Sentinel Security Life Insurance Company (Utah)

Petition for Rehabilitation Filed

On March 21, 2025, Utah Insurance Commissioner Jon Pike filed a petition with Utah’s Third District Court requesting that Sentinel Security Life Insurance Company, Haymarket Insurance Company, and Jazz Reinsurance Company (also known as “the A-CAP companies”) be placed in rehabilitation. Sentinel Security Life is the only direct writer, with the other two insurers providing reinsurance. Sentinel Security Life is licensed in 36 states; according to the company’s financial filings, it has approximately $5.4 billion in annuities and $2.5 billion in deposit-type contract liabilities.

The Sentinel Security Life Task Force, which was formed in January 2025, is in the process of performing a detailed review of the almost 400-page petition. The Utah Department of Insurance has compiled an FAQ document on the companies.

There are two other A-CAP insurers, located in South Carolina—Atlantic Coast Life Insurance Company (the direct writer) and Southern Atlantic Re Company (a captive subsidiary). NOLHGA also formed a task force for the South Carolina companies earlier this year, chaired by Frank Knighton Jr. (Georgia).

If you have any questions about the filing, please contact Task Force Chair Todd Thakar or Task Force Staff Contact Katie Wade; Jenn Webb and Lindsay Crawford also serve as Task Force Staff Contacts.

Task Force Chair - Todd Thakar (CA & NV)   Staff Contact - Katie Wade

Wisconsin Commissioner Address Guaranty Fund Forum Luncheon

On March 23, 2025, NOLHGA and the NCIGF held their joint Guaranty Fund Forum Luncheon at the NAIC Spring National Meeting. Wisconsin Insurance Commissioner Nathan Houdek, Chair of the NAIC’s Financial Condition (E) Committee, served as the keynote speaker.

Commissioner Houdek’s remarks highlighted the Wisconsin Department’s experience with insolvencies, including Time Insurance and Wisconsin Reinsurance Corporation. He also discussed the Financial Condition Committee’s various ongoing workstreams relating to Risk-Based Capital (RBC) and modernizing insurer solvency regulations in general.

Commissioner Houdek has served as Wisconsin’s Insurance Commissioner since his appointment by Governor Tony Evers in January 2022. Previously, he served as Deputy Commissioner. He also serves on the Board of the Wisconsin Insurance Security Fund.

  Staff Contact - Jennifer Webb

NAIC Updates

The Financial Stability Task Force (FSTF) met on March 17, 2025, in lieu of meeting at the NAIC Spring National Meeting. As mentioned in last week’s NOLHGA Wire, the meeting materials contained a memo from Bob Kasinow (NY) on the work of the Macroprudential Working Group (MWG), which met in regulator-only session on February 6 and received an update from Carrie Mears (IA) on the International Association of Insurance Supervisors (IAIS) Macroprudential Supervision Working Group’s Issues Paper on Structural Shifts in the Life Insurance Sector (see below).

The memo also noted that the MWG is following other jurisdictions’ initiatives, specifically mentioning the UK Prudential Regulation Authority’s recent changes requiring insurers to demonstrate that they can withstand either a single recapture event or multiple recapture events involving highly correlated counterparties. The meeting also featured:

• AG 53 Reports Analysis: Fred Andersen (MN) provided an update on the Valuation Analysis Working Group’s (VAWG) review of Actuarial Guideline 53 (AG 53) reports. While regulators continue their focus on companies with outlier net yield assumptions and reinsurance collectability issues, they also have started to dig deeper into other issues. For example, Andersen noted that regulators plan to provide feedback to companies that have high exposure to internally valued assets. VAWG also plans to pay more attention to higher risk tranches of structured assets, payment-in-kind features, and company-originated assets. The third round of AG 53 reporting is due April 1.
  
• FSOC Update: Director Elizabeth Dwyer (RI - Vice Chair) provided an update on the Financial Stability Oversight Council’s (FSOC’s) activities since the 2024 Fall National Meeting. Dwyer highlighted FSOC’s 2024 Annual Report recommendations related to the insurance sector, including calls for further evaluation of structural shifts in the life industry and the potential impact on systemic risk and financial stability considerations. While the report contains recommendations for state regulators related to offshore reinsurance, credit risk, and the growth of private credit in the life insurance sector, Dwyer emphasized that the recommendations are not binding on states or the NAIC. That said, she noted that most of the recommendations are aligned with the NAIC’s existing macroprudential workstreams.
  
• International Macroprudential Developments: Tim Nauheimer (NAIC) provided an update on international macroprudential activities. Notably, the 2025 Global Monitoring Exercise (GME) launched in the first week of March, and a workshop on individual insurer monitoring (IIM) was held for companies and supervisors.

The RBC Model Governance Task Force’s inaugural call attracted significant attention, with 355 participants. The task force discussed only its 2025 charges, with parties that commented in writing allowed to speak regarding the charges. The charges were adopted without any task force discussion.

While Commissioner Houdek (WI - Co-Chair) wants to move aggressively on the task force’s charges, he also noted the importance of receiving feedback and engagement from industry. The task force met for the second time at the NAIC Spring National Meeting to discuss its 2025 work plan.

  Staff Contact - Sean McKenna

IAIS Publishes Draft Paper on Structural Shifts in the Life Insurance Sector

On March 19, 2025, the International Association of Insurance Supervisors (IAIS) published a consultation draft of the Issues Paper on Structural Shifts in the Life Insurance Sector, which is out for comment until May 19. The Issues Paper focuses on the benefits and supervisory concerns around alternative assets—offering a definition of what constitutes “alternative assets”—and asset-intensive reinsurance. The paper goes on to identify specific financial stability risks associated with these structural shifts and concludes by identifying 46 areas where the Insurance Core Principles and ComFrame may benefit from enhancement to better address alternative assets and asset-intensive reinsurance. The IAIS will conduct a background session on the Issues Paper on April 3 at 7:00 am ET.

  Staff Contact - Sean McKenna

Privacy Updates

Rep. Lori Trahan (D-MA) announced her efforts to reform the Privacy Act of 1974 and issued a request for information seeking input from civil society groups, privacy experts, current and recently terminated government technologists, and concerned members of the public on how to modernize the Act. Interested parties are invited to submit comments by April 30.

On the state front:

• California bill AB 364 was amended to include data localization provisions. Under the amended bill, the California Consumer Privacy Act would be amended to (1) require a business to disclose to a consumer if the business intends to maintain the consumer’s personal information outside of the United States; (2) prohibit a business from maintaining a consumer’s personal information outside of the United States without the consumer’s explicit consent; and (3) prohibit a business from maintaining personal information that is health care information, financial information, or geolocation data in the custody of a foreign government or a third party that is owned or controlled by a foreign government.
  
• Maine introduced a new comprehensive consumer privacy bill—the Maine Consumer Data Privacy Act (LD 1088/HP 710). From July 1, 2026, to December 31, 2027, the Act would apply to persons producing products or services that are targeted to residents of Maine and that during the preceding calendar year (1) controlled or processed the personal data of not less than 100,000 consumers, excluding personal data controlled or processed solely for the purpose of completing a payment transaction; or (2) controlled or processed the personal data of not less than 25,000 consumers and derived more than 25% of gross revenue from the sale of personal data. Starting in 2028, the threshold for the number of consumers whose personal data is controlled or processed will be reduced to 50,000. The bill contains exemptions for financial institutions and affiliates under the Gramm-Leach-Bliley Act and protected health information under HIPAA.

  Staff Contact - Sean McKenna