Registration for the April 2026 MPC Meeting Now Open
Registration for the April 2026 MPC meeting in New Orleans is now available through the meeting website. The site offers both in-person and virtual attendee registration for the meeting, which will be held on April 15–16. The agenda for the meeting will be released in early March, but we expect a full day of meetings on Wednesday the 15th and a half day (ending by noon) on Thursday the 16th.
Please note that non-members and guests will be charged a registration fee ($299 and $99, respectively) to cover meeting expenses. There is no charge for guaranty association members (Administrators, Board members, and staff) to attend the meeting.
The meeting website also offers online hotel reservations for the NOPSI Hotel New Orleans, the host hotel for the meeting. The deadline for reservations at the NOLHGA rate of $216/night plus tax is March 13. The room block could sell out earlier than that, so we encourage everyone to book their rooms as soon as possible.
If you have any questions about the April MPC meeting, please contact Jenn Webb or Sean McKenna. If you have any trouble accessing the meeting website, please contact Dan Hicks.
Staff Contact - Sean McKennaCalifornia 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 McKennaFederal Updates
On February 4, 2026, the House Financial Services Committee (HFSC) heard from Treasury Secretary Bessent on the Annual Report of the Financial Stability Oversight Council (FSOC). Key points from the Secretary’s remarks included:
- Secretary Bessent supported the activities-based approach to systemic risk regulation and said a new proposal for nonbank guidance is expected this year.
- Secretary Bessent said FSOC is working to promote the responsible use of AI and is working with international counterparts to enhance system resilience and monitor risks. A few members urged FSOC to investigate the growing financial stability risks associated with the “AI bubble,” referring to letters sent by House Democrats last year (and Senate Democrats early this year) on the topic. Others questioned the Secretary on what steps are being taken to prevent discrimination caused by AI, noting that those concerns were raised in the 2024 Annual Report but absent from the 2025 report. Bessent is expected to respond in writing.
- Secretary Bessent appeared supportive of increasing FDIC insurance limits on non-interest-bearing transaction accounts to create a level playing field for smaller institutions.
EIOPA Outlines Approach to Insurance Guarantee Schemes
In its February 4, 2026, public stakeholder workshop (attended by more than 300 participants), the European Insurance and Occupational Pensions Authority (EIOPA) outlined its approach to developing advice to the European Commission on whether the EU should adopt minimum common rules for Insurance Guarantee Schemes (IGSs). EIOPA emphasized that IGS harmonization has long been a priority and that its current work is being driven in part by the EU’s adoption of the Insurance Recovery and Resolution Directive (IRRD), which entered into force in January 2025 and will apply beginning in January 2027. EIOPA stressed that this project is not a blank slate but rather a targeted update to its 2020 Opinion supporting IGS harmonization, focusing on areas not previously addressed in detail and on new issues emerging from the IRRD framework.
EIOPA identified four major policy workstreams for its advice: (1) the potential market and consumer impacts of harmonized IGS coverage (including whether coverage should be broad or targeted and the extent to which cross-subsidization between life and non-life insurers is desirable); (2) the interaction between IGSs and the IRRD, including institutional design questions and how IGSs might absorb losses or support resolution tools; (3) funding design, including the tradeoffs between ex-ante, ex-post, and hybrid models and the need for credible liquidity backstops; and (4) operational harmonization issues such as activation triggers, payout timelines, continuation of policies, and the priority status of IGS subrogation claims in insolvency. EIOPA repeatedly flagged that inconsistent national approaches in these areas may undermine level playing field objectives and result in unequal consumer protection across the EU.
EIOPA plans to gather stakeholder input through an immediate public survey (open until February 27, 2026), followed by a formal public consultation on draft advice in the second quarter of 2026, with final advice to be submitted to the European Commission by the end of August 2026. For U.S. guaranty association stakeholders, the presentation underscores a clear European trajectory toward embedding IGSs more explicitly into the broader crisis management framework, including potential roles not only in liquidation-style pay-outs but also in resolution-related tools such as portfolio transfers, bridge undertakings, and solvent run-off mechanisms.
Staff Contact - Sean McKennaNAIC Updates
As the NAIC builds out its committee lists, certain groups have started their 2026 activity. Two noteworthy calls were scheduled for the coming weeks.
