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IN THIS EDITION:
- NAIC 2025 Fall National Meeting
- Opening Session
- Capital Adequacy (E) Task Force
- Receivership and Insolvency (E) Task Force
- Big Data and Artificial Intelligence (H) Working Group
- Life Actuarial (A) Task Force (LATF)
- NAIC/Consumer Liaison Committee
- Health Actuarial (B) Task Force
- Financial Regulation Standards and Accreditation (F) Committee
- Statutory Accounting Principles (E) Working Group (SAPWG)
- Reinsurance (E) Task Force
- Third-Party Data and Models (H) Working Group
- Aggregation Method Implementation (G) Working Group (AMIWG)
- Pharmacy Benefit Management (D) Working Group
- Life Insurance and Annuities (A) Committee
- CIPR Event
- Senior Issues (B) Task Force
- Risk-Based Capital Model Governance (EX) Task Force
- Cybersecurity (H) Working Group
- Valuation of Securities (E) Task Force
- Executive (EX) Committee
- Antifraud (D) Task Force
- International Insurance Relations (G) Committee & IAIS Secretariat Q&A
- Joint Meeting of the Financial Stability (E) Task Force & Macroprudential (E) Working Group
- Financial Condition (E) Committee
- Market Regulation and Consumer Affairs (D) Committee
- Health Insurance and Managed Care (B) Committee
- Innovation, Cybersecurity, and Technology (H) Committee
- Joint Meeting of Executive (EX) Committee and Plenary followed by 2026 Officer Election
NAIC 2025 Fall National Meeting
The NAIC held its 2025 Fall National Meeting on December 7–11. Below is a summary of the guaranty association–related activity at the meeting and at some earlier meetings.
Opening Session
Outgoing NAIC President Godfread covered a few regulatory topics at a high level. He noted that some international voices have questioned the strength of U.S. state solvency regulation, a perspective he firmly rejected. He also highlighted the transformative role of artificial intelligence in insurance, emphasizing the need to keep oversight grounded in public interest. Godfread also argued that health insurance affordability hinges on controlling health care costs rather than focusing solely on premiums, urging continued progress in 2026.
Host Commissioner Yaworsky followed with remarks reinforcing the importance of ongoing reforms and collaboration among regulators. Florida CFO Ingoglia asserted that tort reforms have revitalized Florida’s insurance market, attracting 17 new companies to the state. He cautioned that housing affordability will be one of the biggest issues facing regulators in the coming year.
The 2025 Dineen Award recipients were Kevin Beagan (MA), Amy Malm (WI), and Jamie Walker (TX). The Ray Farmer Award for Exceptional Leadership recipients were Commissioner Houdek (WI) and Director French (OH).
Capital Adequacy (E) Task Force
The task force met on November 19. Most notably, the “RBC preamble” item was removed from the task force’s agenda shortly before the call. According to Mike Yanacheak (Chair-IA), the task force was essentially told to stand down on this issue while the commissioner-level RBC Model Governance Task Force considers the purpose and use of RBC. The task force also:
- Adopted 2025-08-CR, which contains the catastrophic event list from January 1 through October 15.
- Adopted its working agenda (and the agendas of its working groups).
- Received a referral from the Statutory Accounting Principles Working Group related to collateral loan reporting. The Life RBC Working Group has a conceptual exposure out for comment on this topic; given the small amount of collateral loan investment by P&C and health companies, regulators determined that there is no current need to amend those formulas.
Receivership and Insolvency (E) Task Force
The task force met on December 1 to receive updates on international resolution projects and the uniform data standard (UDS) 3.0. Bob Wake (ME) highlighted the application papers on recovery planning and resolution powers and planning that were exposed following the International Association of Insurance Supervisors (IAIS) Annual Meeting. The IAIS Resolution Working Group has received considerable input from the NAIC on these two papers, and comments are due February 25. Wake also noted that the Financial Stability Board (FSB) has reaffirmed its decision to discontinue its annual identification of global systemically important insurers and instead rely on the IAIS’s Holistic Framework to assess and mitigate systemic risk in the insurance sector.
Big Data and Artificial Intelligence (H) Working Group
The working group discussed comments on the AI Systems Evaluation Tool 2.0 and worked through real-time revisions. Commissioner Humphreys (Chair-PA) was unable to attend, so the meeting was led by Commissioner Ommen (Co-Vice Chair-IA) and drafting group leads. The working group only had time to discuss the tool’s Instructions, Exhibit A, and the Pilot Process.
Instructions
- Regulators emphasized that the Evaluation Tool is intended for use during the existing examination process. Language was added to make clear that “inquiries and information requests performed related to this tool will be coordinated consistent with the guidance provided by, including but not limited to,” the relevant NAIC Handbooks.
- The working group opposed a suggestion that the Tool explicitly exclude financial impact on insurers. There was a recognition that at some point the Tool may need to be tailored for its specific use, but for purposes of the pilot it is broadly applicable, especially as it relates to governance.
- There seemed to be consensus that thematically the Tool should focus on “direct” impact, and that the intent is for Exhibits C and D to be focused on high-risk systems. Exhibit A is meant to provide an initial high-level understanding of what tools are being used.
- The following language will be added to the company instructions: “For purposes of responding to information requests related to this Exhibit, those models that augment or automate decision making related to consumers are considered to have direct consumer impact.”
- Besides likely adjusting the third column to read “Number of AI System Model(s) with Direct Consumer Impact,” there are no changes anticipated to the other columns. However, in response to interested party comments, Iowa (1) supported allowing insurers to report a range rather than a specific number and (2) suggested it would be appropriate for companies to submit a different format entirely if it substantially fulfils the Exhibit’s requests. Virginia opposed both ideas.
- The “Other” row will be revised to read “Other Insurance Practices” to capture use of an AI model related to insurance practices that doesn’t fall into an above-named category. Clarifying examples will be provided on certain rows, such as “Other” and “Producer Services.”
- It is still expected that the pilot will be used on a mix of financial and market conduct exams in the participating states. So far, 10–12 states have agreed to participate; once the pilot group is finalized, the participating states will be made public.
- The pilot group includes examiners with financial and/or market conduct experience, and the working group continues to coordinate with the Financial Condition (E) Committee, Market Regulation and Consumer Affairs (D) Committee, and other task forces.
- Regulators discussed having the pilot group convene on a regular cadence to discuss what is working (or not) with the Tool, which will inform potential edits. It is too early to know the exact timing of the pilot phase or when/how interested parties will be updated on its progress.
- There was brief discussion about potentially starting with Exhibit A, but the outcome was unclear. Some interested parties suggested deleting Exhibits C and D from the Tool entirely, which regulators opposed before seeing how they perform in the pilot.
Life Actuarial (A) Task Force (LATF)
Exposure of Reinvestment Guardrail (APF 2025-16): This proposal would create a consistent reinvestment guardrail in VM-20, VM-21, and VM-22. The proposal would add the following guardrails: 5% Treasury, 15% PBR credit rating 3 (Aa2/AA), 40% PBR credit rating 6 (A2/A), and 40% PBR credit rating 9 (Baaa2/BBB), which are consistent with the American Academy of Actuaries’ proposed guardrails during the development of VM-22. Rachel Hemphill (Chair-TX) recommended that the LATF not consider adoption of this proposal until regulators can review additional impact testing, which the ACLI has agreed to perform. The ACLI also requested that the NAIC’s model office assist with this modeling. The proposal was exposed for 60 days.
