MPC Meets in Bonita Springs

The Members’ Participation Council (MPC) held a meeting on January 22–23, 2026, in Bonita Springs, Florida, and online. The two-part MPC General Session featured:

• Comments from NOLHGA Chair John Deitelbaum, who praised the two educational sessions held at the meeting (see below) and also highlighted the outstanding work of the Global Bankers, SHIP, and PHL Variable Insurance Company Task Forces.
  
• The MPC Chair Report, during which MPC Chair Amanda Barbera (Indiana) reviewed the suggestions for 2026 education topics received during the MPC Executive Committee meeting, previewed the State GA Board Chairs Conference that will be held in July, and encouraged the members to focus on working together as the system meets the challenges before it.
  
• The NOLHGA Management Report, in which NOLHGA President Katie Wade updated attendees on progress made in NOLHGA’s workstreams to implement the Vision 2027 strategic plan, including plans to continue to bolster NOLHGA’s operational effectiveness.
  
• An update on AssessConnect’s company database and assessment services platforms (one of the strategic plan workstreams) and development plans for 2026 by NOLHGA Chief of Staff Jenn Webb.
  
• Closed-session presentations by the task forces for Global Bankers Insurance Group (North Carolina), Senior Health Insurance Company of Pennsylvania (SHIP), and PHL Variable Insurance Company (Connecticut).

The MPC meeting also featured:

• A meeting of the MPC Executive Committee.
  
• A closed-session meeting of the PHL Variable Insurance Company (Connecticut) Task Force.
  
• Variable Products 101, an educational presentation conducted by moderators Tom Sullivan (Iowa) and Jenn Webb (NOLHGA) and panelists Brandon Considine (Lincoln Financial), Michael Ramirez (John Hancock), and Sam Watts (Protective Life).
  
• Assumption Reinsurance, an educational session conducted by moderator Pamela Epp Olsen (Minnesota, Nebraska, and New Mexico) and panelists Charles Gullickson (South Dakota), Lindsay Crawford (NOLHGA), and Ralph Donato (illumifin).
  
• IT support sessions conducted by Jaime Sanchez, NOLHGA’s IT Operations Manager.

  Staff Contact - Sean McKenna

McCarran-Ferguson Restoration Act Introduced

On January 6, 2026, Rep. Troy Downing (R-MT) introduced the McCarran-Ferguson Restoration Act with broad stakeholder support, including the NAIC, American Property Casualty Insurance Association (APCIA), Association for Independent Insurance Agents (the Big “I”), and National Association of Mutual Insurance Companies (NAMIC). There are three core components to the bill.

First, the bill would abolish the Federal Insurance Office (FIO) and FIO Director position and replace it with a United States Insurance Representative (USIR) inside the Treasury Department. Previous FIO elimination efforts raised the question of where Treasury’s insurance analysis would take place without FIO.

Second, the bill would selectively transfer some FIO functions to the USIR, while eliminating others:

• The USIR would replace FIO’s role in covered agreements, administration of the Terrorism Risk Insurance Act (TRIA), orderly liquidation recommendations, international engagement, and general insurance advice to the Secretary of the Treasury.
  
• FIO roles to be eliminated would include identifying state regulatory gaps for systemic risk, monitoring access to insurance for underserved communities, and data collection (eliminating FIO’s subpoena powers).

Finally, on the Financial Stability Oversight Council, the bill would change the state insurance regulator representative into a voting member appointed by the President in consultation with the NAIC.

  Staff Contact - Sean McKenna

NAIC Updates

The NAIC’s International Insurance Relations (G) Committee circulated its proposed comments on the International Association of Insurance Supervisors’ (IAIS’) draft ICS-related ComFrame standards and the Financial Stability Board’s (FSB) draft Scope of Insurers Subject to the Recovery and Resolution Planning Requirements in the FSB Key Attributes. Interested parties should submit feedback by January 30, and comments will be discussed in further detail on the committee’s February 3 call. Here are the key issues:

• IAIS draft ICS-related ComFrame Standards: The consultation develops ComFrame material specific to insurance capital standard (ICS) supervisory reporting and public disclosure. The NAIC cautions against publicly disclosing the same information that is reported to group-wide supervisors and recommends revising the disclosure-related requirements to ensure they are fit for purpose.
  
