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 at [email protected].

Company Contact Information Updates Now Easier Through NAIC Filing Process

Beginning with this year’s NAIC quarterly financial statement filing process, a new “Guaranty Association Assessment Contact” field has been added to the electronic Jurat page. Starting in June, the information entered in this field will automatically populate NOLHGA’s universal company database, AssessConnect, streamlining updates for participating guaranty associations. Insurance companies are reminded to review and update their guaranty association contact information to ensure timely receipt of assessment, meeting, and tax notices from state guaranty associations.

Currently, 45 states and the District of Columbia use AssessConnect to manage member company contact information. Companies should also visit AssessConnect directly to:

• Update meeting and tax notice contacts
• Add additional email recipients for assessment notices
• Review and maintain current company contact information

No password is required to make updates. Users simply enter their email address to receive a secure access link that allows them to view, add, or delete contacts associated with their company domain.

For additional information, visit the AssessConnect page on the NOLHGA website.

Federal Updates

On April 30, 2026, the Trump administration issued a new Executive Order: Promoting Retirement-Savings Access for American Workers by Establishing TrumpIRA.gov. The order seeks to create low-cost, portable retirement savings accounts for workers who lack employer-sponsored retirement accounts and directs the Treasury Department and Department of Labor to implement regulations to set up these accounts. TrumpIRA.gov, which will launch in 2027, will identify appropriate financial institutions to manage these accounts.

On April 28, the Treasury Department announced a broad group of nineteen appointments, including several officials with longstanding ties to the White House and President Trump’s campaign. Among the appointees of note, Christina Skinner was nominated to serve as Deputy Assistant Secretary for the Financial Stability Oversight Council (FSOC). Skinner is a tenured associate professor at The Wharton School who has written and spoken widely on central banking, nonbank regulation, and managing systemic risk. She previously worked as a Legal Counsel at the Bank of England.

Also on April 28, the House Financial Services Committee (HFSC) held a hearing to evaluate the impact of bank capital proposals on economic growth. Private credit and nonbank financial institutions (NBFIs) were a subject of discussion, largely stemming from concerns raised by witness Mayra Valladares (MRV Associates). She argued that reduced capital requirements would not stimulate greater bank lending to traditional sectors like mortgages or small businesses but would instead “fuel trading, increase lending to non-banks such as private credit, dividends, and buybacks.” Rep. Davidson (R-OH) questioned the effectiveness of international banking regulations, arguing that they constrain U.S. banks, and expressed concern that the growth of private credit suggests traditional banking may not fully address market needs. Rep. Casten (D-IL) further noted that financial risk can shift from large banks to insurance companies where it may go unnoticed by regulators. He asked how oversight could be broadened to ensure risks are monitored across the entire financial system, not just within the largest banks. Valladares called for more regulatory oversight of NBFIs, stating that these entities are not currently subject to the same risk-based supervision as banks, which she identified as a significant gap in the financial regulatory framework.

NAIC Updates

On May 6, 2026, the NAIC announced that Jeffrey C. Johnston, currently the organization’s Interim CEO, would become the permanent CEO effective June 1. As CEO, Johnston will oversee NAIC operations and work closely with members to advance key strategic objectives focused on financial oversight, data modernization, resilience, and responsible innovation. Before serving as Interim CEO, Johnston held senior leadership positions across the NAIC, including serving as the Chief Financial Officer and Chief of Regulatory Affairs..

In other NAIC news, the Life RBC Working Group made its way through several items on its April 30 call (the meeting materials can be found here). Key developments include:

• Exposed two options for the treatment of collateral loans for 21 days: Option one closely tracks the ACLI’s tiered approach, which would provide tiered haircuts to RBC factors on underlying collateral based on the LTV amount (higher cuts for lower LTV ratios). The ACLI’s approach requires companies to provide independent verification on the value of the underlying collateral to receive any haircut. Option two was developed by working group members and would make two changes: (1) the 90–100% LTV tier would not receive any haircut, and (2) the RBC haircut would be capped at 50%. (In other words, the very low LTV ratios would not receive the significant haircuts that are contemplated in the ACLI approach.) Texas, California, New York, and the District of Columbia all voiced an initial preference for option 2, in part for the sake of efficiency because the 50% haircut cap would not require additional analysis for those loans with low LTV ratios.
• Exposed Item 2026-09-L for 32 days: This item incorporates changes previously adopted by the Blanks Working Group that provide more granular reporting for collateral loans—integrating the more detailed collateral loan classifications into LR008 in the life formula. The proposal also updates guidance for collateral loans backed by mortgages, clarifying that if insurers do not have loan-level information to perform look-through analysis, they cannot receive look-through treatment for those collateral loans. Comments are due June 1.
• Adopted Item 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 affiliated Schedule BA Mortgages for residential mortgages this treatment—including a risk charge of 0.0068.
• Agreed to establish C-3 Alignment Drafting Group: At the ACLI’s request, the working group will establish a drafting group to tackle outstanding questions related to the American Academy of Actuaries’ C-3 Field Test Specs. The ACLI raised a number of design and implementation questions that it would like addressed prior to moving forward with the Field Test (see Attachment 6 of the materials linked above). The ACLI and the Academy will participate in the drafting group, and other interested parties should reach out to NAIC staff (Kazeem Okosun and Maggie Chang) or Ben Slutsker (Chair, MN) to participate.
• Discussed impact of default cost analysis: At the end of the meeting, NAIC staff walked through its analysis of potential double counting in RBC for default costs. The main takeaway is that there does not seem to be a significant impact. Slutsker noted that this could of course vary by company.

On April 30, the Life Actuarial Task Force (LATF) took the following actions:

• Adopted APF 2026-03 (VM-22 SPA Dynamic Lapse Formula): APF 2026-03 updates the calculation in the VM-22 SPA dynamic lapse formula to express values as percentages rather than whole numbers.
• Adopted APF 2026-02 (IMR Reference Inconsistency): APF 2026-02 clarifies IMR allocation in VM-21 and VM-22, aligning it with VM-20 by specifying allocation to model segments rather than selected assets to address inconsistencies and remove ambiguity. Rachel Hemphill (Chair, TX) acknowledged a minor formatting error under VM-22 Section 4.A.7 in the APF, which will be corrected.
• Exposed APF 2026-04 (2017 CSO Clarification) for 21 Days: APF 2026-04 is intended to (1) clarify that references to the 2017 CSO Mortality Table in the Valuation Manual refer to the loaded version unless otherwise indicated; and (2) correct information about the table’s location (available on the Society of Actuaries website).
• Disbanded the Variable Annuities Capital and Reserve Subgroup: LATF voted to disband the subgroup since the subgroup’s main charges (to monitor changes to the variable annuities reserve framework and RBC calculation and determine whether changes are needed) have been achieved, noting significant work completed on variable annuity reform and SPA updates. Hemphill explained that ongoing work related to VM-21 fits under LATF’s broader responsibilities. Once the Life RBC Working Group considers the subgroup’s disbandment, it will go through the typical NAIC approval process.
• Discussed issuing a request to review the VM default and spread methodology: The task force will request that the Academy’s Life Reserves Work Group (LRWG) review the VM default and spread methodology, last reviewed in 2009, as part of LATF’s ongoing charge to ensure actuarial frameworks remain current and appropriate. Regulators expressed support for the review, citing periodic questions from industry on the methodology and the need for a fresh assessment. In the request, the task force will inquire about the Academy’s current workload, whether the LRWG should coordinate with the Academy’s Life Practice Council, and a feasible timeline for completing the review.

The Privacy Protections (H) Working Group met recently to discuss comments on Article VII of the Chair Draft Revising the Privacy of Consumer Financial and Health information Regulation (#672). The discussion focused on three main pieces of the revised Article VII:

• Exclusion from the act for nonprofit organizations sharing information to assist with law enforcement investigations of criminal and fraudulent acts relating to insurance (Section 25): The ACLI expressed confusion regarding the intent of this provision. Director Dwyer (Chair, RI) clarified that it is not intended to have a deeper meaning and is meant to encourage compliance with mandatory reporting requirements, such as reporting performed by the National Insurance Crime Bureau (NICB) and the NAIC. Consumer representatives and a representative of the Coalition Against Insurance Fraud commented on potential ways to limit the exception to only the NICB, the NAIC, and successor organizations.
• Disclosure of personal information and consent requirements: Harry Ting (consumer representative) disagreed with NAMIC’s proposal to allow verbal authorization for disclosure of personal information without having an accompanying written or electronic authorization. He also expressed concerns that the current drafting does not include provisions reflective of state restrictions on the sharing of certain types of health information, such as substance abuse disorders, that go beyond HIPAA protections.
• Interplay with state and federal laws: Chris Peterson (Arbor Strategies) and the consumer representatives discussed whether Section 25 (Relationship to Federal Rules) should specifically reference Part 2 of Title 42, CFR. The discussion boiled down to whether health plans are separately required to comply with such provisions or if they are covered by the current reference to compliance with HIPAA. Dwyer noted that the drafting group will continue to investigate this concern for the compiled draft.

Next, the working group will meet to discuss comments on Article VIII of the revised draft (currently exposed through May 6). Dwyer said the working group intends to release a comprehensive draft of the revised model, including definitions, for review and discussion at the Summer National Meeting.

During its April 30 call, the Innovation, Cybersecurity, and Technology (H) Committee adopted the Cybersecurity Working Group’s proposal (see Attachment B) to create a centralized cybersecurity event notification portal. The portal, which has been under discussion by the Cybersecurity Working Group for some time, would centralize and achieve consistency in reporting cybersecurity events among states that have adopted the NAIC Insurance Data Security Model (#688).

The Market Analysis Procedures Working Group (MAPWG) began its meeting by announcing Jo LeDuc (Chair, MO) has left the Missouri Department of Commerce & Insurance, and Raymond Guzman (previous Vice Chair, MD) will be Chair with Cassie Sousy (OR) as Vice Chair. In light of the leadership change, MAPWG will review all MCAS lines this year beginning with private passenger auto (PPA) and homeowners (HO) as they have the same ratios. The working group also reviewed updates to the MARS level 2 edits. This received minimal comments during the meeting, and the working group will continue its review at later meetings.

International Developments

On April 29, 2026, the Bank of England’s Prudential Regulation Authority (PRA) published Consultation Paper (CP) 8/26 outlining proposed changes to the regulation of funded reinsurance. According to the CP, the changes have been primarily motivated by the increase in UK insurers’ use of funded reinsurance, particularly to support growth in the bulk purchase annuity market. The PRA observed that current regulations do not adequately reflect the underlying risks of funded reinsurance compared to that of economically similar assets, leading to excessive reliance on these structures. If left unaddressed, the PRA is concerned about the potential for rapid accumulation of underestimated risks.

Consequently, the PRA aims to address these risks by aligning regulatory treatment more closely with actual risk exposures. The proposal was informed by a thematic review of insurers’ use of funded reinsurance, results of the 2025 Life Insurance Stress Test, and industry stakeholder roundtables. At a high level, the proposal seeks to:

• Revise the calculation of the counterparty default adjustment for funded reinsurance arrangements
• Require a more granular assessment of credit quality and maturity of funded reinsurance cashflows, using the reinsurer’s financial strength rating and allowing for upward notching based on certain collateral criteria
• Establish a formal definition of “funded reinsurance” and clarify the requirements’ scope, which will apply only to new arrangements backing annuity or capital redemption liabilities after September 30, 2026, with a proposed implementation date of July 1, 2027
• Amend the PRA Rulebook and Supervisory Statement 5/24 to reflect these new expectations and definitions.

For existing funded reinsurance transactions, firms currently hold capital worth 2–4% of the value of the underlying liabilities. Under the proposals, the PRA estimates that the capital held for the average existing funded reinsurance transaction would shift to around 10%. The CP further explains that the changes are designed to remove incentives for excessive or underpriced use of funded reinsurance, encourage firms to transact with more creditworthy counterparties, support the inclusion of strong collateral arrangements, and promote greater investment in UK productive assets. Comments are due July 31.

