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Hotel Deadline for April 2026 MPC Meeting Approaches

The deadline for reservations at the NOPSI Hotel New Orleans, the host hotel for the April MPC meeting, is March 13. After that date, the hotel cannot guarantee the NOLHGA rate of $216/night plus tax. The room block could sell out earlier than that, so we encourage everyone to book their rooms as soon as possible.

Attendees can make hotel reservations and register for the meeting at the MPC 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.

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 McKenna

Assessable Premium Exhibit Guidance Update on Stable Value Contract Principles Now Available—Filing Due April 1

The Assessable Premium Exhibit (APE) Guidance Working Group, including both guaranty association administrators and members from industry, recently developed and approved clarifying guidance related to the treatment of Stable Value Contracts within the annual NAIC Life & Health Insurance Guaranty Association Assessable Premium Exhibit. The guidance includes key clarifying principles on:

Determining whether stable value contracts are deemed allocated or unallocated for purposes of the Exhibits
Limiting the use of Line 15 of the Exhibit to Synthetic GICs as referenced in the NAIC Annual Statement Instructions

A copy of the guidance is available on the Assessable Premium Exhibit Resources page on NOLHGA’s website. Please reach out to Lindsay Crawford if you have any questions related to the guidance.

We would like to thank APE Guidance Working Group Chair Don Sirois (Maine) and all the working group members for their time and dedication to the development of the clarifying principles.

Staff Contact - Lindsay Crawford

Illinois 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 McKenna

NAIC Updates

Emphasizing leadership, modernization, and resilience, the NAIC Recently announced its strategic priorities for 2026. Key initiatives (along with some observations) include:

Enhancing Capital & Investment Frameworks: Finalizing, adopting, and steering the implementation of a new investment and capital framework, while working “to ensure the proposed reforms are well-vetted, balanced, feasible, and harmonized among the states.” (Note: This appears to address a number of existing workstreams—RBC gap analysis, investment framework, revised charges for certain asset classes—as opposed to a new workstream.)
Enhancing Data Architecture, Predictive Analysis & Market Analysis: Deepening capabilities as a data aggregator and analytics provider. (Note: The NAIC has had longstanding goals to centralize and enhance technical support for state regulators; the priority does not explicitly reference leveraging AI.)
Increasing Resilience Through Regulation, Mitigation & Public Partnership: Closing protection gaps and strengthening disaster preparedness and recovery, including enhanced catastrophe modeling guidance and state-federal coordination to promote insurance and resilience. (Note: This priority is wide-ranging, encompassing catastrophe modeling, protection gaps, and disaster preparedness.)
Leading on AI Model Governance, Innovation Oversight & Cyber Threats: While asserting the state-based system’s primary role, the NAIC will advance a framework to address cybersecurity threats and insurers’ use of technology and data, including piloting an AI evaluation tool. (Note: This priority touches on the state-federal tension on who, how, and whether to regulate AI.)

The International Insurance Relations (G) Committee recently reviewed its comments on the International Association of Insurance Supervisors’ (IAIS’) draft revised Application Papers on recovery planning and resolution powers; the comments were largely editorial and clarifying in nature. The committee voted to incorporate NOLHGA’s and the NCIGF’s proposed additions to the Application Paper on resolution powers, preparation, and plans. Ryan Workman (NAIC) said the committee found the comments very helpful, and Rhode Island expressed strong support for their inclusion, noting the importance of highlighting the differences between the United States and other jurisdictions. Comments were due to the IAIS on February 25.

On February 17, 2026, the Big Data and AI Working Group met to continue discussing the draft AI Systems Evaluation Tool.

On the pilot: Commissioner Houdek (Chair, WI) announced the addition of Maryland and Louisiana as participating states, bringing the total to 11. Houdek also said updates on the pilot program will be provided regularly throughout the year, noting stakeholder concerns that National Meeting updates are too infrequent. The working group still intends to launch the pilot in March.
On the tool: Interested parties continued to offer suggestions that would alter the scope of the tool. Houdek reinforced that the working group wants to keep the language broad during the pilot phase, with the opportunity to narrow it based on states’ experience and feedback. In addition, there was consensus among interested parties and regulators for a coordinated and consistent approach between participating states. The working group is still accepting feedback, ideally in the form of redline changes, but intends to finalize the tool soon.

