Texas GA Names Executive Director

The Board of Directors of the Texas Life & Health Insurance Guaranty Association (TLHIGA) has announced that Jan Graeber will succeed Bart Boles as Executive Director. Ms. Graeber is a member of both the Society of Actuaries and the American Academy of Actuaries. Since November 2018, she has served as Senior Actuary with the American Council of Life Insurers (ACLI), where she has worked closely with regulators and industry leaders on a range of life and health insurance policy issues. Prior to joining the ACLI, she served as Chief Actuary and Deputy Commissioner at the Texas Department of Insurance.

Ms. Graeber will begin transitioning into the role on April 1 and will fully assume Executive Director responsibilities upon Mr. Boles’ retirement on December 31, 2026.

We understand that Ms. Graeber will be attending the April 2026 MPC meeting in New Orleans, and we encourage everyone to welcome her to the guaranty community.

Federal Updates

On March 10, 2026, the Department of the Treasury published a notice that a two-year charter for the Federal Advisory Committee on Insurance (FACI) will be filed with Congress, following the lapse of its previous two-year charter in June 2025. The notice says that, following the February 2025 Executive Order “Commencing the Reduction of the Federal Bureaucracy,” the Treasury Department is re-establishing FACI in the public interest. Per the notice, FACI allows the Federal Insurance Office (FIO) to get timely information and draw on the knowledge and experience of insurance regulators, state legislators, and industry and academic experts. The Treasury Department anticipates direct feedback through FACI from “insurers, reinsurers, brokers, private equity firms, state insurance regulators, consumer advocates, and other insurance sector stakeholders.” The department will publish a call for FACI membership nominations.

In other federal news, the litigation in the Northern District of Texas challenging the Biden administration’s fiduciary rule, which would have expanded the definition of fiduciary under ERISA, was withdrawn, according to a joint motion from plaintiffs and the Department of Labor. The court granted the motion and vacated the proposed rule. There is still no replacement rule, but the department is expected to issue one in May.

NAIC Updates

The NAIC Spring National Meeting begins this weekend in San Diego, and the NAIC has issued its preview document. For the guaranty system, some of the highlights of the meeting include:

General

• Public hearing to gather input on possible amendments to the NAIC Policy Statement on Open Meetings (Executive Committee)
  
• Discussion of comments received on RBC Gap Analysis Request for Input (RBC Model Governance Task Force)
  
• Update on the American Academy of Actuaries’ CLO work (RBC Investment Risk and Evaluation Working Group)
  
• Discussion of the draft of the Aggregation Method Implementation Working Group’s review of U.S. Group Solvency Regulation (Aggregation Method Implementation Working Group)
  
• First meeting of the new Invested Assets Task Force and Investment Designation Analysis Working Group
  
• Presentation on understanding illustrations (Life Insurance and Annuities Committee)
  
• Adoption of the Restructuring Mechanisms White Paper (Joint Meeting of the Executive Committee and Plenary)

• Discussion of potential revisions to the third-party framework based on the comments and feedback received (Third-Party Data and Models Working Group)
  
• Update on the AI Systems Evaluation Tool and Pilot at several meetings
  
• Discussions on (1) how to operationalize the NAIC’s AI Model Bulletin and (2) governance practices supporting the implementation of AI systems (Big Data and Artificial Intelligence Working Group)

• Discussion of comments on the VM-22 aggregation, settlement options, and deposit-type contracts exposures
  
• Discussion of comments on the in-force application of VM-22
  
• Possible adoption of the alignment of the Reinvestment Guardrail
  
• Potential re-exposure of Group Annuity Data Collection changes
  
• Potential formation of a non-forfeiture drafting group
  
• Likely exposure of an APF on the PRT Reinvestment Guardrail and a discussion of principles development by the Academy

• Discussion of several items related to Net Negative interest maintenance reserve (IMR) (looking to adopt the Proof of Reinvestment item and defer action on the Impact on Reinsurance item)
  
• Possible re-exposure of Item 2025-27: SSAP No. 1 Modco/FWH Codes (NAIC staff seeking feedback from the working group)
  
• Likely deferral of (1) Item 2025-24: Commitments and Contingencies Disclosures (possibly directing NAIC staff to work with industry; also seeking regulator feedback on RBC treatment for contingencies and commitments); (2) Item 2025-26: SSAP No. 48 Equity Changes (possibly directing NAIC staff to work with a limited industry focus group); and (3) Item 2025-29: Reporting Clarification (recommending that the working group sponsor a Blanks proposal related to various issues related to the principles-based bond definition, including payment due at maturity and origination balloon payment percentage)
  
• Exposure of the Residential Mortgage Loans Held in Statutory Trusts Issue Paper, a new item regarding the disclosure of funding agreement–backed notes (FABNs) and similar structures, and an item clarifying how funds withheld liabilities should be recorded.