Proposal to Modify Reinvestment Assumptions for PRT Business: New Jersey has developed a proposal that would permit a company to modify VM-22 reinvestment guardrails for pension risk transfer (PRT) business, while still maintaining an appropriate level of conservatism. While the APF suggests that companies would be permitted to use their own spread, default, and investment strategy assumptions, the deck New Jersey used did not go that far. Dave Wolf (NJ) suggested that the current VM-22 framework embeds non-economic conservatism that inflates reserve requirements—incentivizing companies to cede business offshore to reduce the total asset requirement. He highlighted that PRT business is unique and subject to certain safeguards (fiduciary standards, the approval of PRT plan of operations in most states, etc.) that make the business arguably less risky than other VM-22 business. The task force ultimately exposed New Jersey’s deck, which contains the proposal’s conceptual elements.
Task force members raised the prospect of applying this approach to different lines of business but recognized that doing so likely would need to be discussed with the Life Insurance and Annuities Committee and the Financial Condition Committee. Regulators recognized that if they are going to take steps to change the U.S. system to reduce the incentive for companies to cede business offshore, it probably requires a broader discussion.
AG 53 Reviews to Shift Focus to Certain Assumptions: Fred Andersen (MN) provided an update on the Value Analysis Working Group’s (VAWG’s) review of asset adequacy testing (AG 53) submissions. Notably, VAWG will shift its focus to certain company assumptions in cash flow testing in light of the increased complexity of investments and product design. Specifically, Andersen suggested that some companies have fairly aggressive net yield assumptions without robust modeling of default/underperformance risks. VAWG will begin addressing this topic by developing a list of questions related to company assumptions, focusing on non-traditional assets and policyholder behavior. Companies with complex assets and complex products will be prioritized. Andersen emphasized that where there is risk beyond AG 53, VAWG may consider VM-30 review.
Retroactive Application of VM-22: The LATF has held five regulator-only sessions to hear from individual companies regarding the application of VM-22 to in-force business. Those meetings have resulted in a menu of potential options for retroactive application (see Attachment Nine, beginning on page 262 of the Meeting Materials). Regulators have ruled out Options A (mandatory application for all VM-22 business) and G (no application of VM-22 to in-force business). Hemphill emphasized that task force members must balance concerns from companies that want to apply VM-22 to a significant portion of their non-variable business with those that recognize the operational difficulties of doing so. The rest of the approaches will be exposed 75 days for comment, along with the four discussion topics included in the materials and an additional question related to materiality.
Movement on “Day 2” VM-22 Issues: The task force discussed three additional VM-22 topics that remain open as we head into year one of optional VM-22 implementation: (1) aggregation, (2) settlement options, and (3) deposit-type contracts. Ben Slutsker (MN) will make Chair exposures through the VM-22 Subgroup on each of these topics with a 90-day comment period. A few notes for each topic:
- Aggregation: The subgroup will expose the Texas proposal to eliminate the specific criteria that companies must satisfy to permit aggregation of blocks of business in VM-22. Under this approach, companies that aggregate blocks in VM-22 would be required to quantify the benefit of aggregation as part of VM-31 disclosure obligations. The proposal will contain a cover letter requesting additional feedback on the disclosure requirements.
- Settlement Options: There was momentum in the move to allow for optionality in the treatment of settlement options, depending on the circumstances—in other words, it may be appropriate for companies to value settlement option benefits using principle-based reserving (PBR) or pre-PBR requirements of VM-V based on the circumstances of a particular block of business. Regulators seemed to lean toward making PBR the default option, with the option to use pre-PBR requirements with approval from the domestic regulator. There was general consensus that, once a company selected a methodology for a particular block of business, it would need to continue using that methodology.
- Deposit-Type Contracts: This item will result in two Chair exposures. First, the subgroup will expose the American Academy of Actuaries’ proposed clarifying changes relating to contracts that fall within the scope of VM-22. The ACLI continued to argue that deposit-type contracts should be scoped out of VM-22 altogether. Second, the subgroup will expose CoreBridge’s proposal that would scope funding agreements into VM-22.
Exposure of Group Annuity Data Collection APF: As previewed on the last call of the Experience Reporting Subgroup, the LATF exposed a Group Annuity Data Collection APF for 60 days. Pat Allison (NAIC) walked through the elements of the data collection (see Attachment 3, beginning on page 80 of the Meeting Materials) and how they compare to the recent Society of Actuaries’ Group Annuity study. The intent of the proposal is to align this collection with products subject to VM-22. The proposed effective date of the collection is January 1, 2027, with the first initial submission due on September 30, 2027, and the first final submission due on February 28, 2028.
GOES Model Governance Framework Adopted: While additional work needs to be done, the model governance framework adoption is a major step in the implementation of the new Generator of Economic Scenarios (GOES). The adopted framework incorporated revisions regarding incident documentation/remediation and ongoing maintenance of the framework. Industry continues to call for additional documentation and information. Even though it was adopted at the meeting, additional work on the framework will continue next year.
Exposure of APF on Aggregation in Stochastic Reserve: Rachel Hemphill (Chair-TX) introduced APF 2025-17, which would amend VM-20 to allow for aggregation in the stochastic reserve. Hemphill noted that the deterministic reserve already allows for aggregation. The APF was exposed for 60 days.
SOA Updates: The Society of Actuaries (SOA) highlighted 2025 studies on Fixed Indexed Annuity (FIA) policyholder behavior (released in February) and group long-term disability incidence (released in October) and previewed studies planned for release in 2026 on various topics, including large annuity and payout annuity mortality, long-term disability claim termination, individual life mortality, and registered index-linked annuity (RILA) policyholder behavior. The SOA is also conducting a large life insurance company expense study looking at commission and acquisition expenses. Finally, the SOA highlighted its recent roundtable conversation on PRT business, which was designed to provide an objective view of these transactions.
American Academy of Actuaries Updates: Kevin Dyke highlighted the recent activity of the Actuarial Standards Board (ASB), including work on ASOP 7 (life and health cash flows), ASOP 41 (actuarial communications), ASOP 12 (risk classification), and ASOP 1 (introductory standard of practice), along with standards on reinsurance pricing and PBR, which are currently under review. William Hines of the Actuarial Board for Counseling and Discipline (ABCD) explained that the ABCD is seeing a relatively small number of complaints; he encouraged actuaries to submit complaints to the ABCD, as he believes more complaints exist than are submitted. Amanda Barry-Moilanen highlighted recent Life Practice Council (LPC) engagement at the NAIC and two webinars focused on actuaries and investment management and VM-31 in the eyes of regulators. She also reminded stakeholders about the Life and Health Valuation Law Manual that comes out on January 1 each year. Finally, the LPC is seeking input on potentially disruptive events (e.g., another pandemic or a cure for cancer).
Compact Discussion: Katie Campbell updated the LATF on the Insurance Compact’s activities for the first time in a few years. Notably, the Compact is now reviewing nearly as many annuity filings as life filings—a major shift from a decade ago, when it mostly reviewed life filings. Campbell walked through the details of the Compact’s recent Information Notice on universal life products, part of which relates to the new Guidance Note for policies where cash surrender value is based on multiple sets of guaranteed interest rates, expense charges, and/or mortality. Hemphill noted that she has received several questions about this Guidance Note, and the LATF intends to hold regulator-only sessions with companies in January to discuss these changes.
Campbell also highlighted several trends that the Compact is seeing, including annuity bonus riders with a charge, more complex guaranteed lifetime withdrawal benefit (GLWB) riders and index strategies, and annuities where all the crediting strategies are in riders. Next year, the Compact will be looking into proprietary indexes, the definition of an index, and the types of charges that should be considered asset charges for purposes of nonforfeiture analysis. In response to the conversation regarding annuity riders, Mike Yanacheak (IA) questioned how it is possible to have a base contract with no consideration.
