Missouri GA Seeks General Counsel

The Missouri Life & Health Insurance Guaranty Association and Missouri Property & Casualty Insurance Guaranty Association are seeking to obtain the services of an individual or law firm to serve as outside general counsel to one or both associations. The general counsel will serve as legal advisor to one or both associations and their Boards of Directors. The issues encountered range from statutory opinions, Board governance best practices, representing the association on national multi-state liquidations, employee liability issues, and representing the associations in litigation.

The general counsel is expected to monitor current, new, and pending state and federal legislation as well as case law as applicable to the associations. The general counsel should inform and provide direction to Board members and the Executive Director regarding compliance issues and any impact on the associations.

Any attorney designated to provide any portion of the services must be a member in good standing of the Missouri Bar. The selected individual or firm will report to and be managed by the Executive Director and Board Chairs from each association.

Interested parties should contact Executive Director Tamara Kopp ([email protected]) by July 31, 2026.

International Developments

Insurance Europe responded to the European Insurance and Occupational Pensions Authority’s (EIOPA) consultation regarding minimum common standards for insurance guarantee schemes (IGSs), challenging the rationale for EU-level harmonization. Insurance Europe contended that divergent jurisdictional outcomes stem from deeper structural differences (such as tax regimes, contract law, consumer protection, language, and distribution) rather than variation among IGSs. The trade group suggests that even under a harmonized IGS framework, disparities in national insolvency proceedings, claims administration, and technology infrastructure would persist. Insurance Europe urged the EU to focus on enhancing cross-border supervisory coordination and data sharing and cautioned that advancing IGS reform before the Insurance Recovery and Resolution Directive (IRRD) is fully operational risks creating duplicative structures and compounding costs for both insurers and policyholders.

In other EIOPA news, on July 8, 2026, EIOPA published for consultation two draft regulatory technical standards on valuation methodologies for resolution of insurance/reinsurance undertakings and groups under the IRRD. These are EIOPA’s final policy instrument consultations regarding IRRD implementation. The first covers methodologies for assessing asset and liability values in resolution and calculating the buffer for additional losses in provisional valuations. The second addresses post-resolution action valuation to determine whether shareholders, policyholders, beneficiaries, claimants, and other creditors would have fared better under normal insolvency proceedings. Comments are due October 20.

The International Association of Insurance Supervisors (IAIS) published its Mid-year Global Insurance Market Report (GIMAR) last week, presenting interim outcomes of its 2026 Global Monitoring Exercise (GME). The report notes that while structural shifts in the life insurance sector are not a focus of this year’s GIMAR, work in this area continues under the IAIS Roadmap 2026–2027, building on the IAIS Issues Paper, and includes enhanced data collection through the GME to strengthen systemic risk analysis as well as a review of IAIS supervisory and supporting material.

The 2026 GME identifies three sector-wide themes as top priorities for insurers and supervisors, recognizing their interconnections and potential non-linear effects:

• First, the report examines the impact of macroeconomic risks on life insurers’ balance sheets. It notes that several factors pose challenges: rising interest rates, widening credit spreads, liquidity pressures from derivative margin calls and policyholder surrenders, sovereign risks, growing interconnectedness with non-bank financial intermediaries, and capital and asset-liability management strains. These risks are particularly pronounced given life insurers’ exposure to long-duration liabilities and their sensitivity to interest rate shifts.
• Second, the report addresses transmission channels of geopolitical risk in non-life insurance, highlighting that escalating geopolitical tensions are driving energy price volatility; inflating claims costs across motor, property, and liability lines; elevating maritime and aviation risks; and complicating war exclusions and cyber risk coverage.
• Third, the report focuses on the impact of advancements in AI and technology on insurers’ cyber resilience, noting that frontier AI models are reducing the time to identify vulnerabilities and mount cyber-attacks, exposing insurers both as underwriters and as potential victims of operational disruption, and underscoring the need for effective operational resilience frameworks.