Life RBC Working Group (February 10): The working group planned to receive comments on the conceptual Collateral Loans proposal and hear an update on the C-3 Field Test Survey results. Notably, in voicing its support of the collateral loan proposal, the Iowa Insurance Division suggests that “the Collateral Loan asset type is the most easily exploited asset class for capital arbitrage.” Several industry participants called for a delay in the effective date to ensure a more deliberative process, noting that there is no industry-wide risk or immediate solvency concern related to collateral loan holdings. The working group also will consider exposure of Item 2026-02-L BA, which would afford unaffiliated BA residential mortgages in good standing with a risk charge of 0.0068 (the same as affiliated BA residential mortgages).
RBC Investment Risk and Evaluation Working Group (March 2): The American Academy of Actuaries (Academy) will provide an update on its collateralized loan obligation (CLO) project, and the working group will discuss comments on its RBC structural proposal for CLOs.
In other news, the NAIC has asked its Financial Stability Task Force and Macroprudential Working Group members to vote on whether to refer a revised Funding Agreement disclosure proposal to the Statutory Accounting Principles Working Group and Blanks Working Group. The initial proposal related solely to Funding Agreement–Backed Notes (FABNs). The revised proposal incorporates the ACLI’s proposed changes to the initial version and now includes five new categories for disclosure:
- Funding Agreement–Backed Commercial Paper (FABCP)
- Funding Agreement–Backed Repurchase Agreements (FABRs)
- Funding Agreement–Backed Loans (FABLs)
- Funding Agreements Backing Muni Prepay Structures
- Other Funding Agreements Backing SPV Issuances
The International Insurance Relations (G) Committee has discussed and approved its comments on the following consultations.
IAIS ICS-related ComFrame Standards: In addition to minor clarifying comments, the NAIC encouraged the International Association of Insurance Supervisors (IAIS) to review the proposed public disclosure requirements to ensure they are fit for purpose, raising concerns that the level of detail required publicly is too granular and could overwhelm or mislead stakeholders. The ACLI and Louisiana asked the committee to incorporate a comment related to the importance of preserving confidentiality, which Ryan Workman (NAIC) agreed to include before submitting the comments to the IAIS.
FSB Scope of Insurers Subject to the Recovery and Resolution Planning Requirements in the FSB Key Attributes: A few of the NAIC’s substantive comments to the Financial Stability Board (FSB) include (1) recognition that the criteria are helpful but jurisdictions should have the flexibility to decide whether to set thresholds; (2) opposition to the revised definition of “critical function” because it could broaden the scope of what is considered a critical function, resulting in increased resolution-planning burdens and stretched supervisory resources; and (3) a recommendation to define the terms “financial system” and “real economy.” The ACLI supported the comment letter but encouraged the NAIC to underscore the differences between insurers and banks, raising concerns with how the consultation discusses hedging and reinsurance.
Director Dunning (Chair, NE) closed the meeting with a brief update on the activities of the Aggregation Method Implementation Working Group (AMIWG). AMIWG, newly led this year by Rebecca Easland (Chair, WI) and John Rehagen (Vice Chair, MO), is working on its review of U.S. group solvency regulation, and Dunning forecasted a busy year for the working group.
On February 5, the Life Actuarial Task Force (LATF) spent most of its call discussing New Jersey’s PRT Reinvestment Guardrail Proposal, which would allow a company to modify VM-22 investment guardrails for pension risk transfer (PRT) business while maintaining an appropriate level of conservatism (for example, a reinvestment guardrail based on BBB plus a spread increase of 50 basis points to account for illiquidity spreads).
At the outset, Rachel Hemphill (Chair, TX) noted that many LATF members have not yet formed a definitive view on the proposal and that no consensus has emerged among those that have. She outlined several issues LATF is evaluating to determine next steps (and has circulated to members for input), including (1) the appropriate scope of the proposal and whether it should be limited to PRT or expanded to other blocks with similar characteristics; (2) the reinvestment guardrail and whether states are open to revising it; (3) whether changes are warranted to the prescribed company run assumptions; (4) if so, what those changes should be; and (5) whether there is flexibility to loosen the maximum net spread adjustment factor for starting assets.