NAIC/Consumer Liaison Committee
Consumer Advocacy Awards Presented to Godfread & Peterson: Consumer representatives presented Excellence in Consumer Advocacy Awards to Commissioner Godfread (NAIC President, ND) and Mike Peterson (CA).
The committee heard several presentations, including:
- Health Consumer Protection Priorities During Uncharted Times: Deb Darcy (American Kidney Fund), Shamus Durac (Rhode Island Parent Information Network, or RIPIN), Jennifer Snow (National Alliance on Mental Illness, or NAMI), and Silvia Yee (Disability Rights Education and Defense Fund, or DREDF) presented jointly on the impact of federal health policy changes. They touched on topics such as lessons learned from the unwinding of the Covid Public Health Emergency, state options for protecting access to vaccines and preventive care, how state legislators and regulators can mitigate anticipated coverage losses, and what Departments of Insurance can do on their own and in collaboration with other states.
- How Flawed Death Records Make It Difficult to Locate Beneficiaries of Unclaimed Benefits: Dick Weber (Life Insurance Consumer Advocacy Center, or LICAC) expressed concern that death records are not locating all beneficiaries of unclaimed benefits and, as a result, benefits are delayed or never received by beneficiaries. His presentation outlined five recommended actions: (1) require insurers to search the states that sell vital records data; (2) require standardized validation protocols with evidence that all sources have been tapped; (3) establish annual metrics; (4) tighten the timeframe for locating beneficiaries and paying benefits to 60 days; and (5) require monthly documentation of searching all sources. Weber intends to submit a formal request for action to the committee.
Health Actuarial (B) Task Force
MedSupp Pricing & Possible Other Issues in 2026: Kevin Dyke (Chair-MI) noted plans for the coming year for the task force to look at Medicare Supplement (MedSupp) pricing issues and state actions that may impact premiums, including the impact of state changes to the birthday rule (generally, a limited open enrollment period around an individual’s birthday for current MedSupp enrollees). It was noted that Nebraska is interested in this work. Perhaps the most novel development of the meeting occurred when member Rocky Patterson (WA) requested a discussion at a future meeting of two topics: one related to the interplay of risk-sharing arrangements and health care claims, and the second related to ACA medical loss ratio (MLR) reporting. We expect the members of the task force to confirm collective interest in these additional topics in a future meeting.
Update from CMS-CCIIO: A brief update from the Centers for Medicare & Medicaid Services (CMS) was mum about the forthcoming CY2027 Notice of Benefit and Payment Parameters currently in development, though no changes to the “original” CY2026 qualified health plan (QHP) and rate review timelines are anticipated for the CY2027 cycle. When asked if CMS is doing contingency planning in case changes to premium tax credit eligibility (including extending enhanced tax credits) are enacted, CMS stated that they do not comment on particular legislation.
Society of Actuaries Report: Dale Hall of the Society of Actuaries (SOA) presented on the Society’s recent study activities, including an upcoming LTC experience study that is expected to take a year to complete, with a tentative report publication in the first quarter of 2027. Hall also said that the 2015–2024 Group Long-Term Disability Termination Report is scheduled to be completed by the fall of 2026.
Lots of Changes Underway for Health ASOPs: Dyke, speaking on behalf of the Actuarial Standards Board (ASB) for the last NAIC meeting in which he will hold the ASB Chair title, highlighted many health-specific actuarial standards of practice (ASOPs) under development; most recently, the ASB approved ASOP 7, Life or Health Cash Flow Analysis. Dyke surmised that the attention to health is due to the cyclical nature of ASOP updates. Other ASOPs under revision or development include:
- ASOP No. 8, Regulatory Filings for Health Benefits, Accident and Health Insurance, and Entities Providing Health Benefits
- ASOP No. 45, The Use of Health Status Based Risk Adjustment Methodologies
- ASOP No. 49, Medicaid Managed Care Capitation Rate Development and Certification
- Pricing Reinsurance or Similar Risk Transfer Transactions Involving Life Insurance, Annuities, or Long-Duration Health Benefit Plans (new)
- ASOP No. 45, The Use of Health Status Based Risk Adjustment Methodologies
Financial Regulation Standards and Accreditation (F) Committee
Continued Accreditation Awarded to Four States: Commissioner Clark (KY) announced continued accreditation for Idaho, Kentucky, Oklahoma, and Vermont.
Review Team Guidelines & SEG Revisions Adopted: The committee adopted:
- Revisions to the Review Team Guidelines and Self Evaluation Guide (SEG) regarding the use of contract personnel; these revisions incorporate interested party feedback to address issues of conflicts of interest and confidentiality.
- Technical changes to the SEG to address various topics, including the retention of personnel.
Statutory Accounting Principles (E) Working Group (SAPWG)
SAPWG acted on several items, notably the new exposures on negative interest maintenance reserve (IMR), private placement commitments, non-admitted assets in separate accounts, a comprehensive review of how equity changes are reported, and additional changes related to modco/funds withheld asset reporting.
The working group adopted the following items:
- Ref #2025-13, which provides new guidance to SSAP 37 – Mortgage Loans to allow a qualifying statutory trust structure to hold and report residential mortgage loans on Schedule B as if the loans were held directly. A statutory trust must meet all six of the criteria to be considered qualifying and within the scope of SSAP 37. The changes are effective January 1, 2027, with early adoption permitted. Industry representatives supported the changes.
- Ref #2025-19, which updates disclosures for private placement securities effective year-end 2026 (note that the working group did not incorporate revisions proposed by interested parties). For all investments in scope, companies will be required to identify whether each investment is (1) publicly registered; (2) a private placement under rule 144A; (3) a private placement security, or (4) N/A (e.g., a bank loan or long-term CD). Companies must report annually on an aggregated basis each type of investment, the total amount of aggregate deferred interest and payment-in-kind (PIK) interest, and the total book/adjusted carrying value (BACV) supported by private letter ratings. Expect a Blanks proposal to be exposed via Chair exposure shortly after the National Meeting.
- Ref #2024-21, which eliminates the investment subsidiaries concept from financial statement instructions, effective December 31, 2026. The Blanks Working Group has already exposed a proposal to effectuate this change.
- Ref #2025-18, which adopts with modification ASU 2019-12, Simplifying the Accounting for Income Taxes.
- Ref #2025-20, which makes several revisions to the reporting of debt securities to make debt security reporting consistent across SSAPs: (1) provides new residual disclosure to identify the company’s measurement method; (2) expands the existing SSAP No. 26 and SSAP No. 43 disclosure on bond sale proceeds and the resulting realized gain or loss to be a statutory data-captured disclosure; (3) clarifies the reporting requirements for the bonds by maturity date disclosure—additionally, a comparative summary disclosure was added to SSAP No. 21 for non-bond debt securities; (4) revises the disclosure of impaired securities (when fair value is less than the amortized cost) to be consistently included in the statutory financial statements for all debt securities with a data-captured template—it also adds clarity as to what shall be captured in this disclosure (all impaired securities regardless of measurement method) has also been incorporated; (5) in the annual statement instructions and template, expands the disclosure for bifurcated other-than-temporary impairment to include non-bond debt securities as well as residual interests that follow the allowable earned yield method; and (6) incorporates disclosures for residuals in the scope of SSAP No. 21 to be consistent with other invested asset disclosures.
- Ref #2025-21, which clarifies that assets held at net asset value (NAV) shall be included in the required fair value disclosure.
1. Negative IMR items (Ref #2025-22 and 2025-23): The ad hoc group working on negative IMR issues continues to meet weekly as it develops a long-term solution to the admittance of net negative IMR.
