California GA Seeks Outside Legal Counsel
The California Life & Health Insurance Guarantee Association (CLHIGA) is seeking an experienced California-barred attorney or firm to serve as outside counsel. The ideal candidate will have expertise in insurance regulation, insurer insolvencies (rehabilitations and liquidations), and guaranty association operations.
Interested parties should contact CLHIGA Executive Director Todd Thakar at [email protected] for the Outside Legal Counsel RFP package.
Staff Contact - Sean McKennaIllinois GA Seeks Outside Legal Counsel
The Illinois Life & Health Insurance Guaranty Association (ILHIGA) is seeking an experienced Illinois-barred attorney or firm to serve as outside counsel. The ideal candidate will have expertise in insurance regulation, insurer insolvencies (rehabilitations and liquidations), and guaranty association operations.
Interested parties should contact ILHIGA Executive Director Janis D. Potter at [email protected] for the Outside Legal Counsel RFP package.
Staff Contact - Sean McKennaNAIC Updates
The NAIC recently released its 2026 Committee List, which contains the committee structure and most of the committee rosters for 2026. While it is not noted on the list at this point, Wisconsin Commissioner Nathan Houdek will chair the NAIC’s Big Data and AI Working Group, taking the reins from Pennsylvania Commissioner Mike Humphreys. Houdek previously chaired the (now disbanded) Accelerated Underwriting Working Group, which developed guidance for insurance departments to use when reviewing life insurers’ use of accelerated underwriting programs.
In other NAIC news, the Life Actuarial Task Force (LATF) resumed its weekly calls on January 29, 2026, taking the following actions:
- Adopted APF 2025-15, which updates VM-20 (and by extension, VM-21 and VM-22) to reflect more granular NAIC Designation Categories. When principle-based reserving (PBR) was established, PBR credit ratings gave a more granular designation than what was used for NAIC designations; now that the more granular NAIC categories are available, the additional granularity in PBR is no longer needed.
- Exposed APF 2025-12, which clarifies certain elements of the Standard Projection Amount (SPA) in VM-22. The revisions clarify that if an Additional SPA (ASPA) is indicated and the company is not strengthening its reserves in response to the SPA result, it needs to provide support that the material drivers of the difference are due to company assumptions that can be supported based on reliable, relevant, and credible company data. These changes have been adopted by the VM-22 Subgroup but must also be adopted by the LATF to become effective. Comments are due by February 18.
- Discussed editorial revisions to the Valuation Manual.
Finally, AI activity is ramping up at the NAIC—three calls have been scheduled over the next month to advance work on the draft AI Systems Evaluation Tool and the draft Third Party Regulatory Framework:
- February 9 at 10:00 a.m. ET: Big Data and Artificial Intelligence Working Group call to discuss Exhibits B–D of the AI Systems Evaluation Tool
- February 17 at 12:00 p.m. ET: Big Data and Artificial Intelligence Working Group call to continue discussing Exhibits B–D, if needed
- February 26 at 12:00 p.m. ET: Third-Party Data and Models Working Group call to discuss comments received on the draft regulatory framework (note that comments are due February 6)
International Developments
The International Association of Insurance Supervisors (IAIS) has appointed Commissioner Scott White (VA) as the newest Executive Committee Vice Chair, replacing Andy Mais, who stepped down last year. The IAIS also named the Vice Chairs of its new committees, which became operational at the start of the year (the Chairs were appointed at the Annual Conference in November):
- Monitoring and Risk Assessment Committee: Chair – Dieter Hendrickx (National Bank of Belgium); Vice Chairs – Jörg Krause (BaFin Germany) and Marcelo Ramella (BMA)
- Standards and Supervisory Practices Committee: Co-Chairs – Commissioner Judi French (Ohio, USA) and Farzana Badat (South Africa); Vice Chairs – Paolo Cadoni (PRA UK) and Adriana Jazmin Bernal Lugo (Paraguay)
- Implementation Assessment Committee: Chair – Vicky White (PRA UK); Vice Chairs – Rashmi Sutton (NAIC) and Tony Chan (Hong Kong)
The authors suggest that because life insurers now share more characteristics with banks, there is a strong case for prudential regulation to add a systemic component to capital requirements based on each insurer's contribution to systemic risk. Staff Working Papers do not represent Bank of England policy—they are published to elicit comments and further debate; however, their conclusions could influence future regulatory initiatives.
Staff Contact - Sean McKennaPrivacy Updates
Various privacy bills continue to work their way through the legislative process:
- Illinois introduced the Illinois Consumer Data Privacy Act (SB 2875). The act applies to legal entities that conduct business in Illinois or produce products or services that are targeted to Illinois residents and that (1) during a calendar year, control or process the personal data of 100,000 or more consumers, excluding personal data controlled or processed solely for the purpose of completing a payment transaction; or (2) derive over 25% of gross revenue from the sale of personal data and process or control the personal data of 25,000 or more consumers. The act does not apply to (1) data, covered entities, or business associates under HIPAA; (2) data collected, processed, sold, or disclosed under the Gramm-Leach-Bliley Act (GLBA); or (3) insurance companies and insurance producers regulated by the Illinois Insurance Code.
- Mississippi introduced the Mississippi Consumer Privacy Protection Act (HB 1051). The act applies to persons that conduct business in Mississippi by producing products or services targeted to consumers of Mississippi that exceed $25 million in revenue and that (1) control or process the personal information of at least 25,000 consumers and derive more than 50% of gross revenue from the sale of personal information; or (2) during a calendar year, control or process the personal information of at least 175,000 consumers. The act does not apply to (1) financial institutions, affiliates thereof, or data that is subject to Title V of the GLBA; (2) a covered entity or business associate subject to HIPAA; or (3) protected health information and de-identified health care–related information under HIPAA.
- New Mexico introduced the Community and Health Information Safety and Privacy Act (SB 53). The act applies to “covered entities” defined as legal for-profit entities that offer online features, products, or services to consumers in New Mexico and, alone or jointly with others, determine the purposes and means of (1) collecting personal data directly from consumers; (2) using personal data for targeted advertising; or (3) engaging in the brokerage of personal data (provided that the covered entity does not include an entity that processes the data of 15,000 or fewer consumers annually and does not engage in the brokerage of that data). Covered entities that are in compliance with Title V of the GLBA or HIPAA are deemed to be in compliance with the act with respect to the data covered by Title V of the GLBA and HIPAA.