Massachusetts GA Seeks Executive Director

The Massachusetts Life & Health Insurance Guaranty Association (MLHGA) is seeking candidates for its Executive Director position. The current Executive Director, Bill Fisher, will be retiring effective December 31, 2026, following a long and distinguished tenure with the association.

MLHGA is seeking an experienced leader with expertise in insurance products and regulation, insurer insolvencies, and/or guaranty association operations. The preferred start date for the selected candidate is September 2026.

Interested parties should contact MLHGA Board Chair John Deitelbaum by email at [email protected].

Federal Updates

The House Financial Services Committee’s Subcommittee on Housing and Insurance recently held a hearing to examine the role of reinsurance and credit risk transfer (CRT) in diversifying and managing risk across the insurance and housing finance markets. Within this broader discussion, Rep. Troy Downing (R-MT and a former Montana insurance commissioner) stated his opposition to federal involvement in insurance markets and advocated for the elimination of the Federal Insurance Office (FIO). Rep. Downing’s remarks were part of a broader critique of federal proposals to create government-backed reinsurance entities, which he believes would concentrate risk, undermine private sector solutions, and disadvantage consumers in less-risky regions.

The hearing further highlighted federal programs such as the National Flood Insurance Program and Export-Import Bank, which have successfully leveraged private reinsurance and CRT to limit government liability and support market operations. The hearing concluded with calls to expand and institutionalize reinsurance and CRT in federal programs, preserve the public mission of government-sponsored enterprises, and leverage these tools alongside other strategies to support affordable housing and address climate risk.

In other federal news, Secretary of Labor Lori Chavez-DeRemer stepped down on April 21, 2026, after an internal investigation. Keith Sonderling, now the acting Secretary, previously served as a commissioner on the Equal Employment Opportunity Commission (EEOC) and at the Department of Labor during the first Trump administration. With approval for the alternative investments rule pending and recent Employee Benefits Security Administration (EBSA) enforcement priorities released, the department is expected to continue much as it has until a new appointee is confirmed.

NAIC Updates

The NAIC has issued a new Congressional Briefer on how state insurance regulators are responding to the increased insurer exposure to collateralized loan obligations (CLOs) and private credit. The briefer highlights the steps regulators have taken to proactively address any perceived concerns related to these asset classes, including the revised bond definition, increased risk charge for CLO residuals, AG 53 asset adequacy testing, and enhanced oversight over asset-intensive reinsurance through AG 55. The briefer also highlights the NAIC’s efforts to provide greater oversight over rating agencies through a due diligence framework and the authority to challenge individual ratings. Finally, the NAIC emphasized additional reporting for private placements, which will go into effect for year-end 2026 reporting.

On April 20, 2026, the Annuity Buyer’s Guide Working Group convened its first meeting to review comments on the March 16 draft of the Buyer’s Guide on Deferred Annuities. Industry representatives and regulators highlighted the importance of conveying a neutral tone, readability, and clarity for consumers, given that the guide is often provided after consumers have decided they want to purchase an annuity. Stakeholders recommended consolidating consumer questions, simplifying terminology, and aligning the guide’s length with similar resources (such as the Life Insurance Buyer's Guide). Suggestions also included increasing mobile accessibility and incorporating visuals for risk profiles. The working group will assemble a regulator-only drafting group to review feedback, with plans to release a revised draft for additional input that will include explanations for how comments were addressed.

The Life Risk Based Capital Working Group took the following action during its April 23 meeting:

Adopted proposal 2025-14-L, which incorporates the new generator of economic scenarios (GOES) into the C-3 framework. The latest draft replaces the 1-year Treasury rate for determining the discount rate with the 10-year Treasury rate. Brian Bayerle (ACLI) thanked the working group for this change and all its work to finalize the GOES framework. The working group did not incorporate Everlake’s proposed changes for closed structured settlement annuity blocks but agreed to consider their arguments in the course of future C-3 work.

Re-exposed a revised proposal 2025-26-L, which revises the framework for the treatment of collateral loans. The changes would move from a single uniform RBC factor for all Schedule BA collateral loans to a look-through framework tied to the characteristics of the underlying collateral. The initial NAIC staff proposal suggested a single overcollateralization haircut to the RBC factors for those collateral loans backed by residual tranches/interests and those backed by investments in JVs/LPs/LLCs.

At the Spring National Meeting, the working group exposed the ACLI’s proposed framework for overcollateralization adjustments—structured as a sliding scale in which higher collateralization ratios receive larger haircuts to the base look-through RBC factor. The ACLI and the Alternative Credit Council (ACC) each submitted comment letters, which were discussed in detail during the call. Eventually, the working group agreed to re-expose the ACLI proposal, with the following adjustments: (1) incorporation of the ACLI’s recommendation to require independent verification of fair values as a prerequisite to using the ACLI’s banded framework; and (2) consideration of the ACC’s suggestion to make an 80% LTV ratio a mid-point of a tier (since 80% LTV is a prevalent investment limit in states). Ben Slutsker (Chair, MN) reminded stakeholders that the NAIC staff’s original proposal is still in play and encouraged a working group decision on this topic next time it is discussed. The revised exposure had not been released as of April 24.