- The first item discusses how IMR derecognized by a ceding company should be reflected in determining the amount of reinsurance collateral required to receive credit for reinsurance. There is no current mention of derecognized net negative IMR in the existing SSAP 61 for collateral requirements, and there was no consensus amongst the ad hoc group on how this should be treated. Some industry representatives have advocated for symmetrical treatment (derecognized positive IMR increases the collateral requirement; derecognized negative IMR would decrease the collateral requirement). NAIC staff suggested an asymmetrical approach (where derecognized positive IMR would increase collateral requirements, but a derecognized negative IMR would not decrease the collateral requirement).
- The second item provides guidance on the proof of reinvestment that is required for a company to recognize net negative IMR. A company would be required to complete and pass both tests (reinvestment and weighted average yield) to move to a net negative IMR balance (from a prior positive IMR position) or increase a prior year’s net negative IMR balance. The proposal contains charts to make it easier for companies to implement the proposed guidance.
3. A new item related to separate account non-admitted assets (Ref #2025-25). This item would incorporate the concept of non-admitted assets within the separate account balance sheet and corresponding schedules. Revisions are proposed to be effective January 1, 2027. A corresponding blanks proposal will follow.
4. A new item for SSAP 48 equity changes (Ref #2025-26). This item is extremely detailed and contains several areas where NAIC staff is requesting feedback related to SSAP 48 – Joint Ventures, Partnerships and Limited Liability Companies investments. The item proposes a review of several SSAP 48 concepts and how they are applied, to ensure guidance is clear and consistently applied. Specifically, the proposal requests feedback on:
- The timing of recognition of equity value increases/decreases
- The application of the goodwill guidance (positive and negative) and if there is adequate reporting on Schedule BA to identify goodwill impact
- The lack of SSAP 68 disclosures involving goodwill for SSAP 48 investments and whether goodwill from these acquisitions should be captured
- What generates negative investment income and information on what causes an unrealized loss reporting dynamic
- How related party codes are being used—NAIC staff highlighted situations where the entity has a significant majority ownership and reports the investment as a 6 (No Related Party Relationship)
6. Clarification to the guidance requiring non-admittance of long-term repurchase and reverse repurchase transactions (Ref #2025-28).
7. Clarifying changes related to the implementation of the principles-based bond definition (Ref #2025-29).
8. Changes to INT 05-05: Accounting for Revenues Under Medicare Part D Coverage to replace references to the CMS Coverage Gap Discount Program with the CMS Manufacturer Discount Program. The Coverage Gap Discount Program ended as of December 31, 2024, and has been replaced by the Manufacturer Discount Program (Ref #2025-31).
9. Clarifying changes related to Administrative Services Contracts (ASC) disclosure in SSAP No 47 – Uninsured Plans and Note 18B. The main reason for this clarification is to have a result that details the net gain or loss on the ASC plans. With the exposure, NAIC staff will also prepare a Blanks proposal for simultaneous exposure (Ref #2025-30).
10. Updates to incorporate current state of play on the implementation of the Generator of Economic Scenarios and VM-22 (Ref #2025-34).
11. (Re-Exposure) Ref 2025-01, which expands revisions to SSAP No. 22 – Leases to clarify the types of transactions that can utilize sale-leaseback accounting. The proposal incorporates revisions proposed by APCIA and NAMIC clarifying that if the cash or assets received by the seller have access restrictions and do not meet the definitions found in SSAP No. 4, the restricted cash and assets are non-admitted. The edits underscore that it is the total restriction on access to cash or assets, not the mere presence of a restriction, that renders the transaction incompatible with sale accounting.
Additional Updates
- ALM Derivatives: The working group directed NAIC staff to move forward with an issue paper and concurrent SSAP to reflect statutory guidance for interest-rate hedging derivatives used for asset/liability matching (ALM) using the amortized cost approach. These items will be presented next year with a proposed effective date of January 1, 2027.
- New Schedule S, Part 8: The working group sent a memo to the Blanks Working Group addressing certain questions that NAIC staff has received related to the new Schedule S, Part 8 for funds withheld and modco assets on the life blank. The memo emphasizes that Schedule S, Part 8 was not intended to change any part of the way that assets subject to a modco or funds withheld arrangement are factored into the Life/Fraternal RBC calculation.
- Negative IMR Update: The materials contain a report from the negative IMR ad hoc group on ongoing issues, including amortization of IMR and NAIC designation changes. The working group would like to have proposals to address all outstanding negative IMR issues for consideration by the 2026 Summer National Meeting.
- FABN Proposal: The working group is prepared to receive a referral from the Macroprudential Working Group regarding funding agreement–backed securities (FABNs) following its exposure of the FABN proposal. At that time, a SAPWG and Blanks item will be exposed for comment; NAIC staff will present the proposals for an e-vote exposure as soon as possible (by the first quarter of 2026 at the latest).
- IAIS Discussion: In her report on International Association of Insurance Supervisors (IAIS) activities, Julie Gann (NAIC) noted that the IAIS Audit and Accounting Working Group recently discussed private equity investments in accounting firms and related ethical and independence considerations.
Reinsurance (E) Task Force
Wolf Alerts Task Force to PRT Efforts at LATF: Dave Wolf (NJ) reported on New Jersey’s proposal that would permit a company to modify VM-22 reinvestment guardrails for pension risk transfer (PRT) business (discussed above in the LATF summary).
Mutual Recognition of Jurisdictions Working Group Re-Approves QJs/RJs: The Mutual Recognition of Jurisdictions Working Group reported that it has reapproved the status of the seven current Qualified Jurisdictions (Bermuda, France, Germany, Ireland, Japan, Switzerland, and the UK) and the three Reciprocal Jurisdictions that are not party to a Covered Agreement with the U.S. (Bermuda, Japan, and Switzerland). The working group now reports directly to the Financial Condition Committee, which later voted to reapprove these jurisdictions.
Re-FAWG Continues to Passport Reinsurers: The Reinsurance Financial Analysis Working Group has now approved 107 Reciprocal Jurisdiction Reinsurers and 42 Certified Reinsurers for passporting; 49 states, DC, and 2 territories have now passported at least 1 reinsurer.
Reports on Other NAIC Initiatives Affecting Reinsurance: The working group received several updates regarding NAIC workstreams that touch on reinsurance issues:
- AG 55: Fred Andersen (MN) updated the task force on Actuarial Guideline (AG) 55 implementation, including the adoption of reporting templates. The first reports are due April 1, 2026, and the review process will track AG 53 reports (with the Valuation Analysis Working Group (VAWG) doing the initial review and communicating with companies through their domestic regulator).
- Cross-Border Life Reinsurance: As reported in prior meetings, the task force has held two regulator-only educational sessions on various aspects of cross-border reinsurance. According to Monica Macaluso (Chair-CA), the task force will hold additional educational sessions “and figure out next steps.” Macaluso assured stakeholders that any next step will go through the typical NAIC process and likely will require input from other NAIC groups.
- Other Topics: The task force also heard reports on the Macroprudential Working Group’s reinsurance worksheet and 13 regulatory considerations, VAWG’s review of AG 53 submissions, the E Committee’s combo reinsurance work, longevity reinsurance efforts, new reporting for modco and funds withheld arrangements, and the RBC Model Governance Task Force. No new information came out of these reports.
Third-Party Data and Models (H) Working Group
The working group exposed its draft Third-Party Data and Model Regulatory Framework until February 6 (see page 10 of the materials). The framework was developed by a drafting group of regulators from Colorado, Florida, Iowa, Vermont, and Pennsylvania. It applies across all lines of business and requires third parties to register with states if (1) they meet the definition of third party in the framework and (2) their data and/or models are used by insurers in functions with direct consumer impact (pricing, underwriting, claims, utilization review, marketing, and fraud detection). The registration process includes providing regulators with information about the data/model governance program and agreeing to allow regulatory access to certain information. The framework also allows for states to use a discretionary filing process if they wish to require a direct filing of a model/data. Once registration is approved, the models/data are available for use by insurers.