Both the American Academy of Actuaries and the ACLI advocated for the guardrail to apply to other blocks of business with similar risk profiles. Seong-min Eom (NJ) explained the desire to limit the proposal to PRT is not solely due to its characteristics but also because of the controlled governance of asset allocation. Fred Andersen (MN) agreed on starting with PRT, primarily because VM-22 is likely to result in reserve reductions and he believes regulators should get a better sense of that before moving forward with further reserve reductions beyond PRT. On the other hand, Mike Yanacheak (IA) and Tomasz Serbinowski (UT) were concerned with that approach because not all PRTs are alike—some blocks have very limited or no liquidity provisions, and the proposal presupposes they’re all the same.
Bruce Friedland (Academy) said it may not be appropriate to apply a fixed illiquidity spread for all PRT business because of material differences in companies’ risk profiles, asset portfolios, and hedging strategies. He further explained that the realization of the illiquidity spread depends on the interaction between the insurer’s liabilities, supporting assets, and ALM strategy. Essentially, the spread could vary, but there should be justification for how it is determined. Eom said the Academy’s views are consistent with the proposal and that New Jersey views the 50 basis points as the maximum number. Hemphill tasked the Academy with drafting principles to be considered when applying the additional liquidity spread.
It was decided that Eom will draft an APF for consideration based on the discussion and member views, and the Academy will separately work on draft principles for when the illiquidity spread should be applied; both will be discussed and exposed at the Spring National Meeting.
The LATF also discussed APF 2023-10, which is the Academy’s proposal to modify the discount rate used to calculate scenario reserves within the VM-20 Stochastic Reserve. The ACLI is generally supportive but recommended revisions to make the language consistent with VM-21. The ACLI and the Academy will work on a revised APF to be considered at the Spring National Meeting. Finally, changes to the VM-21 and VM-22 Annual/Quarterly Statement Blanks and Instructions that are needed for 2026 reporting were exposed until February 25.
On February 2, the Market Conduct Annual Statement (MCAS) Blanks Working Group continued discussions on the Long-Term Care (LTC) MCAS Blank. Under the LTC General Information section, trade groups had the following comments:
- Proposed Additions to Question 20: America’s Health Insurance Plans (AHIP) raised concerns surrounding the number of applications due to system capabilities and where data is stored.
- Proposed Additions to Question 22: The ACLI said that the questions related to the number of policies terminated are not clear enough.
- Proposed Additions to Question 30: The ACLI commented on the addition of the number of adverse determinations overturned and upheld, noting that these would require extensive manual labor for companies to compile annually.
International Developments
The Financial Stability Board (FSB) published its 2026 Work Programme on February 3, 2026, highlighting efforts related to the following:
- Crisis Preparedness & Resolution: In addition to supporting efforts to enhance the operationalization of resolution tools, the FSB will conduct a strategic review of crisis preparedness activities to ensure they are aligned with emerging priorities and challenges.
- Vulnerabilities Assessments: The FSB is developing a report on vulnerabilities in private credit to be published in May. Additional activity includes possible work on foreign exchange derivative markets or private finance, and enhancements to the FSB’s approach to assessing vulnerabilities (relatedly, the FSB published a report last week on Vulnerabilities in Government Bond-backed Repo Markets).
- Nonbank Financial Intermediation: New work includes improvements to the methodologies used to assess NBFI vulnerabilities and efforts to address identified data issues. The FSB will also follow up on its previous work related to money market funds, open-ended funds, nonbank leverage, and over-the-counter (OTC) derivatives.
- Artificial Intelligence: A report on sound practices for AI adoption, use, and innovation by financial institutions is expected in October. This work will be done in close coordination with other standard-setting bodies.
- Regulatory & Supervisory Modernization: The FSB will conduct a survey of member initiatives regarding whether their respective regulatory and supervisory policies can withstand changes in the financial system and facilitate economic growth. The survey findings will inform future FSB work. A symposium on regulatory and supervisory modernization issues will be held in June.
- Implementation Monitoring: In October, the FSB will publish its final implementation monitoring review report and a thematic peer review on public sector backstop funding mechanisms. The FSB will also begin phase two of the 15-year review of implementation of post-GFC (Great Financial Crisis) FSB recommendations and consider whether there are patterns related to non-implementation of certain recommendations.
The work programme also indicates that the FSB’s Annual Report is now expected in March (delayed from its typical year-end publication).
