November included Thanksgiving, family gatherings, holiday decorating, and an increase of NAIC activity. Much of the increase was due to the approach of the NAIC Fall National Meeting in December. Here is some of that activity.
Risk-Based Capital (RBC) Investment Risk & Evaluation Working Group – November 4, 2025
The main topic of discussion was proposal 2025-12-IRE, which covers the proposed alignment of three types of Securities Valuation Office (SVO)-identified funds. The three types of funds are:
- Exchange-traded funds (ETFs)
- SEC-registered fixed income funds
- Private bond funds
The original proposal was developed in relationship to the Life/Fraternal RBC; however, the possibility of uniform handling between all of the RBC formulas was discussed. No decision was made during the meeting. Even the application to the Life/Fraternal RBC was delayed when one of the comments received questioned the handling of the funds between the C-1cs and the C-1o section of the formula. Referrals on the topic had previously been sent to both the Property/Casualty and Health RBC Working Groups. Those groups will discuss the reporting of these funds within each of the formulas. After reviewing changes to its 2026 working agenda, the Working Group adopted the agenda. The group will not meet at the NAIC Fall National Meeting in December.
Life RBC Working Group & Variable Annuities Capital & Reserve Subgroup – via email, November 4, 2025
These groups jointly released for comment three related items. Although the groups met jointly on October 31, the updated documents were officially released on November 4. The comment period ends January 5, 2026. The released documents are variable annuity scope clarifications for VM-21 and Life RBC and consist of:
- Cover questions
- C3P2 Updates v2
- C-3 Phase 1 instructions
All of the documents can be found on the Working Group’s website.
Blanks Working Group (BWG) – November 5, 2025
There were no outstanding proposals that had previously been exposed for comment. Four new proposals were exposed for comment and some editorial revisions were adopted.
| Reference # | Subject | Disposition |
|---|---|---|
| 2023-17 | Would add a new general interrogatory to indicate the reporting of residuals and update requirements of Notes to Financials 1C6 and 5. | Exposed for comment through February 6, 2026. |
| 2022-15 | Proposed instructional clarifications to Health General Interrogatories – Part 2, lines 10.21 to 10.24. | Exposed for comment through February 6, 2026. |
| 2025-19 | Enhances the Schedule T active status codes adding an “S” to indicate a suspended license. | Exposed for comment through February 6, 2026. |
| 2025-20 | Removes the reporting category of investment subsidiaries from Schedule D – Part 6 – Section 1 and the Asset Valuation Reserve. | Exposed for comment through February 6, 2026. |
Regarding proposal 2025-20, the concept of an investment subsidiary does not exist within Statement of Statutory Accounting Principle (SSAP) No. 97. Therefore, statement reporting should not include such a reporting category.
The chair reminded everyone that the Statutory Accounting Principles Working Group (SAPWG) may have some more statement revisions to submit after the upcoming NAIC National Meeting. If that is the case, the proposals will be exposed for comment via email with the comment period ending February 6, 2026. The adopted editorial revisions should be reviewed carefully for items that may affect this year-end’s reporting. The group reviewed and then adopted its 2026 charges and also approved the state filing checklists. BWG will not be meeting at the upcoming NAIC Fall National Meeting.
Financial Conditions (E) Committee – November 5 & November 20, 2025
On November 5, after a review of some of the comments received regarding the Committee’s proposed 2026 charges, a few wording changes were made and explanations were provided for items where suggested changes were not made. The 2026 charges were then adopted. The chair announced the exposure period for proposed revisions to SSAP No. 61 had been extended until November 16, 2025.
It was anticipated that during the November 20 meeting proposed revisions to SSAP No. 61 (SAPWG reference #2024-06) on risk transfer analysis of combination reinsurance contracts would be adopted, revised, or rejected. But at the beginning of the meeting, the chair announced no action would be taken on the issue by the Committee at that time. Those organizations that submitted comments were given the opportunity to summarize their comments. The comments can easily be divided into two groups, those that want what SAPWG had originally adopted and those that wanted the newer version crafted by the E Committee. Furthermore, those supporting the original SAPWG version were regulators (seven states responded and were unanimously against the revised wording), with industry generally wanting the newer version adopted. One of the problems arising with no action being taken during this meeting is the implementation deadline of year-end 2026. Depending upon what is finally adopted, industry may have a significant amount of work to be done to meet that deadline. The chair did state that a decision would be made at its upcoming meeting in December.
The next topic of discussion was the timeline on incorporating collateralized loan obligations into the Life/Fraternal RBC investment risk. The current anticipated timeline indicates the reporting format should be adopted no later than May 15, 2026, with the factors in place by the end of June 2026. Although this timeline is only for the Life/Fraternal RBC, both the Property/Casualty and Health RBC groups will be independently considering revisions to those two formulas.