Jason Lapham (Chair-CO) emphasized that confidentiality provisions will apply to third parties the same way states apply the laws to insurers and that insurers remain fully responsible for their own compliance obligations. Interested parties seemed generally supportive of the framework but encouraged the working group to make the process more efficient (e.g., a single point of filing) and proportional to reduce burden on smaller companies.
Aggregation Method Implementation (G) Working Group (AMIWG)
AMIWG primarily discussed the timeline of its review of U.S. group solvency regulation, which will inform the final version of the Aggregation Method (AM).
U.S. Group Solvency Regulation Review: The immediate next step for AMIWG is to begin review of the U.S. group solvency system, focusing on the two areas highlighted for further work in the IAIS comparability assessment: (1) treatment of interest rate risk and (2) appropriate timing of supervisory intervention. This will include utilizing the AMIWG technical papers as reference material, primarily for work related to interest rate risk sensitivity, and reviewing existing regulatory tools to identify gaps and potential areas for refinement. AMIWG expects to complete the review in the second quarter of 2026.
Revising & Finalizing the AM: The review will inform potential changes to the AM as well as high-level recommendations for other NAIC working groups to consider if applicable. The finalization of the AM will lead to a separate document that describes the final version (similar to ICS Level 1 and 2 texts), including its use of the excess relative ratio (ERR) scalar approach and how the final AM is similar (or not) to the Group Capital Calculation (GCC). Ned Tyrrell (NAIC) acknowledged there will need to be further discussion of exactly how reporting and disclosure requirements will apply to the AM, noting the recent IAIS consultation on ICS-related ComFrame standards. The goal is for the G Committee to approve the final AM by the third quarter of 2026.
Pharmacy Benefit Management (D) Working Group
Adoption of PBM Licensure & Regulation Guidelines: In an atypical fashion for an NAIC body, the working group adopted the Guidelines document at the meeting despite taking numerous substantive amendments to the document offered by Michigan’s written comments and Iowa’s oral comments, which were not written into the draft for working group members to view before a vote at the meeting. Joylynn Fix (Chair-WV) provided initial remarks seeking to frame the Guidelines as reflective of provisions that states have already put in place as licensing standards “and related procedures,” rather than as a model law. Before the Guidelines were advanced, industry members from the Pharmaceutical Care Management Association (PCMA), Blue Cross Blue Shield Association (BCBSA), UnitedHealthcare, Cigna, Elevance, and CVS Health each gave brief remarks opposing the adoption of the document in its current form, arguing in many instances the document read like a model law, which would exceed the working group’s charges, and expressed interest in collaborating further with the working group on a future draft.
Awaiting Comments on Continued Work on PBM Examination Chapter: A brief update was given on the inaugural pharmacy benefit manager (PBM) examination handbook chapter, which was exposed for the first time on November 25, 2025. Fix expressed appreciation for a claims template provided by PBMs and stated she anticipates many edits to the document. Public comments are due January 16. After this period, the working group will meet either later in January or February to discuss next steps; it is expected that interested parties will have a brief time allotted to highlight their comments at this meeting, following NAIC convention.
State Based System (SBS) Changes to Ingest Complaints about PBMs: Susan Jennette (Co-Vice Chair-DE) provided an update on the work she is leading with West Virginia, Iowa, Oregon, and Vermont to design a new module in SBS that would be used to ingest complaints from pharmacies, pharmacists, and pharmacy services administrative organizations (PSAOs) against PBMs. The next steps are to name the fields and what regulators need to intake these complaints. Jennette is working with D Committee Chair Dean Cameron (ID) to obtain approval for the new SBS module by NAIC plenary.
Life Insurance and Annuities (A) Committee
ASWG Update: After a brief update from Commissioner Ommen (IA), the committee adopted the Annuity Suitability Working Group’s Safe Harbor Guidance and Considerations document.
Criminal History in Life Insurance Underwriting Project: Kelly Edmiston (Center for Insurance Policy and Research, or CIPR) updated the committee on CIPR’s joint study with the Society of Actuaries (SOA) regarding the use of criminal history in life insurance underwriting. The first part of the project involved a literature review, which is nearly complete. Research suggests there’s an elevated risk of mortality after release from prison, particularly in the first few weeks following release, which, according to some studies, has resulted in a mortality rate of 13 times that of the general population. CIPR noted more challenges in the second part of the project, which involves discussions with data providers (phase 1: complete), reinsurers (phase 2: in progress), and life insurers (phase 3: up next). Edmiston reported that, while some data providers and reinsurers have been willing to have conversations, there has been some general reluctance to participate. At Edmiston’s request, Commissioner Fowler (AL) agreed to send insurers a letter (drafted by CIPR) ahead of phase 3 to encourage participation. Director French (Chair-OH) suggested Edmiston work with Fowler to discuss the letter and next steps in more detail.
GOES Update: Scott O’Neal (NAIC) provided a background presentation (see page 16 of the materials) on the Generator of Economic Scenarios (GOES), project deliverables as well as updates on the Model Governance Framework discussed and adopted during the LATF meeting (see summary above).
CIPR Event
The CIPR event Supporting Consumers Through Outreach: Amplifying Public Awareness of State Insurance Departments included the following:
PIO Survey Results: Brenda Rourke (NAIC) shared key findings from a recent survey of Public Information Officers (PIOs) across 20 states and territories. The survey was initiated in response to ongoing conversations about consumer awareness aimed to identify best practices for increasing public understanding of insurance, effective communication strategies, and barriers faced by state departments in their outreach efforts. Notably, 81% of states reported having launched consumer outreach programs. Budget constraints and shifting priorities were cited as major obstacles, yet most states were eager to continue the work.
Rourke outlined best practices for successful outreach initiatives, including clear and consistent messaging (often through infographics), building trust, leveraging multiple channels, and using data to measure campaign impact. She also discussed persistent challenges such as misconceptions about agency roles, low public awareness, apathy, and difficulties in communicating through the media. The NAIC is looking to support PIOs by providing infographics and fostering collaboration with similar agencies.
Panel Discussion Overview: The panel discussion moderated by Melissa Jackson (Director of Communications, NAIC) brought together Lori Croy (Missouri), Shamus Durac (Consumer Representative), and Jeff Rohaly (DOI Consumer Advocate) to explore what the current policy environment means for consumers, providers, and payers. The panelists agreed that public understanding of state insurance departments remains limited, with most people only seeking help when they need insurance rather than proactively engaging with departments before making decisions. To address this gap, the panel stressed the importance of using data to understand consumer questions, simplifying complex insurance concepts into plain language, and maintaining consistent messaging. Enhanced face-to-face interactions, translation tools for ESL consumers, and accessible materials were highlighted as key strategies to propel communication. Panelists also discussed the value of practical outreach such as conducting post-contact surveys and running magazine ads to reach rural populations not active on social media. The discussion concluded with a reminder to focus on the needs of both insured and uninsured consumers, as valuable lessons can be learned from both groups.
Senior Issues (B) Task Force
Newly appointed National Association of Insurance & Financial Advisors (NAIFA) President Christopher Gandy presented on the lack of training for financial advisors on LTC riders in life insurance policies. Because advisors only receive 5–6 hours of LTC insurance training per year due to the decrease in enrollment in standalone LTC products as compared to 20–30 years ago, there is a gap in knowledge of how hybrid life insurance policies with LTC riders work. Gandy recommended that carriers improve both consumer and advisor education and dispel myths about how these products interact. Gandy also criticized carriers’ moves to shed toll-free numbers in favor of AI-enabled technology or social media tools.
