As industry breathed a short sigh of relief after completing its annual filings due March 1, the NAIC was gearing up its activities. Some groups were not meeting during the March NAIC National Meeting and held their sessions prior to or after that Meeting, while other groups needed to complete activity for further action during the National Meeting. It was a busy month.
Reinsurance Task Force – March 2, 2026
This Task Force was not scheduled to meet during the NAIC Spring National Meeting, holding this session instead. Unfortunately, it was marred by several technical difficulties. After adopting its own meeting minutes from its last session, the Task Force then heard from and adopted the report of the Reinsurance Financial Analysis Working Group. The Working Group had reapproved several reciprocal jurisdictions and certified reinsurers and was continuing that renewal process for 2026. The Mutual Recognition of Jurisdictions Working Group updated the Task Force on its activities.
The discussion then turned to a referral from the Statutory Accounting Principles Working Group (SAPWG) regarding the treatment of derecognized net positive Interest Maintenance Reserve (IMR) (or IMR realized gains) in relation to reinsurance collateral required for applicable unauthorized or certified reinsurers. The referral was a result of SAPWG’s current agenda item 2025-22, which had been released for comment; an issue that affects insurers reporting an IMR. The question arising from the referral is whether treatment of derecognized net negative IMR should reduce collateral requirements symmetrically (decreases collateral requirement) or asymmetrically (does not reduce collateral requirements). The current Statement of Statutory Accounting (SSAP) No. 61 and the corresponding Appendix A-785 provide guidance for derecognized net positive IMR but not derecognized net negative IMR.
Comment letters on the SAPWG exposure were included in the materials and those organizations submitting the letters were given a chance to speak. All of the comments supported the symmetrical approach; however, the letter from the American Academy of Actuaries (Academy) suggested some further guardrails as part of the treatment. The Task Force took no definitive action on the referral during the meeting, citing the need for further regulatory discussion.
Wondering what derecognized IMR is? It’s complicated but, according to SAPWG, occurs when IMR is eliminated (derecognized) by the cedent in a reinsurance transaction when the block of business associated with the recognized IMR has been eliminated. U.S. companies are required to recognize a corresponding amount of IMR for statutory accounting as part of the reinsurance transaction. (Offshore reinsurance companies do not recognize the concept of IMR.)
The meeting concluded with a summary of ongoing NAIC projects that could affect reinsurance.
Risk-Based Capital (RBC) Investment Risk & Evaluation Working Group – March 2, 2026 & March 23, 2026
The saga of the treatment of collateralized loan obligations (CLOs) within the RBC continues with this Working Group. As a reminder, all CLO discussions to date have concerned only the Life/Fraternal RBC. But ultimately, the adopted treatment will most likely be considered for the other formulas as well.
The March 2 meeting opened with a summary of the comments that had been received regarding the Academy’s December 2025 presentation on CLOs. Most of the comments indicated the information presented was a step in the right direction but was not sufficient for making any final decisions. Since the Academy had indicated the project was still a work in progress, those comments made sense.
The Academy then presented a new update on the project. Unlike previous discussions, this update included possible factors, the methodology used to arrive at those factors, and an expanded universe of CLOs instead of a limited few. There were several questions/comments from regulators during the presentation. The newer presentation was then exposed for comment through April 16. The goal is still to add the CLOs to the Life/Fraternal RBC for year-end 2026.
Time did not allow for a review of the comments received on previously exposed item 2025-22-IRE, which covers the structural changes needed to the Life/Fraternal RBC formula for the CLO reporting. That discussion and possible adoption is scheduled for the National Meeting.
At the March 23, 2026 meeting, held during the NAIC Spring National Meeting, the Working Group reported that it had held a regulator-to-regulator session where it received more information from the Academy on its March 2 CLO RBC project presentation and discussed the RBC impact analysis. Since the Academy’s presentation had been exposed for comment, those submitting comments provided brief summaries. The Academy reported on the work that has continued since March 2.