All of this will be addressed in greater detail in the year-end GIMAR.

NAIC Updates

The NAIC published its Summer National Meeting Preview last week, providing a roadmap of anticipated activity at the upcoming meeting in August. Noteworthy items include:

General

• Disclosure of Material Transactions Model Act: The Financial Condition (E) Committee will discuss whether changes should be made to the Disclosure of Material Transactions Model Act (#285) with respect to its thresholds and requirements related to reinsurance.
• Cybersecurity Response Framework: The Market Regulation and Consumer Affairs (D) Committee will receive an update on the development of a cybersecurity response framework for multistate coordination of cybersecurity events.
• Privacy Model Revisions: The Privacy Protections Working Group will hear comments on the soon-to-be-exposed full draft of the revised Privacy of Consumer Financial and Health Information Regulation (#672).
• Third-Party Data & Models: The Third-Party Data and Models (H) Working Group will discuss potential revisions to its third-party framework focused on pricing and underwriting data and models.
• Macroprudential Updates: The Financial Stability Task Force will receive the macroprudential risk assessment report and hear an update on the Financial Stability Oversight Council (FSOC).
• Market Conduct Modernization: The D Committee will receive an update on market conduct regulation modernization efforts, including a summary of comments received from interested parties and several listening sessions.
• AI Systems Evaluation Tool Pilot: The E Committee and Big Data and Artificial Intelligence Working Group will receive an update on the AI systems evaluation tool and its pilot.
• Aggregation Method: The Aggregation Method Implementation (G) Working Group will discuss finalization of the Aggregation Method based on recommendations from its US Group Solvency Review.
• IAIS Updates: The International Insurance Relations (G) Committee will discuss progress on several International Association of Insurance Supervisors (IAIS) initiatives, including the insurance capital standard (ICS), insurance core principle (ICP) and ComFrame implementation assessments, and plans for addressing strategic themes and emerging risks.
• Cross-border Reinsurance: The G Committee will discuss activities and issues related to cross-border reinsurance.

Life & Annuity

• AG 55 Guidance Document: The Life Actuarial Task Force (LATF) will discuss an Actuarial Guideline LV (AG 55) year-end 2026 guidance document related to testing the adequacy of reserves for certain life reinsurance treaties.
• AG 53 Reviews: LATF will hear an update on regulator reviews of Actuarial Guideline LIII (AG 53), which relates to testing the adequacy of life insurer reserves.
• VM-22 Retrospective Application: LATF will discuss comments on retrospective application of VM-22.
• SAPWG – Key Exposures: The Statutory Accounting Principles Working Group will hear comments on previously exposed items related to the negative interest maintenance reserve (IMR), fair value disclosures, asset liability management (ALM) derivatives, and the valuation of funds withheld assets.
• Level 3 Assets: The Invested Assets Task Force will hear a presentation regarding the recent growth of certain Level 3 assets, including auditing and reporting of said investments.
• CRP Working Group – Revised Due Diligence Framework: The Credit Rating Provider (CRP) Working Group will discuss comments received on the draft due diligence framework and consider exposure of a revised proposal.
• IDAWG – P&P Manual Amendments & CRP Application: The Investment Designation Analysis Working Group will receive proposed amendments related to (1) the U.S. Government Money Market Fund List and (2) modeling of, and assignment of NAIC designations to, collateralized loan obligations (CLOs). The working group will also discuss a nationally recognized statistical rating organization (NRSRO) application for acceptance as a CRP.
• RITF – FABN Proposal: The Receivership and Insolvency Task Force is scheduled to meet on August 5 to receive comments and discuss the treatment of funding agreement–backed notes (FABNs) in a receivership.
• Compact – Annuity & LTC Uniform Standards: The Interstate Insurance Product Regulation Commission will continue consideration of proposed amendments to individual annuity and LTC rate Uniform Standards that were the subject of a July 2025 public hearing.

