April 2026 MPC Meeting Website Posted

The schedule for the April 2026 MPC meeting in New Orleans (and online) has been posted on the April MPC meeting website in the Meeting Schedule & Info section. The website also features in-person and virtual meeting registration, hotel reservations, and other meeting information.

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 times listed for all presentations are estimates. We will do our best to keep to the posted times, but presentations might start a few minutes early or late depending on how the meeting progresses.

If you have any trouble accessing the meeting website, please contact Dan Hicks. If you have any questions about the meeting, contact Jenn Webb or Sean McKenna.

  Staff Contact - Sean McKenna

New York DFS Appoints Shah as Executive Deputy Superintendent of Insurance

Avani Shah has returned to the New York Department of Financial Services to lead its Insurance Division. Shah previously held this role in an acting capacity a few times over her career and served as Deputy Superintendent of Insurance from 2020–2024.

  Staff Contact - Sean McKenna

DOL Extends Comment Period for PBM Disclosure Rule

On March 2, 2026, the Department of Labor published a notice extending the comment period for its pharmacy benefit manager (PBM) disclosure proposed rule. The comment deadline has been extended to April 15 from the original March 31 deadline. The proposed rule, released in late January in response to an executive order, would require entities with a contract with self-insured and level-funded group health plans to disclose pricing, cost, rebate, and utilization data to plan sponsors in connection with pharmacy benefits.

  Staff Contact - Sean McKenna

AM Best Cites Private Credit & Offshore Reinsurance Risks

AM Best’s recent Market Segment Report, U.S. Life and Annuity Industry Continues to Shift More Focus to Annuities, highlights insurers’ increased investment allocation to private credit and use of affiliated and offshore reinsurance. The report states that the increasing private credit allocations have been largely driven by private equity– and asset manager–backed insurers and raised concerns regarding affiliated investment structures. Regarding offshore reinsurance (which AM Best said it does not view exclusively as negative), the report highlighted the potential for counterparty and liquidity risk as well as concerns with weaker regulatory oversight compared to onshore jurisdictions and differences in capital and reserve treatment. AM Best acknowledged Bermuda’s 15% corporate income tax for large enterprises, which it said narrows the gap between off- and onshore tax benefits.

  Staff Contact - Sean McKenna

NAIC Updates

In preparation for its May fly-in, the NAIC published its 2026 Federal Priorities and new congressional briefers on the SVO Discretion Issue and AI and State Insurance Regulation.

The 2026 priorities include:

• Protect consumers by supporting federal policy that reinforces state-based insurance regulation and ensures consumers (especially vulnerable populations) are protected when an insurer fails or fraud occurs (the NAIC included support for the State Insurance Receivership Priority Act).
  
• Support resilient communities by encouraging Congress to invest in proactive mitigation and risk-reduction strategies with targeted federal funding and tax incentives to lower catastrophe losses, improve affordability, and stabilize the homeowners’ market.
  
• Oppose administrative overreach, stating that federal agencies (and Congress) should respect state primacy in insurance regulation, specifically avoiding duplicative or conflicting mandates (the NAIC included support for the McCarran-Ferguson Restoration Act, which would eliminate the Federal Insurance Office, and the Financial Stability Oversight Council Improvement Act).

In other NAIC news:

RBC Investment Risk and Evaluation Working Group: The American Academy of Actuaries presented its much-anticipated comparable attributes and related factors to the RBC Investment Risk and Evaluation Working Group on March 2 (see Slide 13 of the linked presentation). The Academy’s modeled tail risk can largely be explained by a combination of three attributes: remaining reinvestment horizon, rating, and tranche thickness.

The Academy utilized an Ordinary Least Squares (OLS) regression model to produce modeled C-1 factors. Because C-1 factors for other asset classes are horizon-neutral, the Academy utilized a single reinvestment horizon of 2.41 years. Collateralized loan obligation (CLO) debt tranches were then sorted using two comparable attributes: rating and tranche thickness. Tranche thickness was needed only for debt tranches rated Baa3 and lower and is treated in a simple manner: dividing each rating into a tranche thickness greater than 4% and a tranche thickness less than 4%. Note the significant difference between Baa3 and Ba1 charges.