Adopted Proposal 2026-07-L, which makes structural changes to the Longevity Risk Page to incorporate longevity reinsurance products. For 2026 reporting, companies will be directed to report “zero” for the capital amounts while the American Academy of Actuaries further refines its methodology.

The working group ran out of time to address the other items on its agenda and planned to schedule another call to address the remaining items.

In advance of their June 18 joint call, the RBC Model Governance Task Force and Capital Adequacy Task Force exposed proposed changes to the RBC preamble until June 8. The proposed changes remind companies of statutory restrictions on making certain comparisons of insurers’ RBC but also recognize that there are ways insurers use RBC information outside of its intended purpose of identifying weakly capitalized companies. The proposed revisions provide that whenever an insurer discloses RBC information, it must be consistent with state laws and should be accompanied by a disclosure statement articulating the relevant considerations when using RBC calculations outside of their stated regulatory purpose. The following items constitute the “considerations” that companies are directed to consider:

• Insurers voluntarily strengthening or weakening assumptions used for reserving, resulting in a reduction or increase of an insurer's RBC ratio.
• RBC requirements are often developed with data that extends over a substantial period of years, with actuarial modeling often extending over long horizons. As a result, RBC requirements often represent a relatively stable, durable measure of capital adequacy that is generally not intended to fluctuate materially with short-term market movements.
• While RBC requirements are designed to reflect differentiated risks across components, on their own they may be insufficient for assessing differentiated risks for purposes other than identifying weakly capitalized companies. Limitations may result from RBC components not being sufficiently granular to differentiate risks, given the immateriality as it relates to solvency risk, or a single component not reflecting a comprehensive perspective of risk—as is the case, for example, with asset risk, which may not reflect liquidity, market, or duration risks, which are captured elsewhere in the framework when applicable.
• RBC requirements can fluctuate without indicating a corresponding change in the insurer’s financial condition. Fluctuations may be driven by changes in the RBC formula, dividends, capital infusions, reinsurance transactions, the sale or acquisition of a block of business, and a significant change in new business written.

The Receivership and Insolvency Task Force (RITF) received a primer on Funding Agreement–Backed Notes (FABNs) and similar structures from Tim Nauheimer (NAIC). Nauheimer walked through examples of the various structures, provided an overview of the rise in the use of these instruments in recent years, and described recent changes that will require more detailed reporting about insurers’ FABN activity. Earlier this year, the Macroprudential Working Group sent RITF a referral requesting that the task force analyze how these instruments are treated in an insolvency and to report its findings, including any recommendations. Jacob Stuckey (Chair, IL) emphasized that the focus of insurance regulators generally is limited to what is “left of the red line” in the typical FABN structure (see slide 3 of the NAIC primer).

Ultimately, the task force exposed nine questions for stakeholder feedback. One question specifically asks whether there is guaranty association coverage for these instruments. Amy Malm (WI) suggested that the guaranty associations are best suited to answer this question; Stuckey agreed, explaining that the working group would specifically reach out to NOLHGA on this question. Working group members encouraged industry input on these questions, which were exposed through May 20.

After years of work, the Statutory Accounting Principles Working Group exposed several items related to the treatment of net negative interest maintenance reserve (IMR), including (1) a revised SSAP No. 7 – Asset Valuation Reserve and Interest Maintenance Reserve; (2) an Issue Paper; (3) revisions to other SSAPS; and (4) proposed reporting changes. The issue paper provides details on the history behind the work, specific items that have been addressed by the changes, and an overview of related changes that have been made over the last few years. It also summarizes how the ad hoc group came to its recommendations on various topics. Comments are due June 22.

On June 15, the Life Insurance and Annuities (A) Committee will hear two presentations from consumer representative Richard Weber of the Life Insurance Consumer Advocacy Center (LICAC). The first will discuss issues regarding indexed universal life (IUL) sales and premium financing, and the second will focus on unclaimed life insurance benefits and the inefficiencies associated with varying state adoption of the related NCOIL model and the degradation of the federal Death Master File. The latter presentation likely will be similar to Weber’s presentation to the NAIC/Consumer Liaison Committee at the Spring National Meeting.

