NAIC Updates

The Senior Issues (B) Task Force (SITF) briefly discussed concerns related to long-term care (LTC) riders on life products, including consumer confusion and if complaints had been filed with state regulators The task force tabled the discussion and will hear more information at the Summer National Meeting in Minneapolis this August.

The SITF also heard a presentation from Bonnie Burns (California Health Advocates) and Steve Schoonveld (GCG Consultants LLC) on state LTC financing initiatives, highlighting the Washington program (WA Cares Fund) and the studies performed by California and Minnesota, as well as the Massachusetts study that was released on June 10, 2025.

The Life Actuarial Task Force adopted APF 2025-04, incorporating the new Generator of Economic Scenarios (GOES) into the Valuation Manual. The task force voted not to include either the weighted average approach as an alternative or the seven-year phase-in period with approval of a company’s domestic regulator.

In additional GOES news, (1) NAIC staff noted that they continue to work with Conning to release additional field test data, with a goal of releasing multiple scenario sets in early July; and (2) NAIC staff reminded attendees that regulators previously agreed to use the Conning Corporate Yield Model in the field test (as that question came up on recent calls). The task force also adopted APF 2025-06 and the knowledge statements for the Appointed Actuary, Illustration Actuary, and Qualified Actuary.

On June 9, the Aggregation Method Implementation Working Group (AMIWG) heard a presentation from Ned Tyrrell (NAIC staff) on its work plan and next steps. The AMIWG was formed in response to the International Association of Insurance Supervisors’ (IAIS’s) finding that the Aggregation Method (AM) provides a “basis of implementation” of the Insurance Capital Standard (ICS), with additional work needed on (1) the interest rate sensitivity of U.S. internationally active insurance groups (IAIGs) in the life sector; and (2) the timing of supervisory intervention. These items are the focus of the working group through 2026.

Most notably, the working group’s goal is to narrow the gap between the AM and the Group Capital Calculation (GCC) and, ideally, have the GCC be the full implementation of the AM. Here are some other key takeaways:

• The working group will begin with work related to scalars, which will be important to address the two items identified by the IAIS. AMIWG will consider the potential use of an Excess Relative Ratio approach calibrated to 200% of the Authorized Control Level, which is currently used in the GCC. The working group will make a formal scalar recommendation at the Summer National Meeting in August.
  
• The working group will conduct a review of the AM to provide a response to the IAIS on the outstanding issues, which will include the consideration of scalars, what a Prescribed Capital Requirement means in the context of the U.S. system, how issues are already addressed, and any suggested areas for refinement. The review will require technical input, and AMIWG is forming a group of stakeholder volunteers to contribute to this work. Volunteers should contact Ned Tyrrell by June 20.
  
• AMIWG will meet at the Summer National Meeting to discuss a recommendation on scalar method and calibration and scalar updates for key jurisdictions, a draft package of AM reporting materials, and updates on the review of sensitivity to interest rates and supervisory intervention. A detailed timeline is included in Attachment 3 of the presentation.

Privacy Updates

The National Institute of Standards and Technology (NIST) released an initial public draft of Special Publication 800-18r2 Revision 2: Developing Security, Privacy, and Cybersecurity Supply Chain Risk Management Plans for Systems. The publication provides guidance on the development of system plans that address system-level security, privacy, and cybersecurity supply chain risk management (CSCRM) requirements. The new revisions include (1) expanded guidance to address system plans within the context of other NIST publications; (2) updated descriptions of system plan elements; (3) considerations for automating the development and maintenance of system plans; and (4) insights into the development of a consolidated system plan that encompasses security, privacy, and CSCRM plan elements. Interested parties may submit comments through July 30, 2025.

NIST also released Special Publication 1800-35: Implementing a Zero Trust Architecture. The publication provides guidance for securing an organization’s computer network from cyberattacks in the modern age, with a goal of illustrating solutions to cybersecurity challenges using commercial technology.