Steve Smith (Academy) walked through the analysis in detail. Key takeaways include:

• Universe of CLOs Used in the Academy’s Analysis: The Academy analyzed all U.S. broadly syndicated loan (BSL) CLOs that have rated collateral. The working group discussed how this analysis would not be applicable to CLOs that do not have ratings on underlying loans.
  
• Importance of Tranche Thickness: The Academy’s analysis shows that thin tranches are riskier but notes there were few examples of thin tranches for tranches above a Baa3 rating.
  
• Alternative Models Considered: The Academy tested several alternative models (see Appendix 3) but notes that ratings provide a better estimation for risk than all the other factors tested combined.
  
• Regulator Questions/Concerns: Philip Barlow (Chair, DC) asked whether tranche thickness was easily ascertainable. Kevin Clark suggested that regulators may benefit from additional information about tranche thickness and materiality if the working group is going to pursue an interim approach that does not incorporate any of that analysis. Carrie Mears (IA) wondered whether the NAIC’s SSG model could be maintained to validate some of the Academy’s outputs on an ongoing basis (which it can, according to NAIC staff). Doug Stolte (VA) voiced concern about middle market CLOs that do not contain rated underlying collateral. Fred Andersen (MN) wanted more information regarding the cliff from Baa3 to Ba1 and questioned whether CLO originators could “game” the ratings by creating tranches that are all 4.1%.

The Academy’s presentation was exposed for 45 days until April 16. The working group will discuss initial feedback at the Spring National Meeting. Philip Barlow (Chair, DC) suggested potentially using the ratings-only charges as an interim approach for year-end 2026 and deferring the incorporation of the tranche thickness analysis to the following year.

Reinsurance Task Force: The Reinsurance Task Force met on March 2 in lieu of meeting at the Spring National Meeting, with the main topic being the treatment of derecognized net negative interest maintenance reserve (IMR). Highlights included:

• Net Negative IMR Discussion: This discussion stems from the Statutory Accounting Principles Working Group’s (SAPWG) multi-year effort regarding the treatment of net negative IMR. The ultimate question is whether derecognized net negative IMR should reduce reinsurance collateral requirements in a manner that is symmetrical to collateral increases caused by positive IMR. The ACLI supports a symmetrical approach. The American Academy of Actuaries similarly proposed a symmetrical approach, provided a ceding company conducts stand-alone cash flow testing when the negative IMR reduces collateral below the policy reserves. Although no consensus resulted from the discussion, regulators did not push back on the ACLI or Academy’s proposal but instead want to ensure policyholders are adequately protected. NAIC staff will prepare a proposed path forward while regulators continue to consider the various options.
  
• ReFAWG Report: The Reinsurance Financial Analysis Working Group (ReFAWG) reported progress on reciprocal jurisdiction and certified reinsurer licensing and passporting. The working group has approved 107 reciprocal jurisdiction reinsurers and 42 certified reinsurers for passporting, with 49 states and two territories now passporting reciprocal jurisdiction reinsurers. A full list of reciprocal jurisdiction and certified reinsurers is available here.
  
• Mutual Recognition of Jurisdictions Working Group Report: John Rehagen (MO) has taken over as Chair following Bob Wake’s retirement. The working group continues to track ongoing enhancements to the Bermuda, Japan, and UK regulatory regimes.
  
• Ongoing NAIC Projects Affecting Reinsurance: In execution of the NAIC’s goals for greater collaboration across groups, the task force received updates from NAIC staff regarding projects across the NAIC landscape that touch on reinsurance. Jake Stultz (NAIC) highlighted older projects, including AG 55, the Macroprudential Working Group’s reinsurance worksheet, and VAWG’s review of AG 53 submissions. The NAIC held two regulator-only educational sessions last year on cross-border reinsurance issues and plans to hold additional sessions this year.