Health

• Mark Cuban Presentation: The Health Insurance and Managed Care (B) Committee will hear a presentation on prescription drug affordability from Mark Cuban, founder of the Mark Cuban Cost Plus Drug Company.
• ERISA Preemption & PBM Laws: The Regulatory Framework Task Force will consider adoption of a guidance document on ERISA preemption and state pharmacy benefit manager (PBM) laws.
• ICHRAs: The Regulatory Framework Task Force will hear an update on individual coverage health reimbursement arrangements (ICHRAs) from the Robert Wood Johnson Foundation.
• Substance Use Disorder Coverage: The Prescription Drug Coverage Working Group and the MHPAEA Working Group will meet in joint session to consider coverage of prescription drugs used to treat substance use disorders.
• LTC Riders: The Senior Issues Task Force agenda has not yet been fully developed but will likely include further discussion on LTC riders.
• PBM Examination Discussion: The PBM Working Group will hear a discussion from state PBM examination contractors on findings and suggestions.
• Consumer Representative Presentations: Consumer representatives will present to the NAIC/Consumer Liaison Committee on their 2026 health priorities, focusing on misleading marketing of health coverage, trends affecting Marketplace enrollment and alternative coverage products, efforts to expand biomarker testing, and challenges with expanding LTC options.

The Financial Condition (E) Committee met on July 8 to consider adoption of three major RBC changes previously adopted by the Capital Adequacy Task Force: (1) changes to the RBC preamble; (2) revised risk factors for CLOs, collateralized bond obligations (CBOs), and collateralized debt obligations (CDOs) in the life RBC formula; and (3) revisions to the treatment of collateral loans (effective for year-end 2027 reporting).

Commissioner Houdek (Chair, WI) noted that the RBC Investment Risk and Evaluation Working Group plans to develop a workplan for further refinement of the CLO framework (likely additional analysis of middle market CLOs) and other working group priorities; an update on the workplan is expected at the Summer National Meeting. Finally, Ken Catrone (CT) provided an update on the framework that allows regulators to challenge CRP ratings on individual assets. The technical aspects necessary to operationalize the challenge framework are now complete.

The Third-Party Data and Models Working Group exposed its revised Regulatory Framework for Third-Party Data and Model Vendors through August 5. As discussed at the Spring National Meeting, the revised draft is specific to property and casualty insurance pricing and underwriting, which is characterized as the “first phase” of the broader regulatory framework. Importantly, the framework maintains that insurers bear full accountability for regulatory compliance, including independent validation of model suitability, ongoing testing and monitoring, and verification of data quality. Key components of the revised framework include:

• A centralized, voluntary multi-state registry administered by the NAIC would require participating vendors to submit corporate governance details and data/model governance programs aligned with the NAIC’s AI Principles and Model Bulletin. All submitted information would be treated as confidential.
• Third-party data and models used by insurers would need to be included in rate and underwriting filings, either within an insurer’s own submission or as a standalone vendor filing, and regulators could bar use of a vendor’s products if the vendor fails to provide requested information.
• Vendors would be subject to an annual attestation in which a senior leader with appropriate expertise certifies both the effectiveness of the governance program and compliance with applicable insurance laws in each state where their products are deployed.
• Vendors must submit material changes to datasets or models to the registry, including model decommissioning.

Federal Updates

The Trump Administration’s recently released Unified Agenda of Regulatory and Deregulatory Actions contains a number of health policy items relevant to state-based insurance regulation, including:

Proposed Rules

• Exchange Pre-Enrollment Verification (codifying HR 1): Expected July 2026; already at the Office of Management and Budget (OMB) for review.
• Short-Term, Limited-Duration Insurance (STLDI): Expected July 2026; already at OMB for review.
• State Innovation Waivers & Health Care Choice Compacts: Expected August 2026; not at OMB.
• Expanding Access to Individual Coverage Health Reimbursement Arrangements (ICHRAs): Expected July 2026; not at OMB.
• Mental Health Parity and Addiction Equity Act (MHPAEA): Expected November 2026.
• Association Health Plans: Expected November 2026.
• Drug Copay Assistance Regulation (titled “Cost-Sharing Under the ACA”): Long-term action; no publication date assigned.