After Vice Chair Chrystal Bartuska asked if products were uniform enough among states to merit a single explainer document, Gandy replied that he believed that material could be developed to cover “90 percent” of the market by covering the major types. Bartuska also expressed concern that regulators and consumers will be “in the same boat” with LTC riders in 15-20 years if states allow rate increases on the LTC rider itself, noting that ND does not allow rate increases on annuity products. Gandy noted a tighter process on initial underwriting would potentially curb surprise rate increases.
Risk-Based Capital Model Governance (EX) Task Force
Adoption of RBC Principles: The task force adopted the RBC principles—marking a major achievement of Commissioner Godfread’s tenure as NAIC President. The P&C trades proposed some clarifying language to the “Equal Capital for Equal Risk” principle in the last few weeks, but the task force decided against making any further substantive changes.
Updates on Other Initiatives: Following the adoption of the principles, Amnon Levy of Bridgeway Analytics (NAIC’s consultant on these efforts) provided an update on other task force initiatives and a preview of next steps. Highlights included:
- RBC Preamble: As a reminder, issues related to the use of RBC that were previously being discussed by the Capital Adequacy Task Force are now under the purview of this task force. Regulators have come to an informal consensus on two conceptual revisions to the RBC Preamble: (1) introduction of a new disclosure to be used when RBC is used for any purpose beyond its intended purpose of identifying weakly capitalized companies; and (2) a listing of considerations whenever RBC is used beyond its intended purpose. No formal exposure has been made; regulators are working on streamlining some of the existing language.
- Gap Analysis: For the first time this year, information about the NAIC’s gap analysis of the RBC framework was presented publicly. Bridgeway and the NAIC have performed an evaluation of the current RBC formulas and created an initial inventory of investment categories that feed into the formula. Any incomplete or inconsistent RBC instruction has been communicated to NAIC staff. Notably, the task force submitted a formal request to the American Academy of Actuaries requesting that the Academy work with NAIC staff and Bridgeway to work toward a more formal project plan for the gap analysis, with an initial focus on the life RBC formula. The Academy has since formed the Cross-Practice RBC Task Force to assist with this work and is working with Bridgeway to refine the analysis.
- Model Risk Management Guidelines: Bridgeway has prepared draft Model Risk Management Guidelines that contain governance concepts for analyzing RBC adjustments. The guidelines will be utilized as the NAIC works with the Academy on the gap analysis.
- Education & Public Messaging Campaign: The task force has prepared a draft deck to execute on its charge to develop an education and public messaging campaign to highlight the benefits and strengths of the RBC framework. The deck covers the NAIC and state-based system; the state regulatory toolbox; RBC; and discussion of IAIS harmonization and Aggregation Method comparability. Levy suggested that “industry stakeholders and NAIC staff find the content helpful,” but the deck itself has not been made public at this time.
Cybersecurity (H) Working Group
Revisions Expected on Portal Project Intake Form: The working group discussed the development of a Cybersecurity Event Notification Portal and heard comments on the Project Intake Form. Michael Peterson (Chair-VA) emphasized that creation of the portal would reduce the large cost imposed on industry by Section 6 of Model #668 (Insurance Data Security Model Law), and that compliance costs will be further minimized as more states adopt the Model. In response to questions raised by other regulators and industry, Peterson clarified that only states that have adopted Model #668 would have access to the portal—there is no anticipated access at this time for states with other/similar cybersecurity laws or for any external party.
Interested parties were aligned in their feedback, agreeing that the portal could create significant efficiencies but wanting more information about confidentiality, access, and associated fees. The National Association of Mutual Insurance Companies (NAMIC) questioned the reporting expectation for Section 6B of the Model, specifically referenced in the intake form. Peterson confirmed that regulators only expect high-level reporting on those items, and NAMIC requested that clarifying language be added to the form before adoption. It appears the working group will revise the Project Intake Form at NAMIC’s request and also add language regarding the security of the portal (likely making mention of NAIC SOC reporting).
Feedback Sought on Approach to Cybersecurity Insurance Report: Wanchin Chou (CT) and Koty Henry (NAIC) provided highlights from the 2025 Cybersecurity Insurance Report. Afterward, they asked regulators to consider if there is other information that should be captured in the report moving forward. The NAIC would like the report to be a more useful document and is interested in feedback to inform potential improvements.
Valuation of Securities (E) Task Force
The task force held its final meeting in its current iteration, as investment-related issues will be handled under a revised structure in 2026. Here are the highlights of task force action at the meeting:
Delayed CLO Modeling Implementation: As previewed at the Summer National Meeting, the task force approved a P&P Manual change to delay the effective date of the NAIC’s Structured Securities Group’s modeling of collateralized loan obligations (CLOs) to year-end 2026. On December 15, stakeholders received a report from the American Academy of Actuaries on its efforts to develop an alternative approach to analyzing CLO risk; the RBC Investment Risk and Evaluation Working Group may expose a structural change to the Life RBC formula to effectuate CLO-related changes at that time.
Received an Update on CRP Due Diligence & Challenge Framework: PwC, which has been hired by the NAIC to assist in the development and implementation of a due diligence framework over Credit Rating Providers (CRPs), provided an update on its work to date. The framework design is ongoing, and regulators and other stakeholders will be briefed on design decisions along the way. The framework is designed to provide a practical oversight function focused on areas where ratings have the potential to impact industry. PwC is reviewing historical information from the NAIC and issued a data call to CRPs this summer. Only one submission has been deemed complete, and PwC intends to review the information on a rolling basis. The completed draft framework will be presented to the new CRP Working Group. The next update is expected at the Spring National Meeting.
Charles Therriault provided an update on the portion of the framework that gives regulators the authority to challenge individual CRP ratings. In short, the relevant agreements and structure continue to be put in place; Therriault summed up his short update with, “We are still working on it.” We expect to see movement on this in 2026.
Adopted Grace Period for CRP Rating Annual Updates: The task force approved a P&P Manual change that gives companies a 30-day grace period to provide the Securities Valuation Office (SVO) with a CRP rating annual update.
Advanced a Security Identifier Proposal: The SVO has proposed combining Security ID fields into one field and adding a new field to identify the Security ID Type. This will allow the NAIC to integrate S&P Global’s Global Instruments Cross Reference Service (GICRS) into its systems. The SVO also recommends developing a new reporting field to clearly identify when a Security ID has not been validated on a financial statement investment schedule submission. The task force directed NAIC staff to work with industry to develop a Blanks proposal to effectuate these changes.
Executive (EX) Committee
The Executive Committee adopted a Model Law Development Request to modify the Insurance Holding Company Act to clarify states’ authority to review fees charged by reciprocal exchange attorneys-in-fact to ensure those fees are fair and reasonable. This work will be done by the newly created Reciprocal Exchanges (E) Working Group. The committee also adopted its 2026 charges, unchanged from 2025.
Antifraud (D) Task Force
LTC Added as Fraud Category Within Reporting System: The task force added LTC insurance as a category for fraud within the NAIC’s Online Fraud Reporting System. The addition was first discussed at the Summer National Meeting and met with positive feedback from stakeholders.
CAIF Presentation on AI: The Coalition Against Insurance Fraud (CAIF) gave a wide-ranging presentation on generative AI, including the results of its recent survey on the topic. Nearly all respondents from both the public and private sector are concerned about the impact of generative AI on fraud in the industry. Regulatory uncertainty on the carrier side and budget constraints and a lack of expertise on the regulator side have slowed adoption of some of these technologies. Stakeholders are seeing most of the generative AI fraud in the claims stage of the insurance life cycle.