Big Data and AI Working Group: The Big Data and AI Working Group kicked off the AI Systems Evaluation Tool pilot on March 2, now with 12 participating states: California, Colorado, Connecticut, Florida, Iowa, Louisiana, Maryland, Pennsylvania, Rhode Island, Vermont, Virginia, and Wisconsin. The revised pilot project summary reflects the updated timeline, added states, and intent of the working group to provide regular updates.

Participating states will use version 4 of the AI Systems Evaluation Tool, which has been informed by stakeholder feedback over the last several meetings and remains subject to change depending on the results of the pilot. The working group acknowledged four areas still in need of attention that will be studied during the pilot:

• References to materiality and risk assessment and whether the concepts should rely on company definitions
  
• Inclusion of general language models (GLMs) in all or part of the tool
  
• Terminology to scope inclusion of models (i.e., use of augment/automate language to narrow focus) and whether that language choice is adequate based on regulators’ goals
  
• Inclusion of questions relating to financial and market conduct–related inquiries in a single tool

Blanks Working Group: The Blanks Working Group took action on several items on March 5:

Adopted the following previously exposed items:

• 2025-17BWG (Modified), which seeks to improve the consistency of reporting of debt securities across various SSAPs (and stems from Statutory Accounting Principles Working Group (SAPWG) Ref #2025-20). This item also adds a general interrogatory to indicate the method used for reporting residuals. The interrogatory was revised to require a reporting entity to indicate if it is transitioning from the Practical Expedient to the Allowable Earned Yield method.
  
• 2025-18BWG, which adds clarifying instructions (and an example) to Health General Interrogatories 10.21–10.24.
  
• 2025-19BWG (Modified), which adds a designation to Schedule T for a suspended license in a given state.
  
• 2025-20BWG (Modified), which updates Schedule D, Part 6, Section 1 reporting categories and AVR lines to remove investment subsidiaries. This item stems from SAPWG Ref #2024-21, which removes the investment subsidiary concept from financial statement instructions. Notably, SAPWG did not receive any comments on that proposal. The changes become effective December 31, 2026.
  
• 2025-21BWG, which revises the definition of Accepted Actuarial Designation based on the Actuarial Opinion Working Group’s assessment of educational materials of the Society of Actuaries and Casualty Actuarial Society. This also clarifies several items deemed to be confusing by regulators or industry and/or inconsistently reported by reporting entities. It also clarifies the instructions on the reconciliation of data used by the appointed actuary to Schedule P.
  
• 2025-22BWG (Modified), which amends the investment schedules to identify whether an investment is publicly registered, a Rule 144 investment, or a private placement security (or none of those). The item also adds a new part to Note 5 – Investments to report the total book/adjusted carrying value (BACV), fair value, and total amount of aggregate deferred interest and payment-in-kind (PIK) interest, and the total BACV supported by private letter ratings. See Ref #2025-19 coming out of SAPWG.
  
• 2025-25BWG, which updates Note 2 – Accounting Changes and Corrections by adding a reference to VM-20. See SAPWG Ref #2025-34.
  
• 2025-28BWG (Modified), which adds two investment characteristic categories to clarify if an investment is owned by a qualifying statutory trust. This item also updates Schedule B instructions for reporting guidance for mortgages held in qualifying statutory trusts. See SAPWG Ref #2025-13.
  
• 2025-30BWG (Modified), which provides clarification to Note 12 on how to complete fair value disclosures for retirement plan assets measures at net asset value. See SAPWG Ref #2025-21.

Deferred action on the following items:

• 2025-23BWG (Modified), which updates the Separate Account Assets page by adding “Nonadmitted Assets” and “Net Admitted General Account Assets” lines. This item also adds a new line on the Separate Account Summary of Operations to reflect a “Change in Nonadmitted Assets” within the surplus account. Finally, it adds an Exhibit of Nonadmitted Assets to the Separate Account Blanks. See SAPWG Ref #2025-25.
  
