2026 Summer National Meeting on August 11–14 in Columbus, Ohio. Below is a summary of the guaranty association–related activities at the meeting.

General/Financial

• An initial list of 10 RBC gaps was exposed for comment—the list ultimately will be whittled down to 5–6 gaps to be considered for future action. (RBC Model Governance Task Force)
• Options for establishing a Commissioner-level RBC Steering Group were exposed for comment. (RBC Model Governance Task Force)
• New Macroprudential workstreams were announced: (1) review of assumptions and overall framework of Liquidity Stress Test; and (2) enhancements of the risk assessment methodology around interconnectedness and contagion risk. (Financial Stability Task Force)
• Comments on the Credit Rating Provider (CRP) Diligence Framework were discussed. (CRP Working Group)
• The RBC Investment Risk and Evaluation Working Group is evaluating the next asset class for in-depth analysis. (Financial Condition Committee)
• The NAIC Capital Markets Bureau report on private credit is expected soon. (Invested Assets Task Force)
• The Investment Analysis Working Group (which generally meets in regulator-only sessions) previewed additional work on Level 3 assets, emerging asset classes such as fund finance and certain forms of structured finance, bond issuer and structured securities reporting attributes (including payment-in-kind features and leverage characteristics), and capital markets research and analytical products. (Invested Assets Task Force)
• Arizona was announced as the first user for the new SERFF platform, with 3–4 more states expected to fully transition by the end of 2026. (SERFF Modernization)

Life Actuarial Updates (Life Actuarial Task Force)

• AG 55 (asset adequacy testing for asset-intensive reinsurance) reviews: regulators identified 10 areas for additional review/analysis.
• AG 53 (asset adequacy testing) reviews: areas of focus include unmodeled cliff risk of complex assets, unmodeled illiquidity risk of complex assets, and valuation of Level 3 assets.
• VM-22 retroactivity: documentation elements required for transition of in-force business to principle-based reserving (PBR) were exposed for comment through October 30.
• The American Academy of Actuaries’ memo on prescribed default and spread methodology was exposed for comment through September 10.
• The Asset Portfolio Segmentation concept (which would add several documentation requirements to support asset segmentation within the model portfolio) was exposed through September 10.

Health

• CMS invites states concerned with the impact of implementing Columbus II-necessitated plan filing changes to notify CMS to allow it to determine whether it is necessary and appropriate to instead move forward with pre-Columbus II ruling filings. (Health Actuarial Task Force)
• CMS will exercise temporary enforcement discretion for issuers providing cost-sharing reduction (CSR) estimates in lieu of actual CSR spending in the 2027 unified rate review template. (Health Actuarial Task Force)
• The Mental Health Parity and Addiction Equity Act (MHPAEA) state enforcement survey is ongoing and will be posted sometime after the August 31 deadline. (MHPAEA Working Group)
• The ERISA Preemption and State Pharmacy Benefit Manager Laws Guidance Document was adopted. (Health Insurance and Managed Care Committee)

Privacy, AI & Cybersecurity

• There was continued discussion on the AI Risk Evaluation Supplement. (Big Data and AI Working Group; Financial Condition Committee; Market Regulation and Consumer Affairs Committee)
• Initial comments were discussed on the comprehensive revisions to the Privacy of Consumer Financial and Health Information Regulation (#672). (Privacy Protections Working Group)
• Updates were provided on the Cybersecurity Event Notification Portal and Cybersecurity Incident Response Framework. (Innovation, Cybersecurity and Technology Committee; Market Regulation and Consumer Affairs Committee)

International Developments

• U.S. Group Solvency Review Recommendations were approved; a referral to the Financial Condition Committee on Group Capital Calculation (GCC) items is forthcoming. (International Insurance Relations Committee)
• There was discussion on the Final Aggregation Method (AM) and implementation timeline. (Aggregation Method Implementation Working Group; International Insurance Relations Committee)

Reinsurance-Related Activity

• A memo to the Life RBC Working Group called for a new RBC factor for business ceded to reinsurers in non-Reciprocal Jurisdictions and changes to account for reinsurers with “lower financial strength ratings.” (Financial Condition Committee)
• A memo was released requesting input on whether to provide increased transparency regarding unaffiliated reinsurance transactions, including possible changes to the Disclosure of Material Transactions Model Act. (Financial Condition Committee)
• The Cayman Islands, Korea, and Guernsey filed Qualified Jurisdiction applications. (Financial Condition Committee)

Accounting Exposures—Comments due October 2 (Statutory Accounting Principles Working Group)

• The negative Interest Maintenance Reserve (IMR) packet was revised and re-exposed, with a key decision point on the effective date (January 1, 2028); the ACLI is developing a roadmap for future discussions at the Fall National Meeting.
• Insurance Company-Owned Life Insurance (ICOLI): A proposal would move ICOLI amounts to Schedule BA and send a referral to the Capital Adequacy Task Force regarding the appropriate RBC charge (note that the working group is not moving this item to the active agenda until comments are received/discussed).
• Residential Mortgage Loans: A proposal requests stakeholder feedback on several questions related to the definition of residential mortgage loans.
• Embedded Asset-Liability Management (ALM) Risk: A proposal would remove “multi-collateral structured credit investments” with “significant ALM risk” from the bond definition and move them to Schedule BA, with a higher RBC charge.
• Replication Synthetic Asset Transactions (RSATs): Among other things, this change would require an RSAT to be backed by a high-quality Issuer Credit Obligation bond and would eliminate the possibility of using lower-quality bonds, asset-backed securities (ABS), or other invested assets as cash components supporting the replication.

Market Conduct

• There was a discussion of third-party oversight in market conduct regulation, particularly regarding TPAs. (Market Conduct Regulation Modernization Working Group)
• There were several fraud-related discussions, including regarding financial exploitation of seniors, the ACA marketplace, auto insurance, and catastrophe claims. (Antifraud Task Force; Producer Licensing Task Force; Pre-Disaster Mitigation and Risk Modeling Working Group)

For an in-depth overview of all the guaranty association–related activities at the NAIC Summer National Meeting, please contact Sean McKenna.