Improper Marketing WG Update: The Improper Marketing of Health Insurance Working Group reported that they continue to meet in regulator-only sessions on various topics, including unauthorized agent transfer, open enrollment challenges, and steering issues. The group remains actively engaged with state and federal regulators.
NICB Updates: The National Insurance Crime Bureau (NICB) provided an update on its efforts to enhance its reporting forms and its data quality and usability. The NICB also highlighted fraud trends in the third-party litigation funding space. In its report summarizing key 2025 initiatives, the CAIF applauded Washington Commission Patty Kuderer’s efforts to add digital specialists and financial examiners to her fraud staff.
International Insurance Relations (G) Committee & IAIS Secretariat Q&A
The International Insurance Relations Committee meeting was immediately followed by a Q&A Session with IAIS Secretary General Jonathan Dixon. Both sessions touched on recent IAIS activity, and Dixon gave an overview of what to expect in 2026. Here are the key updates:
Next Steps on Structural Shifts in the Life Insurance Sector: Following the publication of the final Issues Paper, the IAIS has agreed on several next steps:
- Enhanced Monitoring: The IAIS will enhance its monitoring of investments in alternative assets, particularly private credit, and asset-intensive reinsurance (AIR) by incorporating both into the annual Global Monitoring Exercise to examine the issues in greater detail.
- Systemic Risk Review: Even though the Issues Paper states these trends have not resulted in systemic risk, the IAIS intends to conduct an in-depth analysis to get a more definitive view. Dixon noted that other institutions have discussed potential systemic risks in this area.
- Supervisory Guidance: The IAIS will develop supervisory guidance on addressing risks from AIR and investments in alternative assets.
- Review of Existing Standards: A review of IAIS standards will inform whether enhancements are needed to address the structural shifts, as highlighted in the Issues Paper. Dixon said we will have to “wait and see” whether the review will result in changes to the standards, but if that’s the agreed outcome, the changes will be subject to the usual consultation process.
An interested party referenced the Financial Stability Board’s (FSB’s) nonbank financial institution (NBFI) work plan and shared concern with investment in private credit and asked about the IAIS’ strategy to ensure the FSB’s analysis is done in a balanced manner. Dixon shared that the IAIS’ assessment of private credit will feed into the FSB’s analysis in this area. There is no expectation that the FSB will duplicate the work; rather, they are expected to rely on the IAIS’ work to inform their assessment.
Implementation Assessment Activity: Dixon noted that the IAIS will be busiest regarding this area of work, with a great deal of activity expected in 2026. The IAIS will launch two baseline self-assessments: (1) on the Insurance Capital Standard (ICS) (and the Aggregation Method (AM) in the United States); and (2) on the qualitative ComFrame standards, which have not yet been assessed since they were adopted in 2019 (Dixon expects a good degree of implementation by now among jurisdictions). The IAIS is also developing the ICS Implementation Assessment Methodology for use on the jurisdictional assessments that will begin in 2027.
Upcoming Deliverables
- The 2026–2027 Roadmap detailing timelines for key projects will be published in early 2026.
- Outcomes of the Holistic Framework Targeted Jurisdictional Assessment will be made public in early 2026.
- An aggregate report detailing the results of the Peer Review on ICP 13 (Reinsurance) will be completed in early 2026.
- The final Operational Resilience Objectives and Toolkit will be published in the first quarter.
- The Market Conduct Working Group is developing an Issues Paper on consumers receiving value from insurance products to be published for consultation in the Spring.
Joint Meeting of the Financial Stability (E) Task Force & Macroprudential (E) Working Group
Funding Agreement/FABN Proposal: In November 2025, the Macroprudential (E) Working Group (MWG) exposed a proposal that would require insurers to report aggregate funding agreement and funding agreement–backed notes (FABN) data on their annual statements. The ACLI requested a 45-day extension of the comment period to ensure that the proposal captures all types of issuances backed by funding agreements that regulators intend to be in the scope of the disclosure. The extension was granted, and comments are due January 26, 2026. The Blanks Working Group hopes to finalize these new requirements for year-end 2026 reporting.
LST Report Summary: NAIC staff provided a high-level summary of companies’ 2024 liquidity stress test (LST) submissions. A total of 27 groups were required to make LST submissions (up 2 from the previous year). Similar to last year’s results, the largest asset sales emanated from the investment grade corporate bonds and U.S. Treasury and Agency bond categories. The comparison to market data showed there should be no material impact on the capital markets from insurers’ potential sales of these two asset classes.
LST Framework Exposed: The MWG voted to expose the 2025 LST framework for a 45-day comment period ending January 26, 2026. No material updates were made to the 2024 framework, but the MWG does plan to review the document in the second quarter of 2026 with a focus on the liability assumptions included in the framework.
MWG Regulatory Considerations: The table providing status updates on the MWG’s 13 Regulatory Considerations (originally the “private equity considerations”) was updated in November 2025. Of note, the MWG will continue its heightened monitoring of cross-border reinsurance. When year-end data is available, the working group will again run and assess exposures by type of reinsurance, assuming jurisdiction, product types ceded, and affiliated transactions. The November update suggests the regulators are wrapping up confidential discussions with industry on this topic and “will consider further work and/or referrals” when the discussions conclude.
Macroprudential Risk Assessment: NAIC staff has updated all the key risk indicators for the Macroprudential Risk Dashboard (which is a regulator-only tool). The public macroprudential report is being updated and will be issued upon approval of the working group—likely in the first quarter of 2026.
VAWG Update: Fred Andersen (MN) provided an update on Actuarial Guideline (AG) 53 reviews similar to the report he gave to the LATF, highlighting a focus on certain company assumptions related to non-traditional assets and policyholder behavior. He also previewed how the Valuation Analysis Working Group (VAWG) will interact with the newly created Invested Assets Working Group (InvAWG)—with the former taking the lead on issues that have more of an actuarial component and the latter taking the lead on investment-heavy issues. Several regulators will sit on both groups.
Financial Condition (E) Committee
Adoption of Restructuring Mechanisms Documents: After years of work at the working group level, the committee adopted a white paper and best practices document related to restructuring mechanisms (namely corporate divisions and insurance business transfers). Since the documents were adopted at the working group, Bob Wake (ME) proposed a few changes to the white paper to clarify that restructuring mechanisms are not limited to personal lines. The committee was comfortable with these changes.
Adoption of Combo Reinsurance Proposal: Following several discussions since the Summer National Meeting, the committee adopted revised guidance regarding the treatment of combo reinsurance arrangements (those with a coinsurance and yearly renewable term (YRT) component). The revisions to SSAP 61R provide that for purposes of evaluating risk transfer, the YRT and coinsurance components of a combo reinsurance arrangement should be evaluated individually and together to satisfy risk transfer. When evaluated in its entirety, such contract(s) cannot (1) potentially deprive the ceding insurer of surplus at the reinsurer’s option or automatically upon the occurrence of some event; (2) potentially require payments to the reinsurer for amounts other than the income realized from the reinsured policies; or (3) contain any of the other conditions prohibited by Appendix A-791 related to risk transfer. The revised guidance will become effective for new contracts immediately and for existing contracts beginning with year-end 2026 reporting.
Commissioners Brown (TX) and Ommen (IA) suggested that the Statutory Accounting Principles Working Group hold additional educational sessions on these types of transactions and the concepts outlined in the ACLI’s comment letter, emphasizing that this will be most useful for those states that do not allow permitted practices.