• FSB consultation report on the Scope of Insurers Subject to the RRP Requirements in the FSB Key Attributes: The most substantive comment pertains to the FSB’s proposed revised definition of “critical function” (which would change from “the sudden failure to provide the function would be likely to have a material impact on the financial system and the real economy” to “…or the real economy”). The NAIC opposes the revision, noting that changing the conjunction would materially broaden the scope of what is considered a critical function, potentially resulting in increased resolution-planning burdens and stretched supervisory resources.

  Staff Contact - Sean McKenna

International Developments

The Financial Stability Board (FSB) published its 2025 Resolution Report on January 21, 2026, slightly behind schedule. The report (1) sets the FSB’s 2026 resolution priorities; (2) details 2025 progress in implementing resolution reforms across banking, insurance, and financial market infrastructures; and (3) discusses upcoming work, which includes the biennial resolvability monitoring report to assess implementation of insurance sector resolution regimes.

On January 19, the International Association of Insurance Supervisors (IAIS) published its 2026–2027 Roadmap, which provides an overview of anticipated activity in support of the 2025–2029 Strategic Plan, including:

Recovery & Resolution: The final Application Papers on recovery and resolution planning are expected in the third quarter.

Structural Shifts in the Life Insurance Sector: The IAIS will take on a handful of projects following the finalization of the Issues Paper:

• Enhance its collection of data regarding alternative assets (specifically private credit) and asset-intensive reinsurance (AIR) through the Global Monitoring Exercise (GME).
  
• Conduct an in-depth analysis of potential systemic risks arising from the structural shifts based on the enhanced data collection.
  
• Review its supervisory material to address issues identified with alternative assets and AIR, building on the gap analysis and findings in the Issues Paper.
  
• Develop supporting material on increased allocation to alternative assets and increased adoption of AIR, which will include examples of supervisory practices to address these trends.

Insurance Capital Standard (ICS): Implementation of the ICS will be a significant focus over the next year. The IAIS will:

• Coordinate the ICS baseline self-assessment in 2026.
  
• Continue developing the implementation assessment methodology, which will consider the specificities of the ICS via the Aggregation Method.
  
• Continue developing supporting material, including technical parameters for the production of yield curves.
  
• Adopt the ICS-related standards on supervisory reporting and public disclosure (currently out for comment through February 5).

Holistic Framework: Early this year, the IAIS will publish its report on the second phase of the Holistic Framework Targeted Jurisdictional Assessments (TJAs) conducted in Australia, Bermuda, Italy, Singapore, Spain, and South Africa. This will also feature an update on progress made by the initial 10 TJA jurisdictions (including the United States) to close any previously identified gaps. In addition, the IAIS plans to update supervisory and supporting material related to macroprudential supervision and liquidity risk management (in response to the 2024 revisions to the ICPs following the first Holistic Framework TJA).

Artificial Intelligence: Discussions on AI and digital innovation will continue through the IAIS FinTech Forum. The Forum’s focus will be on (1) emerging trends in AI, including finalization of a question bank for supervisors to use when engaging with insurers on their AI use cases; and (2) governance processes and the use of AI in supervisory technology (SupTech), including a members-only report on insurers’ use of agentic AI to identify prudential and conduct risk.

Stakeholder Engagement Opportunities: The Roadmap does not contemplate a 2026 or 2027 Global Seminar. There is reference to a virtual Global Leadership Dialogue in the third quarter and again in 2027, but no further details are offered. The 2026 Annual Conference will be held on November 12–13 in Hong Kong, and the 2027 Annual Conference will be held on November 11–12 in Morocco.

Other Items:

• The final Application Paper on operational resilience objectives and toolkit is expected in the first quarter.
  
• The IAIS completed its peer-review process for ICP 13 (Reinsurance); the public report will be published in the first quarter.
  
