NAIC Updates
The Capital Adequacy Task Force held a call on June 30, 2026, working through a substantial agenda that included adoption of several proposals and significant discussion on the collateralized loan obligation (CLO) RBC factor proposal. The task force adopted the following items:
Proposal 2026-12-IRE MOD, the landmark proposal adopting the American Academy of Actuaries’ C-1 risk charges for CLOs, collateralized bond obligations (CBOs), and collateralized debt obligations (CDOs). The working group agreed to review certain decisions if new information is presented or guidance is received from the task force.
Indiana proposed an amendment committing the Academy to perform additional analysis on middle-market (MM) CLOs, including validation, review of key sensitivity drivers, and tranche-level calibration as the immediate next phase of the structured products roadmap. Philip Barlow (Chair, DC) acknowledged MM CLOs will be on the working group’s future topics list but stated it is premature to commit to next steps before the working group reviews all options and priorities. No other states supported the Indiana amendment.
Proposal 2026-09-L MOD, which updates the Life RBC formula to account for enhanced granularity in Schedule BA reporting for collateral loans. The changes integrate more detailed classifications directly into LR008, Line 51 (Schedule BA Collateral Loans) annual statement source references.
Proposal 2026-10-CA, which incorporates changes to the Annual Statement Source for collateral loans, residual tranches or interests, and tax credit investments on pages XR008, PR008, and PR009 for both the health and P&C formulas, reflecting the adoption of 2024-19BWG Modified by the Blanks Working Group. The changes are consistent with those adopted for life, with no asset valuation reserve (AVR) changes and no interim solution related to mortgage loan collateral.
Proposal 2026-01-L, which updates the Life RBC formula AVR default equity and other invested asset component tables in the Life RBC formula to align with Blanks Working Group changes.
Proposal 2026-02-L, which would allow companies to use look-through treatment for unaffiliated Schedule BA Mortgages for unaffiliated residential mortgage loans in good standing. Recall that the working group has already afforded this treatment for affiliated Schedule BA Mortgages for residential mortgages—including a risk charge of 0.0068.
Proposal 2025-16-L MOD, which adopts the current treatment of collateral loans. Currently, all collateral loans except those backed by mortgage loans receive a flat risk charge of 6.8. This workstream was designed to incorporate look-through treatment for all non-mortgage collateral loans. The working group adopted “Option 2” without the ACLI’s proposed changes, resulting in a tiered treatment based on the collateral loan’s loan-to-value (LTV) ratio (with a 50% haircut floor). This change will not take effect until 2027 reporting.
The task force also re-exposed its proposed 2027 Charges for 14 days after incorporating a few of the ACLI’s proposed revisions.
Finally, Steve Drutz (WA) reminded attendees of the Health RBC Working Group’s efforts to update the health underwriting risk charges (noting potential for significant increases effective year-end 2027). The next working group call is July 15; all interested parties are encouraged to attend.
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