Reapproval of Qualified & Reciprocal Jurisdictions: The committee reapproved the list of 7 Qualified Jurisdictions (Bermuda, France, Germany, Ireland, Japan, Switzerland, and the UK) and 3 Reciprocal Jurisdictions that are not party to a Covered Agreement with the U.S. (Bermuda, Japan, and Switzerland). A memo summarizing NAIC staff’s analysis and ongoing due diligence review of these jurisdictions is included in Attachment 12 of the Meeting Materials. The committee also reapproved the Canada Office of the Superintendent of Financial Institutions (OSFI) as a jurisdiction that recognizes and accepts the U.S. approach to group capital calculation.
No Comments on CLO Timeline: Commissioner Houdek (Chair-WI) opened the floor for informal feedback on the proposed 2026 timelines for activity related to the treatment of collateralized loan obligations (CLOs), but no stakeholders made comments.
Technical Changes Head to Commissioners: As always, technical financial items coming out of the committee’s working groups and task forces were compiled and sent to commissioners shortly after the conclusion of the National Meeting. Commissioners had 10 days to object to any particular workstream; if no objections were raised, the items were considered effective immediately.
Market Regulation and Consumer Affairs (D) Committee
MAWG Update: The Market Actions Working Group (MAWG) will host quarterly Chief Market Regulator Forum (CMRF) discussions beginning in 2026 to develop focus areas. In the long term, MAWG intends to explore modernization of analysis techniques, such as using digital data visualization tools. In addition to those substantive items, MAWG is seeking to improve geographic balance in its membership, which is currently Midwest- and Northeast-leaning.
Cybersecurity Incident Response Framework: The purpose of the Cybersecurity Incident Response Framework is to assist NAIC members in assessing the significance of cybersecurity events and include protocols for multistate coordination after a cybersecurity event. The Market Conduct Examination Guidelines Working Group has formed a subject matter expert group to create an initial draft of the framework. The framework will build upon the current Cybersecurity Event Response Plan, published by the Cybersecurity Working Group, which focused on individual state response. The Market Conduct Examination Guidelines Working Group anticipates exposing an initial draft of the framework in the first quarter of 2026.
Producer Licensing Issues
- NAIC Consumer Agent/Broker Search Tool: The committee continues to work on creating a tool (similar to FINRA’s BrokerCheck tool) for consumers to determine if an agent is appropriately licensed. The next update will be at the 2026 Spring National Meeting.
- Template for 1033 Written Consent Process: Larry Deiter (Chair of the Producer Licensing Task Force-SD) noted that the template for 1033 written consent requires further revision and is not ready for adoption. Deiter anticipates the template will be ready for adoption at the 2026 Spring National Meeting.
PBM Working Group: The committee invited industry members to send recommendations for substantive changes to the Draft Pharmacy Benefit Manager (PBM) Licensure and Regulation Guidelines for Regulators document. The committee is tentatively aiming to adopt the guidelines at the 2026 Spring National Meeting.
MAPWG: The Market Analysis Procedures Working Group (MAPWG) is seeking to engage experts to modernize the Market Analysis Prioritization Tool. It plans to work with NAIC staff to draft a project proposal, which it will share for the committee’s consideration at the Spring National Meeting.
Health Insurance and Managed Care (B) Committee
Approval of Prior Authorization White Paper: The committee meeting adopted many workstream reports and unanimously approved the final version of the prior authorization white paper developed under the auspices of the Regulatory Framework (B) Task Force (RFTF). Commissioner Arnold (Co-Vice Chair-MN and Chair of RFTF) noted that the task force likely will explore having a dynamic repository of new prior authorization laws and regulations for states to reference to complement the static case examples described in the white paper; it is unclear if this will be made public.
Presentations & Discussion on Health of the Individual Market: The remainder of the meeting was largely centered on hearing external speakers’ take on the individual market, for which Exchange enrollment is expected to decline by 4 million, with an average 26% gross premium increase.
- Introduced by the consumer representatives, Sabrina Corlette of Georgetown’s Center on Health Insurance Reforms presented a set of mitigation strategies for states to adopt, such as the Basic Health Program, state-funded financial help (“subsidy wraps”), and “sludge audits” to identify and take action to remove consumer “pain points” in the enrollment process to facilitate the most optimal plan for the enrollee. Corlette also identified stronger market oversight of non–ACA compliant products.
- CMS-CCIIO Director Peter Nelson noted that the annual Notice of Benefit and Payment Parameters proposed rule had been delayed due to the government shutdown but added that CMS remains committed to individual coverage health reimbursement arrangements (ICHRAs).
- Wakely Consulting Group’s Michael Cohen and Michelle Anderson discussed the unprecedented morbidity and utilization trends and policy changes to come, summing up 2026 as “somewhere between concerning and uncertain.” They recommended states look more granularly at early 2026 claims and experience data to understand the market going into 2027 rate setting. (During the earlier Health Actuarial Task Force meeting, CMS indicated it plans to keep the “original” rate setting and certification timeline for 2027.) Committee members from ID and UT attempted to pin down why Wakely observes higher morbidity and claims costs in federally facilitated exchanges as compared to state-based exchanges, though Cohen offered a few hypotheses without providing conclusions. At the end of the discussion, there was some interest expressed by regulators in developing a uniform template for issuers to report and potentially for Wakely to analyze to facilitate an apples-to-apples review of the markets, with Commissioner Mulready (Chair-OK) suggesting that committee leadership next year consider seeking answers to why certain markets or states have variations to inform state policymaking.
Innovation, Cybersecurity, and Technology (H) Committee
The committee received reports from the Big Data and Artificial Intelligence Working Group, the Cybersecurity Working Group, and the Third-Party Data and Model Working Group, all of which are reported above. In addition, Lori Munn (AZ) briefly reported on CLARA, an AI tool under development at the SupTech/GovTech Subgroup that regulators hope to pilot in connection with SERFF. Colton Schulz (ND) briefly reported on the Data Call Study Group’s efforts to compile a list of market data points for potential data calls. The Privacy Protections Working Group requested and received a one-year extension to complete its work on the Privacy of Consumer Financial and Health Information Regulation. Finally, the committee heard a presentation from Conning on the surge of insurer adoption of AI.
Joint Meeting of Executive (EX) Committee and Plenary followed by 2026 Officer Election
Wise Elected Secretary-Treasurer: South Carolina Director Michael Wise was elected Secretary-Treasurer for 2026. In the normal course, he will serve as NAIC President in 2029.
Zone Officer Election Results: Zone officer election results were also announced. A commissioner elected as a zone officer also sits on the NAIC Executive Committee. Results for Chair, Vice-Chair, and Secretary were (new officers for 2026 in italics):
- Midwest: Dunning (NE); Dieter (SD); Gillespie (IL)
- Northeast: Zimmerman (NJ), Bettencourt (NH), Grant (MD)
- Southeast: Chaney (MS), King (GA), Mike Yaworsky (FL)
- Western: Lara (CA), Kuderer (WA), Gaines (NV)
- Amendments to Actuarial Guideline 49-A—The Application of the Life Illustrations Model Regulation to Policies with Index-Based Interest Sold on or After December 14, 2020
- Long-Term Care Insurance Multistate Rate Review Framework, with Washington abstaining
- Homeowners Market Data Call Template and Definitions
- Statutory Accounting Ref #2024-06: Risk Transfer Analysis on Combination Reinsurance Contracts
- 2026 Generally Recognized Expense Table
Among the general discussion items, Director Fox (MI) noted that the National Association of Attorneys General is focusing on the Presidential executive order (at the time potential, but now signed) purporting to preempt state AI regulation, and suggested her colleagues consider weighing in with their respective Attorneys General.
All committee reports from the National Meeting and the 2026 NAIC proposed committee charges were adopted.
And finally, Commissioner Houdek (WI), Co-Chair of the RBC Model Governance Task Force, clarified that the task force adopted “Option 1” of the RBC Principle regarding Equal Capital for Equal Risk.