• Possible adoption of proposal 2025-14-L on GOES implementation and impact to C-3 risk
  
• Comments on proposals 2026-02-L on Schedule BA residential mortgage loans and 2025-16-L MOD on collateral loans

• Possible consideration of adoption of the revised state flexibility white paper (Regulatory Framework Task Force)
  
• Discussion of the PBM Licensure and Regulation Guidelines for Regulators (Market Regulation and Consumer Affairs Committee)
  
• Discussion of the revised draft PBM Examination Chapter and possible consideration of a referral to the Market Conduct Examination Guidelines Working Group for its consideration (Pharmacy Benefit Management Working Group)
  
• Discussion of comments and next steps related to the ERISA Preemption and State Pharmacy Benefit Manager (PBM) Laws guidance document (ERISA and Alternative Health Coverage Working Group)
  
• Discussion of LTC riders and recent LTC reports (Senior Issues Task Force)
  
• Presentations on LTCI fraud (Senior Issues Task Force; Antifraud Task Force)

In other NAIC news:

Financial Stability Task Force & Macroprudential Working Group: The Financial Stability Task Force (FSTF) and Macroprudential Working Group (MWG) met on March 16 in lieu of meeting at the Spring National Meeting. Included in the meeting materials was a proposed referral to the Receivership and Insolvency Task Force (RITF), which asks the RITF to review the priority treatment of funding agreements and funding agreement–backed notes (FABNs) (and similar structures) and financial instruments along with (pari passu) “traditional” policyholders in a receivership or insolvency. The referral specifically requests a report outlining the results of the RITF’s review, recommendations, and conclusions. The MWG report suggests that a few states may not provide policyholders (including holders of funding agreements) priority over general creditors in an insolvency. It also questions how foreign bondholders of Foreign Currency Denominated FABNs would be treated in an insolvency. The referral was expected to be made at the meeting. In addition, Fred Andersen (MN) was expected to provide an update on AG 53 (Asset Adequacy Testing of direct business) reviews and preview the process for AG 55 (Asset Adequacy Testing for reinsured business) reviews.

Scott White Discusses NAIC Priorities at Academy Conference: NAIC President Scott White (VA) spoke at the American Academy of Actuaries’ Spring Policy Summit on March 9 and discussed the NAIC’s priorities for 2026. He touched on (1) insurers’ use of AI and the AI Systems Evaluation Tool pilot program; (2) new capital requirements for collateralized loan obligations (CLOs) and the shift in life insurers’ investment strategies; (3) continued focus on offshore reinsurance and asset-adequacy testing; and (4) implementation of a coordinated framework for reviewing LTC rate increases.

Cybersecurity Working Group: The Cybersecurity (H) Working Group discussed and adopted revisions to its Cybersecurity Event Notification Portal Project Intake Form. Michael Peterson (VA) presented the form and discussed notable changes, including (1) adding an additional discussion of the SOC 3 form in the form; (2) providing clarity that there is no intention or plan to charge licensees for submissions now or in the future; and (3) adding additional verbiage from stakeholders. Industry representatives provided comments requesting additional transparency regarding the security of the portal with respect to the sensitive information that will be uploaded, recognition of the concern that the proposal could be interpreted to suggest broad regulator access to the data in the portal, transparency regarding revenue generation related to the portal as the initiative moves forward, and for the meeting minutes to reflect that the depth or level of sensitive information collected will be discussed as the initiative moves forward. The working group voted to approve the form. Next steps are to develop the portal and continue discussions with stakeholders. Once the portal is in working form, the working group intends to hold large demonstrations with fake data to show how the portal is used for cyber events.