International Developments

On April 21, 2026, the International Association of Insurance Supervisors (IAIS) published the aggregate results of its peer review on insurance core principle (ICP) 13 (Reinsurance and other forms of risk transfer), which assessed IAIS member jurisdiction compliance with the ICP’s standards and gathered information on associated supervisory practices. The review was conducted by an expert team of representatives from the United States (Federal Reserve, NAIC, and FIO), Bermuda, Hong Kong, France, India, and South Africa. The report groups participants into three categories: IAIS members that are also members of the Financial Stability Board (FSB) (20), Organisation for Economic Co-operation and Development (OECD) members (28), and other jurisdictions (47). California, Florida, Iowa, Missouri, Pennsylvania, and Texas participated on behalf of the United States. Key findings from the report include:

• There is an overall high level of observance and effectiveness of ICP 13 standards (mostly by FSB jurisdictions and Western Europe and North America), noting “no material risks left unaddressed in requiring insurers to effectively manage their use of reinsurance and other forms of risk transfer.”
• Standards 13.1 (requiring ceding insurers to have a reinsurance program appropriate to their business and part of their overall risk and capital management strategy) and 13.2 (requiring ceding insurers to establish effective internal controls over the implementation of their reinsurance program) were the most frequently observed standards.
• Standard 13.6 (regarding risk transfer to capital markets) was the most difficult to assess due to varying interpretation among jurisdictions and was rated as Not Applicable for nearly 73% of participants. However, observance was high in jurisdictions where applicable.
• The report detailed several areas for improvement, including (1) more comprehensive implementation of Standards 13.1 and 13.2 for those jurisdictions not fully observing them; (2) establishment of clear requirements to implement Standard 13.3 (requiring ceding insurers to demonstrate the economic impact of the risk transfer originating from reinsurance contracts), stating that some jurisdictions only review the impact when there are supervisory concerns; and (3) development of consistent cross-border reinsurance approaches to account for the supervisory framework of the reinsurer’s jurisdiction, as the review found that some members primarily rely on the ceding insurer’s own risk assessment of cross-border reinsurance transactions.

In other international news, at the Cayman International Reinsurance Companies Association (CIRCA) ReConnect 2026 conference on April 16–17, Cayman Islands Premier André Ebanks officially announced that the Cayman Islands intends to submit its NAIC Qualified Jurisdiction application at the end of the quarter. Cindy Scotland, CEO of the Cayman Islands Monetary Authority (CIMA), and other CIMA regulators emphasized that obtaining Qualified Jurisdiction status is both a regulatory and administrative priority. The conference touched on other CIMA priorities, the Cayman Islands’ insurance regulatory framework, and key issues impacting the sector.

Moody’s & A.M. Best Release Reports on Role of Private Credit

On April 22, 2026, Moody’s published a report stating that private credit markets are now confronting increased volatility and liquidity risk as market conditions shift. For life insurers, the report underscores the expansion of private credit holdings and the intensifying regulatory and investor scrutiny of these investments. Moody’s signaled growing pressure to improve transparency, valuation discipline, and disclosure practices as private credit attracts more retail investors and as regulatory focus sharpens.

In addition, a recent A.M. Best report on the credit quality of annuity reserves suggested that increased investment in private credit (among other things) is negatively impacting the stability of the insurance industry. The ACLI issued a press release in response to the A.M. Best report.

Privacy Updates

The House Committee on Energy and Commerce introduced companion privacy bills to establish a federal comprehensive data protection framework. The Securing and Establishing Consumer Uniform Rights and Enforcement over Data Act, or the “SECURE Data Act,” would establish rights for consumers and obligations for data brokers and controllers of data with respect to consumer privacy, sale, use, and access of consumer data. It would contain exemptions for financial institutions subject to Title V of the Gramm-Leach-Bliley Act (GLBA), covered entities and business associates subject to the HIPAA Privacy Rule, and information protected under HIPAA.

The Guidelines for Use, Access, and Responsible Disclosure of Financial Data Act, or the “GUARD Financial Data Act,” would amend Title V of the GLBA to include additional requirements and obligations with respect to data minimization, consumer opt-out rights, limitations on the use of consumer access credentials, consumer notices, access to privacy and disclosure policies, deletion requests, and opt-in requirements for sensitive nonpublic personal information. The bill would include a provision that states it “shall supersede and preempt the application of any State statute, regulation, order, interpretation, or other law that establishes consumer data privacy or security requirements to nonpublic personal information” subject to Title V. However, it clarifies that it does prevent state insurance authorities from enforcing the relevant provisions of Title V or adopting regulations to carry out the applicable provisions of Title V.

On April 16, 2026, Alabama Governor Kay Ivey signed HB 351, the Alabama Personal Data Protection Act, into law, officially making Alabama the 22nd state to enact a comprehensive consumer privacy law. The final version of the bill includes exemptions for (1) financial institutions and data covered by Title V of the GLBA; and (2) covered entities, business associates, and protected health information under the HIPAA privacy regulations.

CalPrivacy is seeking preliminary stakeholder comments regarding the collection and processing of employee data, organizations’ practices regarding privacy policies, and challenges organizations face when disclosing their privacy policies. Interested parties may submit comments through May 20.