NAIC Updates
The Privacy Protections Working Group voted on June 12, 2024, to revise existing privacy Model #672 and discontinue work on the new privacy model draft (#674), consistent with most of the feedback received during the comment period. Consumer representatives opposed the direction of the working group, stating that the industry edits to Model #672 do not go far enough to protect consumers.
The working group, however, voted only on which model to amend, and not necessarily on any amendments themselves (i.e., they did not commit to using the industry draft). Another call will be scheduled for the working group to substantively discuss how to proceed with Model #672 edits.
The International Insurance Relations (G) Committee met on June 11 to approve NAIC comments to the International Association of Insurance Supervisors (IAIS) on three consultations:
- Draft revisions to supervisory material related to the Holistic Framework (comments due June 27): The majority of the NAIC’s comments are intended to clarify language or improve consistency. Notably, the NAIC opposes the presumption that internationally active insurance groups (IAIGs) should be required to have a resolution plan in place even if not assessed as systemically important (asked in the question related to CF 12.4.a), arguing that it does not align with the Holistic Framework and could be overly burdensome.
- Proposed changes to reflect climate risk in selected ICP guidance and supporting material (comments were due June 19): The NAIC is offering minimal comments on this consultation, primarily suggesting language that adds flexibility. A representative from the American Property Casualty Insurance Association (APCIA) encouraged the NAIC to review its comments, as well as those from the Global Federation of Insurance Associations (GFIA), once they are ready, noting that some aspects of the consultation appear to “come close to recommending double materiality.”
- Draft Application Paper on supervising DEI – the governance, risk management, and culture perspective (comments were due June 14): The NAIC suggested adding a sentence to the context and objective section (1.1) that recognizes the jurisdictional legal and privacy issues surrounding the use and collection of data. Other comments included clarifying (i) the description of “groupthink” in Box 2, and (ii) Box 3 regarding diversity/equity/inclusion (DEI) “washing.”