Final Rules

• Department of Labor PBM Fee Disclosure: Expected September 2026; not at OMB.
• No Surprises Act (air ambulance services, agent/broker disclosures, and provider enforcement): Expected September 2026; not at OMB.
• Transparency in Coverage (primarily non-drug items and services): Expected July 2026; not at OMB.

AI Updates

On July 7, 2026, Democratic members of the House Financial Services Committee issued a broad solicitation of stakeholder input regarding how current federal statutes and supervisory frameworks apply across the financial services sector and whether reforms are needed to create a “federal financial AI framework.” The inquiry poses 54 questions across more than a dozen subject areas. Comments are due August 14. Of particular relevance, the Request for Information:

• Asks what disclosure, valuation, and risk management standards should govern AI use by private equity, hedge fund, and private credit managers given accelerating retail access to private markets and the growing reliance on AI in underwriting, valuation, and due diligence for illiquid assets.
• Questions how fiduciary duty, Regulation Best Interest, and supervisory obligations apply when AI systems rather than humans originate investment recommendations or execute transactions.
• Cites IMF warnings that correlated AI failures pose systemic risks to financial intermediation, payments, and market confidence, and separately flags previous Democratic concerns over a potential AI investment bubble.

On July 7, the Financial Stability Board (FSB) hosted a virtual outreach event on sound practices for the responsible adoption of AI by financial institutions. Michelle W. Bowman, the Federal Reserve Board’s Vice Chair for Supervision, delivered opening remarks. A slide deck summarizing the FSB’s consultation paper has been posted online.

AI Updates

The California legislature continues its work to adopt a revised insurance privacy law. SB 354, the Insurance Information and Privacy Protection Act, was previously passed by the California Senate in June 2025. The California Assembly has substantially revised the bill. Notable revisions include:

• Structural change: Rather than introducing a new article to the California Insurance Code, the revised bill would amend the existing Insurance Information and Privacy Protection Act (California Ins. Code Section 791 et seq) and add new provisions to the existing act.
• Expanded scope of covered entities: The revised bill would apply to insurance licensees, surplus line insurers, and reinsurers, as well as such entities’ third-party service providers to the extent they (a) process consumers’ personal information in connection with the business of insurance or (b) engage in insurance transactions with consumers. The act exempts (i) persons and entities engaged in the business of title insurance; (ii) health care providers governed by California’s Confidentiality of Medical Information Act and covered entities and business associates governed by the HIPAA privacy, security, and breach notification rules; and (iii) Securities Exchange Commission–regulated brokers, dealers, investment companies, or registered investment advisors, or depository institutions or affiliates of depository institutions that are subject to the Gramm-Leach-Bliley Act (GLBA).
• Prohibition on “sharing” personal information: In the revised bill, provisions that previously prohibited or conditioned ”processing” of personal information for consent/opt-in/opt-out purposes instead govern ”sharing” of personal information. This would narrow the prohibitions to disclosure to third parties rather than all data-handling activities.
• Privacy notice timing & content: The revised bill would require covered entities to provide consumers with a privacy notice within 21 calendar days after first collecting, processing, or sharing a consumer’s personal information (increased from the 14-day deadline in the Senate’s version). The revise bill would also include an exception where an insurer or surplus line insurer receives personal information from a producer in connection with an application that does not result in policy issuance, and the insurer does not further process, retain, or disclose the information.
• Records retention: The revised bill removes the deadline for destruction of personal information within 90 days of determining that such information is no longer needed. The revised bill would instead require the covered entity to take reasonable steps to securely destroy, delete, or deidentify information “in a timely manner in accordance with its records retention schedule.”