• A draft Application Paper on regulation and supervision supporting inclusive insurance markets will be published for consultation in the first quarter and finalized in the third quarter.
  
• The IAIS will conduct a baseline self-assessment of ComFrame standards in the second half of 2026.
  
• A draft Issues Paper on issues related to customers receiving fair value from insurance products will be published for consultation in the second quarter and finalized in 2027.
  
• A draft Application Paper on the availability of capital (ICS) will be published for consultation sometime in 2027.

In other news, the IAIS has published a revised Application Paper on recovery planning for public consultation, replacing the original 2019 version; the current consultation reflects recent updates to ICP 16.15, evolving supervisory practices, and global legislative changes. The consultation is open for comment until February 25. As a reminder, IAIS application papers offer recommendations and examples but do not introduce new mandatory requirements.

The revised draft clarifies that all insurers are required to evaluate their specific risks and recovery options in advance of severe stress scenarios; however, the obligation to develop and maintain a formal recovery plan applies only to those insurers identified by their supervisor. Supervisors identify which insurers must develop a recovery plan by assessing established criteria such as the insurer’s risk profile, size, complexity, and systemic importance. For example, a supervisor may require a recovery plan if an insurer is deemed systemically important or critical at failure, taking into account factors such as risk exposures, interconnectedness, and the nature of business activities.

The revised paper emphasizes proportionality, allowing for flexible, risk-based application of recovery planning and potential exemptions for small or non-complex insurers. It also reinforces alignment between recovery plans and existing enterprise risk management (ERM) tools, clarifies the role of the NAIC’s own risk and solvency assessment (ORSA), and introduces more explicit guidance on supervisory coordination for insurers with cross-border activities. These changes collectively signal heightened expectations for governance, transparency, and coordination in recovery planning, especially for insurers with international operations and systemic relevance.

On January 22, the Bermuda Monetary Authority (BMA) published its 2026 Business Plan, which details the organization’s anticipated initiatives over the next year. Regarding the insurance sector, the BMA intends to:

• Embed elements of ComFrame and the Holistic Framework into the Bermuda regulatory regime, including those related to recovery and resolution.
  
• Continue its work on strengthening the group supervision regime.
  
• Provide further guidance on the application of the prudent person principle (PPP) for investment management.
  
• Implement enhanced public disclosure requirements on investments for the long-term market.
  
• Propose enhancements to insurer management and governance accountability
  
• Enhance its regulatory framework to facilitate supervision of new prudential and conduct requirements consistent with international standards.
  
• Develop framework enhancement proposals for the responsible use of AI.
  
• Provide guidance to assist with implementing cyber regulatory requirements and best practices.
  
• Continue engaging with the IAIS and the FSB on systemic risk analysis and other efforts.

  Staff Contact - Sean McKenna

AI Activity

The Colorado Division of Insurance has resumed its work with Cathy O’Neil (O’Neil Risk Consulting & Algorithmic Auditing) to continue developing its draft algorithm and predictive model quantitative testing regulation. The division hopes to finalize the testing regulation for life insurers by mid-2026.

  Staff Contact - Sean McKenna

Privacy Updates

New consumer privacy bills were introduced in Iowa and Mississippi:

• Iowa’s HF 2048 applies to companies, defined as persons “conducting business in [Iowa] that process the personal data of five thousand or more individuals who reside in [Iowa] in a single calendar year.” The bill does not exempt entities or data subject to HIPAA or the Gramm-Leach-Bliley Act (GLBA).
  
• Mississippi’s SB 2015 applies to businesses that do business in Mississippi and meet one or more of the following thresholds: (1) have annual gross revenues in excess of $10 million; (2) alone or in combination, annually buy, receive for the business’ commercial purposes, sell, or share for commercial purposes, alone or in combination, the personal information of 50,000 or more consumers, households, or devices; and (3) derive 50% or more of their annual revenues from selling consumers’ personal information. The bill does not contain an exemption for entities or data subject to HIPAA or the GLBA.

  Staff Contact - Sean McKenna

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 McKenna

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