The Committee then voted to send referrals to the Information Technology Examinations Working Group, the Financial Analysis Solvency Tools Working Group, and the National Treatment and Coordination Working Group regarding enhanced cybersecurity considerations, in particular for mergers and acquisitions.
Health RBC Working Group – November 6, 2025
After a brief review of changes made to its working agenda, the agenda was adopted. Proposal 2025-15-CA was then exposed for a 75-day comment period ending January 20, 2026. The proposal is for substantive structural changes to the H-2 Underwriting Risk recommended by the American Academy of Actuaries (Academy). The revised structure will more closely align with the presentation of the Analysis of Operations in the Health Annual Statement. Factor changes will be considered later. If adopted, the change also would apply to the health sections in the Life/Fraternal and Property/Casualty RBC formulas. Both of those RBC Working Groups will be notified of the exposure period to allow time to review and submit any comments.
Also exposed for comment was a possible Health Annual Statement revision to Exhibit 7 adding a new Part 1B providing further detail of summary of transactions with providers. The new Part 1B would contain three sections providing information on direct medical payments, ceded reinsurance amounts, and net medical expenses by line of business. The exposure period will allow the proposal to be reviewed and refined before being formally submitted to the Blanks Working Group for official consideration. The chair reminded attendees that the exposure period for the referral from the RBC Capital Investment Risk and Evaluation Working group regarding the SVO Fund Alignment Project is still ongoing through December 3.
Joint Meeting of Property/Casualty RBC & Catastrophe Risk Subgroup – November 12, 2025
The following actions took place.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-08-CR | Preliminary 2025 catastrophe event list. | Adopted, effective immediately. |
Each year, a catastrophe event listing covering January 1 through October 31 of the year is released and adopted for use. The listing is then updated in January to include any events that happened between the end of October and December 31.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-19-CR | Proposes separating earthquake and hurricane loss experience data in the worksheets of the formula. | Exposed for comment through January 11, 2026. |
| 2025-20-CR | Would add wildfire to the Rcat section of the formula. Previously wildfire had been included for information only. | Exposed for comment through January 11, 2026. |
| Report from the Academy on Property/Casualty RBC premium and loss concentration factors. | Exposed for comment through January 11, 2026. | |
After a review of new and eliminated items, the group’s 2026 working agenda was adopted. The group received an update from the Health RBC Working Group regarding potential changes to the H2 risk in the Health RBC. If adopted, revisions would affect the health section of the Property/Casualty RBC for those companies offering health coverage. The health proposal was released for comment through January 20, 2026.
Life RBC Working Group – November 14, 2025
Previously, the Working Group had exposed for comment work done by the Academy on possible changes to the Life/Fraternal RBC covariance calculation. If implemented, this would be one of the most significant changes to the formula since its inception. This meeting began with a discussion of comments received on the exposure. The comment letters were quite detailed in nature and represented not only the life insurance industry through the American Council of Life Insurers, but several individual life insurers as well. Across the board, the letters urged the Working Group to slow down this process. Expressed concerns included activity being conducted by other NAIC groups that would affect RBC (for example, the generator of economic scenarios) that had not been included in the Academy analysis process. Commenters also encouraged more thorough analysis on the impact of such changes not just on an industry level, but the possible effect on individual companies. The current analysis was done at a very high, industry aggregate level. It became apparent from the tone of the group’s chair that the project would continue. The chair’s responses usually included the phrase “when this is implemented.”
The group then adopted its 2026 working agenda. The final course of action was the release of a “conceptual” proposal for the future handling of collateral loans. The proposal was labeled as conceptual since it is not fully developed and asks several questions to help provide the Working Group with appropriate feedback. The comment period is for 60 days, ending January 13, 2026. The Working Group will not meet at the upcoming NAIC Fall National Meeting in December.
Capital Adequacy Task Force – November 19, 2025
Since the Task Force will not meet at the upcoming NAIC Fall National Meeting, this meeting was held instead. After adopting minutes of its previous meetings as well as the minutes of its various Working Groups, the Task Force adopted proposal 2025-08-CR, which is the catastrophe list for January 1 to October 15, 2025. The listing will later be updated through December 31, 2025. Its working agenda for 2026 was adopted. Attention then turned to a conceptual exposure by the Life RBC Working Group on the handling of collateral loans and whether that proposal should be considered for the Property/Casualty and Health RBC formulas. After some discussion, it was decided the proposal is not appropriate for the other RBC formulas due to the immateriality within the Property/Casualty and Health industries. The Task Force then heard an update on RBC treatment for SVO-designated investments. The Property/Casualty RBC Working Group indicated it was in favor of the concept in general but felt more detailed analysis by insurer and a better understanding of the underlying risk were needed. The Health RBC Working Group reported it had exposed the idea for comment and was awaiting feedback accordingly. Although originally action on the RBC preamble revisions had been indicated, that did not take place.
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