The Association of British Insurers (ABI) convened in London on February 3 for its 2026 Annual Conference. The sessions focused on top-of-mind insurance issues including artificial intelligence, UK regulatory reforms, pensions, and protection gaps. Here are the key takeaways:
Artificial Intelligence: AI and automation are reshaping the insurance landscape, with discussions highlighting their role in improving operational efficiency, risk modeling, fraud detection, and customer experience. Speakers also addressed new and increasing threats regarding cyber risk, including deepfake-enabled attacks and AI-driven business email breaches, emphasizing the need for robust incident response plans and ongoing preparedness through war gaming and scenario testing.
UK Regulatory Reforms: The Financial Conduct Authority’s (FCA) Deputy Chief Executive outlined a transition to outcomes-focused and proportionate regulation, including the introduction of annual market reports to replace the traditional “Dear CEO” letters and targeted data collection aligned with differentiated supervisory intensity based on firm conduct. The FCA emphasized supporting innovation through its AI lab, regulatory sandboxes, and new scale-up unit, and encouraged greater insurance sector participation in these initiatives. The FCA announced that in the first half of the year, it will consult on changes to the scope and application of the regulation on Consumer Duty to reduce duplication, keep requirements lean, and clarify its approach to removing businesses with non-UK consumers from scope, as well as review how wider conduct expectations for insurers apply internationally. Firms were urged to engage early and often with the FCA to receive practical support and regulatory clarity for innovation and growth.
Pensions: Workplace pensions, especially defined contribution schemes, are increasingly allowed to invest in UK private markets and infrastructure. Panels emphasized the need for robust pipelines, diversified investment vehicles, and collaborative partnerships between government, pension funds, and institutional investors to unlock growth. Policy stability and practical enablers were highlighted as more effective than asset allocation mandates for fostering sustainable investment.
Closing the Protection Gap: Millions of UK households remain without adequate financial protection, with only about 30% of UK adults holding protection products and nearly 60% of those who don’t hold them having never considered needing them. Persistent barriers include adviser shortages, product complexity, friction in accessing/understanding policies, and insufficient support for vulnerable groups. The FCA and industry called for more consumer prompts, simplified products, and regulatory collaboration to encourage innovation and widen access, especially for self-employed and gig workers.
On February 3, the European Insurance and Occupational Pensions Authority (EIOPA) launched a consultation on its Supervisory Statement on the authorization and ongoing supervision of (re-)insurance undertakings related to private equity. EIOPA and national supervisory authorities have identified the following risks and supervisory challenges stemming from private equity firms (totally or partially) acquiring European insurers and reinsurers:
- Short or misaligned investment horizons that may be conflicting with long-term policyholder commitments
- Significant changes in business models, such as use of private credit, illiquid assets, and balance-sheet optimization
- Increased reliance on reinsurance, especially from reinsurers (in some cases belonging to the same private equity group) located in third-countries
- Complex ownership structures that may hinder effective supervision
Privacy Updates
New privacy-related bills were introduced in California and Vermont:
- California SB 923 amends the California Consumer Privacy Act (CCPA) to expand consumers’ right to delete all personal information a business holds on an individual, rather than just personal information the business collected directly from the consumer. In addition, CalPrivacy announced Sabrina Ross, former director of public policy at Meta Platforms Inc., as the inaugural head of the agency’s new Audits Division. The Audits Division is tasked with obtaining and analyzing privacy and technology records to determine whether businesses are adhering to the requirements of the CCPA.
- The Vermont Duty of Loyalty Act (HB 812) applies to “covered entities” defined as persons “other than an individual acting in a noncommercial context, that alone or jointly with others determines the purposes and means of collecting, processing, or transferring covered data.” Covered data means “information, including derived data and unique identifiers, that identifies or is linked or reasonably linkable, alone or in combination with other information, to an individual or a device that identifies or is linked or reasonably linkable to an individual.” The bill applies a duty of loyalty to covered entities that prohibits the collection, processing, and transfer of “covered data in a way that conflicts with the best interests of trusting parties” and the designation or implementation of an “information technology in a way that conflicts with the best interests of trusting parties.” Entities subject to HITECH or Title V of the Gramm-Leach-Bliley Act (GLBA) are deemed to be in compliance with the requirements of the bill.