MPC Meets in San Antonio
The Members’ Participation Council (MPC) held a meeting on October 23, 2025, in San Antonio and online. The MPC General Session featured:
- Comments from then-NOLHGA Chair Joy Higa, who thanked MPC Chair Amanda Barbera for her outstanding performance in her first year as MPC Chair.
- The MPC Chair Report, during which MPC Chair Barbera (Indiana) reviewed NOLHGA’s publications and their audiences and also reviewed the active MPC Executive Committee subgroups and working groups as well as NOLHGA’s non-Board committees.
- The NOLHGA Management Report, in which NOLHGA President Katie Wade updated attendees on progress made in NOLHGA’s workstreams to implement the Vision 2027 strategic plan, including the plans to develop a data repository with dashboard and push button reporting capabilities for guaranty associations and the efforts to deepen the consultant bench to eliminate key person dependencies.
- A presentation by Administrators Education Committee Chair Beth Hoffman (District of Columbia and Maryland), during which she reviewed the educational sessions held in 2024 and 2025 and previewed 2026 sessions on variable products.
- A review of NOLHGA’s budgeting and assessments processes by NOLHGA President Wade and NOLHGA Vice President of Accounting and Finance Keith Sheridan.
- An update on AssessConnect’s company database and assessment services platforms (one of the strategic plan workstreams) by NOLHGA Chief of Staff Jenn Webb.
- Closed-session presentations by the task forces for Global Bankers Insurance Group (North Carolina) and North Carolina Mutual Life Insurance Company (North Carolina).
- A meeting of the MPC Executive Committee.
- The Annual Meetings for GABC and LTC Re.
- A closed-session meeting of the Senior Health Insurance Company of Pennsylvania (SHIP) Task Force.
- A presentation on regional guaranty association meetings conducted by moderator Barry Miller (Delaware) and panelists Andrea Bowers (South Carolina), David Breuer (North Dakota), Lori Geadelmann (Montana), Candie Kinch (Idaho, Oregon, and Wyoming), Felix Schirripa (New Jersey), and Dotty Still (Alabama).
- Hands-on demonstrations of the AssessConnect application by various NOLHGA staff members.
NAIC Updates
Last week, the Restructuring Mechanisms Working Group released for comment revised drafts of the White Paper and Best Practices Document related to corporate divisions and insurance business transfers (also known as restructuring mechanisms). The last drafts of these documents were circulated this time last year, and the working group has not met since last October. Most of the changes reflect stakeholder feedback from last year. New language has been added to the Best Practices that would require an applicant to provide (1) an exhibit showing how management’s reserve estimates have changed over time for the business to be transferred/divided and (2) an exhibit showing how the appointed actuary’s (or third-party actuary’s) estimates have changed over time for the business to be transferred/divided. Notably, the working group incorporated both of NOLHGA’s proposed changes from its June 2024 comment letter. Comments are due November 18.
On October 23, 2025, the Capital Adequacy Task Force and RBC Model Governance Task Force held a joint call to discuss proposed changes to the RBC preamble that would limit the use of RBC to its intended purpose of identifying potentially weakly capitalized companies. Mike Yanacheak (IA) provided an overview of the proposed changes, noting concerns about individuals relying on RBC for unintended purposes. Regulators noted that differences in RBC levels may not necessarily reflect differences in financial strength and that some stakeholders may not be able to appreciate this nuance.
The ACLI has proposed revisions to the proposal to remove some of the more controversial language, and the consumer groups are fully supportive of those changes (see Attachment Two of the Meeting Materials). Matt Cheung (IL) has suggested the addition of certain clarifying language (in the preamble or elsewhere) that would provide additional context around differences in RBC levels between companies, with the goal of reducing any possible confusion.
The meeting was intended to be educational in nature, and no next steps were discussed. At the end of the call, Commissioner Houdek (WI) reminded interested parties that comments on the latest draft of RBC principles were due October 23. The RBC Model Governance Task Force plans to schedule another meeting before the Fall National Meeting to discuss any revisions coming out of this round of comments.
The Life Actuarial Task Force (LATF) exposed revised drafts of templates implementing Actuarial Guideline 55 (AG 55), which is related to the asset adequacy of reinsured business, for a 14-day comment period ending November 5. Fred Andersen (MN) walked through the proposed changes, most of which were straightforward improvements proposed by industry. The introductory instructions note that the templates are simply examples of how to convey the information required by AG 55, but companies are free to report in different ways. New language suggests that tabs should be added for each counterparty that is within the scope of AG 55.
In response to a consumer’s request for AG 55 results to be made public, Andersen explained that all submissions are confidential under VM-30 but that the task force will provide aggregate results and trends (similar to the reporting of AG 53 reviews). Industry has requested that LATF adopt the templates within the next few weeks so companies can begin to prepare submissions in advance of the first filing due date (April 2026).
The task force also adopted its 2026 charges. In addition to some changes reflecting the current status of VM-22 work, the revisions remove the Life and Annuity Illustration Subgroup charges, which will be broadened and moved under the Life Insurance and Annuities Committee.
Staff Contact - Sean McKennaCybersecurity Updates
Kaitlin Asrow, Acting Superintendent of the New York Department of Financial Services (NYDFS), issued new cybersecurity guidance addressing the risks associated with entities becoming increasingly reliant on third-party service providers. The guidance does not impose new requirements or obligations but is intended to clarify regulatory requirements under the NYDFS’ cybersecurity regulation and to share best practices. Asrow stressed that regulated entities are still ultimately accountable for protecting consumers and managing risk and must establish and maintain appropriate internal risk management controls when using third-party service providers.
New York Attorney General Letitia James announced a settlement with public accounting firm Wojeski & Company, resolving allegations that the firm did not take proper measures to secure its clients’ personal information and suffered two cybersecurity incidents that exposed the private information of more than 4,700 New Yorkers. An investigation by the New York Office of the Attorney General found that Wojeski took over a year to notify victims of the data breach, in violation of New York’s data breach notification requirements.
Pursuant to the settlement, Wojeski must pay $60,000 in penalties and take steps to improved its cybersecurity program, including: (1) maintaining a comprehensive information security program to protect the security, integrity, and confidentiality of customer information; (2) encrypting personal information that the company collects, stores, transmits, and/or maintains; (3) developing and maintaining an inventory of where personal data is being stored within its network; (4) maintaining reasonable account management and authentication processes that limit employees’ access to sensitive information as necessary; (5) establishing a program designed to identify and correct security vulnerabilities within its computer network; (6) implementing an incident response plan ensuring timely notice to consumers; and (7) implementing a cybersecurity training program to be completed by all employees.
Staff Contact - Sean McKenna