On April 29, the Financial Stability Board (FSB) published its final report on the Scope of Insurers Subject to Recovery and Resolution Planning (RRP) Requirements under the Key Attributes, following its November 2025 consultation. As a reminder, the report does not create a new standard or expand the scope of the Key Attributes, but instead provides guidance to authorities on how to identify insurers that should be subject to RRP requirements—namely, those that could be systemically significant or critical upon failure or whose failure could pose a threat to financial stability. The FSB also reiterates that this work is not a reintroduction of the global systemically important insurer (G-SII) framework, with scope determinations remaining firmly in the hands of national authorities. Consistent with the consultation, the final report retains the six-criteria framework (nature, scale, complexity, substitutability, cross-border activities, and interconnectedness) and the concept of a mandatory override where certain conditions are met.

Substantively, the final report is largely unchanged, with updates focused on clarification rather than policy shifts. The most notable refinement relates to the definition of “critical functions,” where the FSB reinforces that a function may be considered critical if its disruption would have a material impact on the financial system and/or the real economy—clarifying that impact on either is sufficient. The final report also adds modest direction on how authorities should operationalize the framework, emphasizing the need for distinct, criterion-specific analysis, jurisdiction-specific assessments of materiality, and transparent application. Overall, the report confirms a principles-based, supervisory judgment–driven approach, with the mandatory override (critical functions or significant financial stability impact) continuing to serve as the key backstop to ensure the appropriate scope of RRP requirements.

The International Association of Insurance Supervisors (IAIS) published a draft Issues Paper on customers receiving value from insurance products for comment through July 28. The Issues Paper outlines supervisory findings and challenges related to the value delivered by insurance products, noting that consumers often struggle to assess value due to complexity, behavioral biases, and information asymmetries, which can be further complicated by market practices such as bundled sales, opaque pricing, and high commissions. Supervisors identified instances of loyal customers being charged higher premiums unrelated to risk, as well as misleading pricing representations and a lack of transparency in product costs.

To address these concerns, jurisdictions have adopted a range of approaches that are detailed in the paper, such as requiring explicit assessments of “fair value” or “value for money,” considering both the price and the benefits provided, as well as the quality of product design, service, and claims handling. Supervisory tools include governance reviews, transparency measures, and the use of indicators (such as claims ratios and investment returns) to monitor product performance and detect low-value offerings. Effective product design that encourages risk reduction, responsive and consumer-focused claims handling, product flexibility, and downside protection are highlighted as factors that enhance value. The IAIS scheduled a background session on May 12 to discuss the paper in more detail; registration is available here.

On April 29, the Bermuda Monetary Authority (BMA) published its analysis on Liquidity Risk in the Bermuda Long-term Insurance Market (Year End 2024), building on its prior assessment of 2023 data and basing observations on Commercial Insurers’ Solvency Self-Assessments, investment allocations, and stress testing results. The observations were generally positive (with targeted calls for improvement) and centered around three topics:

• Liquidity Risk Management Practices: The BMA observed implementation of liquidity risk management programs, such as liquidity stress tests and liquidity buffers. However, the report observed “varying levels of sophistication” in liquidity risk management across the sector and pointed to room for “more sophisticated contingency planning.” The BMA identified opportunities for enhancement for some entities through enhanced thresholds, diversification of funding channels, cash flow projections, and internal stress testing.
• Investment Allocation and Available Liquidity Sources: The report observed growing allocation to alternative assets (“less liquid investments”). Nevertheless, a “stable liquidity profile” remains, with the foundation being high-quality, fixed income assets.
• Liabilities and Liquidity Coverage Ratios: Again, the findings on the liability side were positive. The report observed that the uptick in surrenders during 2022–2023 had stabilized (likely through interest rate trends and insurer management). Likewise, the percentage of lapse-exposed liabilities decreased year-over-year, with increased use of surrender penalties and time restraints as lapse mitigation features. Liquidity coverage ratios under both the BMA and IAIS stress test methodologies remain generally strong, with an aggregate liquidity position that exceeds potential demands.

The BMA expects insurers to address the risk management gaps that were observed. Liquidity risk management remains a priority for the next filing cycle, in particular enhanced governance and controls, valuation and risk management, stress testing sophistication, and contingency planning.