The NAIC’s Capital Markets Bureau released a primer on funding agreements and funding agreement–backed notes (FABNs) on February 16. This follows two meetings of the Macroprudential Working Group on the topic in 2025; much of the information in the primer tracks the information provided during those meetings. Notably, regulators emphasized that the current funding agreement/FABN landscape does not present a systemic risk to the industry. The report emphasizes the importance of FABN programs’ predictable liabilities—noting that they do not contain mortality or policyholder behavior risk like traditional life insurance products. The primer also highlights the evolution of these programs, outlining several of the offshoots that have developed over recent years (e.g., FABRs, FABLs, and FABCPs). Regulators are considering additional disclosures regarding funding agreements and related issuances, and the Statutory Accounting Principles and Blanks Working Groups are expected to advance this work early in 2026. Staff Contact - Sean McKenna

International Updates

On February 16, 2026, the European Insurance and Occupational Pensions Authority (EIOPA) published the first set of final reports related to the implementation of the Insurance Recovery and Resolution Directive (IRRD). The Batch 1 instruments were subject to public consultation from April to July 2025 and include a mix of Regulatory Technical Standards and Guidelines on (1) the content of preemptive recovery plans; (2) criteria for preemptive recovery planning requirements and methods to be used when determining the market shares; (3) the content of resolution plans and group resolution plans; (4) criteria for the identification of critical functions; (5) the assessment of resolvability; and (6) measures to remove impediments to resolvability and the circumstances in which each measure may be applied. NOLHGA and the NCIGF submitted comments in response to the consultation on the criteria for the identification of critical functions, objecting to suggestions that an insurance guarantee scheme (IGS) could transmit systemic risk. EIOPA declined to make any changes in response to those comments.

On February 19, the International Association of Insurance Supervisors (IAIS) hosted a public background session on its final version of the Application Paper on operational resilience objectives and toolkit, which was published on February 12. The session aimed to provide context for the development of the paper; outline its importance in supporting insurance sector resilience post-pandemic; and share the results of the recent public consultation process, including key stakeholder feedback and resulting changes to the paper.

The Application Paper is structured in two main components—objectives, which provide the basis for a high-level framework for meeting the insurance core principles (ICPs), and a toolkit, which offers a selection of practical implementation approaches for supervisors to achieve those objectives. Both components work in tandem and can be adapted to different markets and supervisory needs. The consultation process resulted in updates to clarify the role of governance, reinforce proportionality, adjust Board and senior management responsibilities, and enhance guidance on third-party risk and incident reporting. For more detail on the material changes, see the meeting slides and recording.

Looking ahead this year, IAIS will develop a member-only report on third-party risk that will define scenarios of third-party involvement in the insurance sector, survey members and stakeholders, share experience on critical function regimes and emerging trends, consider nth-party risk practices from other sectors, and discuss survey conclusions to inform the report.

Staff Contact - Sean McKenna

AI Activity

On February 18, 2026, the Treasury Department announced the conclusion of a public-private initiative aimed at strengthening cybersecurity and risk management for AI in financial services. The public Financial and Banking Information Infrastructure Committee and the private Financial Services Sector Coordinating Council partnered to form the Artificial Intelligence Executive Oversight Group (AIEOG). The AIEOG convened financial services stakeholders, including senior executives from financial institutions and federal and state regulators, to address gaps in the financial sector’s use of AI and develop tools for use in managing AI-specific cybersecurity risks, which are expected to be released by Treasury this month. The intent of the deliverables is “to help financial institutions adopt AI more confidently and securely, strengthening resilience and cybersecurity while supporting innovation across the sector.”

Staff Contact - Sean McKenna

Privacy Updates

The California Privacy Protection Agency Board released the agenda for its February 27, 2026, Board meeting. The meeting will include an update on the Delete Request and Opt-out Platform and the presentation of potential amendments to the California Consumer Privacy Act regulations to recognize tiered consent agreements and privacy-by-design concepts for consumer devices.

A new consumer privacy bill was introduced in Arizona. SB 1815 would apply to individuals or persons that individually or in concert with other individuals or persons determine the purpose and means of processing personal data (defined as “Controllers”) and persons that process personal data on behalf of a controller (defined as “Processors”), without a limitation on the amount of data that must be controlled or processed. The bill would not contain exemptions for data or entities regulated by HIPAA or the Gramm-Leach-Bliley Act (GLBA).

Staff Contact - Sean McKenna