• 2025-24BWG, which updates Note 18B – ASC Plans to make clarifications related to Administrative Services Contracts. See SAPWG Ref #2025-30.
  
• 2025-25BWG, which updates Note 2 – Accounting Changes and Corrections by adding a reference to VM-20 and a reference to phased-in reserve changes related to the prescribed economic scenario generator. See SAPWG Ref #2025-34.
  
• 2025-26BWG (Modified), which updates the annual statement expense categories and instructions to remove outdated terminology. See SAPWG Ref #2025-33.
  
• 2025-27BWG (Modified), which adds a section to the Life AVR to report CLOs. This item also adds a footnote to Schedule D, Part 1 to report the BACV of CLOs by NAIC Designation Category. The revisions expand these reporting obligations to collateralized bond obligations (CBOs) and collateralized debt obligations (CDOs).
  
• 2025-29BWG, which adds restricted asset codes to Investment Schedule General Instructions for assets subject to funds withheld and modco arrangements. See SAPWG Ref #2025-27. Interested parties noted that the changes could result in duplicative disclosures. SAPWG intends to continue discussion of this item at the Spring National Meeting.

Because SAPWG has not adopted these items, the full adoption of these items is being deferred until after the Spring National Meeting. Comments are due April 28.

Exposed the following items until April 28:

• 2026-01BWG, which would add instructions to Note 26 – Intercompany Pooling Arrangements for modifications to an existing intercompany pooling arrangement that involved the transfer of assets with fair value that differs from statement value.
  
• 2026-02BWG, which would update Note 11 – Debt to add a cross-check between Note 11B – FHLB Agreements and General Interrogatory #26.
  
• 2026-03BWG, which would update various elements of the life annual and quarterly blanks to clarify how companies should report valuation standards for VM-22 business. This item also would add an annual supplement for VM-22 reserve reporting.
  
• 2026-04BWG, which would add a section to Note 11 – Debt to disclose funding agreements backing special purpose vehicles (SPV) issuances (FABN). This item would also add a footnote to Exhibit 7 to the Life blanks to report the amount of total funding agreements backed by SPV issuances. This item stems from the Financial Stability Task Force and Macroprudential Working Group’s funding agreement and FABN educational efforts last year.

Received two memos from other NAIC groups:

• A memo from SAPWG regarding the reporting of modco and funds withheld assets. The memo clarifies that the goal of the new Schedule S, Part 8 (effective December 31, 2025) was not to change how assets subject to a modco or funds withheld arrangement are factored into the life RBC formula.
  
• A memo from the Macroprudential Working Group on Funding Agreements, FABNs, and other structures, which ultimately led to the development of Item 2026-04BWG.

  Staff Contact - Sean McKenna

Privacy Updates

A new consumer data privacy bill was introduced in Alaska. HB 367 would amend Alaska’s Personal Information Protection Act to include specific provisions regarding consumer personal information privacy. The provisions would apply to businesses that collect personal information from consumers. The provisions would not apply to covered entities and protected health information collected by a covered entity or business associate governed by the HIPAA privacy, security, and breach notification rules or persons, affiliates, and data subject to the Gramm-Leach-Bliley Act (GLBA).

CalPrivacy has announced a $1.1 million fine against PlayOn Sports for its consumer tracking practices. In its February 27, 2026, statement, CalPrivacy alleges that PlayOn’s digital platform, which enables students to buy tickets for high school events, violates the California Consumer Privacy Act (CCPA) by requiring users to accept tracking technologies without providing an adequate opt-out mechanism, failing to honor opt-out preference signals, and implementing a deficient privacy notice.

CalPrivacy also issued a decision against Ford Motor Company for alleged violations under the CCPA. According to the decision, Ford violated the CCPA by requiring consumers to verify their email address before opting out of the sale and sharing of their personal information. Ford is ordered to pay a $375,703 fine and change its business practices by providing consumers with opt-out methods that do not require additional verification steps. Ford must additionally undertake a compliance audit of its tracking technologies.

  Staff Contact - Sean McKenna