New York Superintendent Harris To Depart
New York Governor Hochul recently announced that Adrienne Harris, Superintendent of the Department of Financial Services, will leave office. Kaitlin Asrow, the Executive Deputy Superintendent for Research and Innovation, will be Acting Superintendent effective October 18, 2025. Asrow is in an acting role, but the Governor’s press release said she is “well suited to lead the Department into the future.” Nevertheless, the administration appears to be searching for a superintendent.
Staff Contact - Sean McKennaGaines Named Nevada Insurance Commissioner
Nevada Department of Business and Industry Director Dr. Kristopher Sanchez announced the appointment of Ned Gaines as Commissioner of the Nevada Division of Insurance effective October 6, 2025. Gaines has served as Commissioner in an acting capacity since July 2.
Gaines has more than 25 years of experience in the insurance industry. Prior to joining the Nevada Division of Insurance as the Chief Deputy Commissioner in April 2025, he served 12 years with the Washington State Office of the Insurance Commissioner in a variety of leadership roles, most recently as the Deputy Commissioner of Rates, Forms and Provider Networks. Previously, he worked for several national property and casualty insurers as a compliance manager, claims manager, claims adjuster, and agent.
Staff Contact - Sean McKennaFIO Issues 2025 Annual Report
The Federal Insurance Office (FIO) released its 2025 Annual Report on September 30, 2025. Notably, the report touches on the retirement protection gap and life insurance sector transformation, third-party litigation funding, and an overview of residual markets.
Staff Contact - Sean McKennaCongress Reviewing FDIC Deposit Insurance
On October 1, 2025, Senate Banking Committee Chair Tim Scott (R-SC) sent Acting FDIC Chair Travis Hill a letter asking for information and data on deposit insurance by October 20. The letter follows a September committee hearing on the topic. Sen. Scott cited the 2023 bank failures as a reminder of “run risks” on banks, the importance of deposit insurance, and the need to evaluate deposit insurance reforms. The letter asks for information on current deposits (insured and uninsured), the impact of changing the deposit insurance cap and structure, and the market impact of such changes.
In addition, the Financial Institutions Subcommittee of the House Financial Services Committee planned to hold a hearing on October 9 on The Future of Deposit Insurance: Exploring the Coverage, Costs, and Depositor Confidence. One specific bipartisan proposal is focused on increasing coverage for business accounts at smaller banks.
Staff Contact - Sean McKennaNAIC Updates
The Big Data and Artificial Intelligence Working Group announced it will hold an extended in-person meeting (it is unclear whether there will be a virtual component) at the start of the NAIC’s Fall National Meeting on December 7, 2025, from 8:00 a.m. to 12:00 p.m. ET. Commissioner Humphreys (Chair – PA) and Commissioner Ommen (Co-Vice Chair – IA) elaborated on the issues that will be discussed during the group’s September 29 call:
- AI Systems Evaluation Tool: The working group is reviewing comments received on the draft AI Systems Evaluation Tool and intends to schedule a call during the week of November 16 to discuss revisions informed by the comment letters. The purpose of the December 7 meeting will be to further refine the draft, with the goal of piloting a final version in early 2026. The meeting will have two 90-minute breakout sessions with regulators, consumers, and industry represented at each breakout table.
- Potential Model Law Development: Based on regulator and interested party feedback, the working group is considering the following options for an AI-focused Model Law: (1) development of a disclosure-focused model; (2) development of a health insurance–focused model; or (3) setting aside model development and encouraging wider adoption of the AI Bulletin. North Dakota, Vermont, Colorado, and Peter Kochenburger (consumer rep) supported a focus on disclosure and transparency. Iowa expressed interest in disclosure but said moving forward now would be premature, suggesting information gathered from use of the evaluation tool could help inform the working group’s decision. Humphreys said the next step would be a working group member survey.
Most of the task force’s meeting was spent discussing APF 2025-13, which provides details on the documentation (and timing) requirements for companies that want to use non-U.S. valuation mortality tables. Regulators were adamant that companies that sought to use such tables this year did not provide enough timely information for regulators to determine the appropriateness of the tables. While the task force plans to hold an educational session with the Society of Actuaries on Canadian and Chinese tables, several regulators voiced concerns about this process. Rachel Hemphill (Chair – TX) encouraged task force members to provide detailed comment letters (including specific language) and suggested that an additional exposure period is likely. Comments are due October 22. The task force also exposed its proposed 2026 charges, including the updated VM-22 charges, which reflect the progress made to date and changes that still need to be addressed. Comments on the charges are due October 13.
The Market Conduct Annual Statement (MCAS) Blanks Working Group requested comments on “Required to File” Procedures for MCAS filings. NAIC staff and regulators reported seeing Required to File indicators in situations where the company was not actually required to file an MCAS, due to companies’ confusion on premium reporting for multiple lines of business. Working group leadership would like to hear about issues that stakeholders are experiencing and suggestions for improvement. The comment period is two weeks.
In addition, the working group continued to review the Long-Term Care MCAS (Attachments 3-5 of the Meeting Materials). Within the Interrogatories section, regulators discussed adding questions related to significant rate changes and whether the company uses managing general agents and third-party administrators. Within the General Information section, one member suggested requesting the number of active cancellations by consumers. The working group will continue reviewing the LTC MCAS at its next meeting. Once the group has gathered enough suggestions, it will begin voting on whether to adopt the suggestions. Finally, the working group adopted language to the LTC Data Call & Definitions clarifying that Health MCAS reporting excludes expatriate business (Attachment 2 of the Meeting Materials).