Market Conduct Examination Guidelines Working Group: On March 12, the Market Conduct Examination Guidelines (D) Working Group heard a presentation from Colton Schulz (ND) and David Buono (PA) on the development of a Cybersecurity Coordination Framework to help regulators respond to national cybersecurity events. The framework could work with and potentially become part of the Cybersecurity Event Response Plan (CERP), but the details are to be determined. The working group is considering several foundational items, such as how the framework is designed, what events are in scope, and how information is communicated. Buono also emphasized that the framework is intended to be a partnership between states and companies during a cybersecurity event.

Bermuda Risk Summit Highlights

The Bermuda Business Development Agency hosted the Bermuda Risk Summit from March 9–11, 2026. The conference included panel discussions on the strength of Bermuda’s insurance regulatory framework and the importance of supervisory coordination, the evolution of private credit and asset-intensive reinsurance, innovation, and Asia’s expansion on the island.

• Regulation & Supervisory Coordination: Gerald Gakundi (Deputy Managing Director and Head of Insurance & Investment Funds, Bermuda Monetary Authority, or BMA) and Andy Mais (Advisor, Deloitte, and former Connecticut Insurance Commissioner) participated on a panel led by Suzanne Williams (CEO of the Bermuda International Long Term Insurers and Reinsurers, or BILTIR). They discussed the importance of mutual trust among regulators, built through a shared commitment to integrity and common regulatory outcomes such as financial resilience, policyholder protection, and systemic stability. Gakundi and Mais emphasized that strong supervisory coordination does not require uniformity, but rather structured, transparent, and cooperative engagement achieved through supervisory colleges, bilateral dialogues, and reliance mechanisms like Solvency II equivalence and Qualified and Reciprocal Jurisdiction status. Transparency in asset and liability disclosures was recognized as strengthening stakeholder confidence and deterring misconduct. The panel also addressed the balance between prudence and innovation, noting that rapidly evolving markets and new technologies require dynamic regulatory frameworks that both facilitate responsible innovation and maintain oversight.
  
• Private Credit: Panelists highlighted how private credit is transforming the landscape of capital raising and risk management in global insurance markets. The conversation underscored private credit’s evolution from a narrow focus on leveraged loans to a broad and diverse universe of asset classes, offering opportunities for investors through the illiquidity premium. They suggested that concerns about systemic risk and default rates have been amplified by media coverage and emphasized that these risks are often overstated and remain manageable within robust risk management frameworks. The growing role of rated notes and structured products was noted as a response to insurer demand for tailored solutions, supported by advancements in data analytics and artificial intelligence. Bermuda’s regulatory environment was recognized for its clarity and alignment with international standards, featuring rigorous stress-testing and capital reserve requirements. The panel concluded that private credit offers compelling opportunities for investors and insurers, provided risks are diligently managed and regulatory frameworks are robust.
  
• Asset-Intensive Reinsurance (AIR): A panel on innovation in reinsurance primarily focused on the growth of AIR. Participants highlighted Bermuda’s principles-based, risk-sensitive approach as supporting responsible innovation, noting that robust oversight, capital requirements, and flexibility for new structures attract global insurers and asset managers. Panelists pointed to the value of ongoing dialogue and collaboration with local and international regulators as deal complexity rises and new tools like AI are adopted, making proactive engagement essential for maintaining policyholder protection and market stability in the AIR space. They also noted the growing sophistication of partnerships between insurers and asset managers as a key driver of efficiency and expanded investment opportunities.
  
• Asia: Asia’s expansion in the Bermuda insurance market is driven by rising interest rates, demographic shifts, and increased demand for cross-border investment and risk solutions. According to panelists, Japan and Korea stand out due to their aging populations, savings cultures, and new needs for U.S. dollar-denominated products, especially for education and retirement. They cited Bermuda’s appeal as rooted in its flexible, innovative regulatory environment, international credibility, and deep insurance expertise, making it a trusted partner for Asian insurers seeking diversification, long-term growth, and stability.

Privacy Updates

On March 7, 2026, CalPrivacy published an invitation for preliminary comments to seek input regarding whether regulatory changes are needed to reduce friction in exercising privacy rights and opt-out preference signals. The invitation contains a list of questions for stakeholders to provide preliminary comments and opinions, including the challenges businesses experience when providing consumers with the ability to exercise privacy rights, how regulations can address them, and the top three things CalPrivacy should prioritize in reducing friction in the exercise of privacy rights. CalPrivacy is accepting preliminary comments through April 6.