The Risk-Focused Surveillance Working Group adopted updated analyst/examiner salary ranges that are set forth in the Financial Analysis Handbook and Financial Condition Examiners Handbook. The working group considers updates to these ranges every two years; the recommendations are based in part on the results of the 2025 Insurance Department Resources Report survey for financial regulatory positions. The working group also adopted updates to the per diem guidelines in the Financial Condition Examiners Handbook (several states currently base examiner compensation on the salary and per diem guidelines). Changes are based largely on changes in the Consumer Price Index.
Staff Contact - Sean McKennaInternational Updates
In advance of its Annual Conference, the International Association of Insurance Supervisors (IAIS) has made progress on a number of projects:
- Structural Shifts in the Life Insurance Sector: The IAIS remains on track to finalize its Issues Paper on structural shifts in the life insurance sector by the end of the year. The Macroprudential Supervision Working Group is working on the resolution of comments.
- Global Monitoring Exercise (GME): The IAIS is conducting its triennial review of the GME, which included consultation on the individual insurer monitoring assessment methodology. The Macroprudential Committee is reviewing comments and discussing next steps as well as comparing the effects of different accounting standards on the methodology. The key themes in the 2025 GME have also been the focus of recent meetings—the Macroprudential Supervision Working Group is discussing insurers’ increased investment in private credit; the Macroprudential Monitoring Working Group is discussing geoeconomic fragmentation impacting insurers’ management of assets and liabilities; and the Governance Working Group is analyzing AI-related data and discussing AI adoption by insurers.
- Recovery & Resolution: Updates to the Application Papers on recovery and resolution planning will be published for consultation later this year. Last month, the Resolution Working Group received updates (1) from member jurisdictions on recovery and resolution developments; (2) from the Financial Stability Board (FSB) Cross-Border Crisis Management Group; (3) from the International Forum of Insurance Guarantee Schemes (IFIGS); and (4) on the Holistic Framework Targeted Jurisdictional Assessment.
- Insurance Capital Standard (ICS): The IAIS continues to develop its ICS-related materials. The Accounting and Auditing Working Group approved the ICS reporting and public disclosure reporting package, which has been sent to the Policy Development Committee to approve for public consultation. In addition, the Capital and Solvency Working Group has had recent discussions on the development of the ICS implementation assessment methodology.
In other news, the European Insurance and Occupational Pensions Authority (EIOPA) published its 2026 Annual Work Programme outlining its key priorities and activities for the upcoming year related to sustainable finance, digitalization, supervision and supervisory convergence, policy, financial stability, and governance. Highlights include:
- Financial Stability: EIOPA will deliver technical information and advice to the European Commission on the appropriateness of minimum common standards for insurance guarantee schemes within the European Union.
- Financial Stability: EIOPA will further develop and refine its framework for assessing economic, market, and emerging risks to financial stability, leveraging existing supervisory and market data and including systemic risk monitoring and cross-sectoral dimensions.
- Financial Stability: As part of its activities to enhance crisis prevention and preparedness, EIOPA will implement the relevant actions under the Insurance Recovery and Resolution Directive (IRRD), although there is an effort to prevent IRRD implementation.
- Digitalization: EIOPA will support supervisors in identifying and mitigating potential risks associated with the use of AI, focusing on consumer outcomes and seeking to promote the fair and ethical treatment of consumers.
- Digitalization: EIOPA will finalize its policy on ethical and fair data use under the Financial Data Access (FiDA) framework and assess potential supervisory issues, including from a consumer protection standpoint, to contribute to regulatory mandates where applicable.
- Supervision & Supervisory Convergence: EIOPA will leverage its expertise and knowledge to address issues related to internal models used by insurers. EIOPA will participate in colleges of supervisors and perform country visits or comparative studies to identify potential risks or developments that create an unlevel playing field or hinder competitiveness among large groups.
Privacy Updates
The California Privacy Protection Agency Board issued a decision finding that Tractor Supply Company violated the California Consumer Privacy Act (CCPA) by (1) failing to maintain a privacy policy that notified consumers of their rights; (2) failing to notify California job applicants of their privacy rights and how to exercise them; (3) failing to provide consumers with an effective mechanism to opt out of the selling and sharing of their personal information, including through the opt-out preference signals such as Global Privacy Control; and (4) disclosing personal information to other companies without entering into contracts that contain privacy protections. To resolve the allegations, Tractor Supply Company has agreed to pay $1,350,000; implement broad remedial measures; and require a corporate officer or director to annually certify the company’s compliance with the CCPA for the next four years.
The New York Department of Financial Services (DFS) published a Cybersecurity Threat Alert on Cisco Zero-Day Vulnerabilities to warn regulated entities about an active cybersecurity campaign. The threat actor is targeting zero-day vulnerabilities in Cisco Adaptive Security Appliances and specific versions of Cisco Firepower that allow for remote code execution, privilege escalation, and manipulation of read-only memory, presenting substantial risk to victim networks. The DFS recommends prompt action to address the threat and lays out recommended steps for remediation. The United States Cybersecurity and Infrastructure Security Agency (CISA) has also issued an emergency directive on the threat and lays out remediation actions for federal civilian executive branch agencies.
The Cybersecurity Information Sharing Act (also known as CISA 2015), which provides legal safeguards for industry to share threat data with other organizations and the federal government, as well as the State and Local Cybersecurity Grant Program, which provided $1 billion in funding to states and localities to help fend off malicious actors who targeted critical infrastructure, has lapsed in the wake of the government shutdown. The House Homeland Security Committee advanced bills to renew both efforts earlier this month, along with short-term extension proposals, but neither option advanced through the Senate prior to the shutdown.
Staff Contact - Sean McKenna