Attention then turned to a proposal that had previously been exposed for comment.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-22-IRE | Provides more granular reporting CLO RBC reporting structure and instructions including the number of issuers and tranche thickness. | Modified and re-exposed through April 17, 2026. |
After reviewing the comments received on the above original proposal and the continuing work by the Academy, NAIC staff made several revisions. These include the addition of Collateralized Bond Obligations (CBOs) and Collateralized Debt Obligations (CDOs), instructions regarding Broadly Syndicated Bond Loans (BSLs), and tranche thickness.
Blanks Working Group (BWG), March 5, 2026 & Via Email March 27, 2026
The following actions occurred on previously exposed items. Unless otherwise noted, all adoptions are effective for year-end 2026 and apply to all statement types. Some items were deferred because SAPWG had not completed its corresponding activity at the time of this meeting. SAPWG activity, including any revisions, is expected to occur at the National Meeting. In the meantime, the comment period on the deferred items has been extended through April 29, 2026.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-17 | New General Interrogatory to indicate method used for reporting residual; updates Notes to Financials (Notes) 1C6 and 5D. | Modified and adopted for year-end 2026. |
| 2025-18 | Enhances instructions for Health General Interrogatory 10.21 through 10.24 including a crosscheck to Exhibit 7 – Part 1. Health statement. | Adopted for year-end 2026. |
| 2025-19 | Adds a status of “S” to the Active Status column on Schedule T, including the footnote. | Modified and adopted for year-end 2026. |
As a point of interest, the “S” is used for final and public suspensions only. If preliminary and/or a confidential action is taken, no “S” would be reported.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-20 | Eliminates the reporting category of “investment subsidiaries” in Schedule D – Part 6 – Section 1. | Modified and adopted for year-end 2026. |
For the Life/Fraternal companies, this also means the elimination of separate treatment of investment subsidiaries in the Asset Valuation Reserve (AVR). Although the proposal originated with SAPWG, during SAPWG’s discussion on the issue it was stressed that this was not an accounting change, did not eliminate the concept of investment subsidiaries, and was not meant to revise any current RBC instructions regarding investment subsidiaries, although a referral was sent to the Capital Adequacy Task Force regarding the statement reporting change.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-21 | Revises the definition of accepted actuarial designation, and clarifies disclosures for long-duration contracts and reconciliation of data used by the appointed actuary in Schedule P. Property/Casualty statements. | Adopted for year-end 2026. |
| 2025-22 | Incorporates electronic reporting to various investment schedules indicating whether the individual investment is publicly registered, a Rule 144A security, a private placement, or not applicable; adds an aggregate disclosure in Notes 5T and the audited financials. | Modified and adopted for year-end 2026. |
| 2025-23 | Inserts the concept of nonadmitted assets to the Separate Accounts reporting. Separate Accounts statement. | Deferred with comments accepted through April 28, 2026. |
| 2025-24 | Updates Notes 18B for Administrative Services Contract disclosure. | Deferred with comments accepted through April 28, 2026. |
| 2025-25 | Augments Notes 2 by adding Valuation Manual (VM)-20 references for PBR life products. Life/Fraternal statements. | Deferred with comments accepted through April 28, 2026. |
| 2025-26 | Modifies annual statement expense categories. | Deferred with comments accepted through April 28, 2026. |
This is not a major rewrite of the expenses categories. Rather, it is an update to some of the language defining the different categories, such as removing a reference to “pony express.”
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-27 | Inserts a section in the Life/Fraternal and Separate Accounts AVR for the inclusion of CLOs, CBOs, and CDOs; adds a footnote to Schedule D – Part 1 – Section 2 for all statements. | Modified and re-exposed through April 28, 2026. |
| 2025-28 | Provides new codes for the Schedule A investment characteristics column for reporting qualifying statutory trusts. Updates instructions and loan type codes for Schedule B regarding mortgages held in qualifying trusts. | Modified and adopted for year-end 2026. |
| 2025-29 | Amends Investment Schedules General Instructions’ restricted asset codes to identify restrictions because of Modco and funds withheld reinsurance agreements. | Deferred with comments accepted through April 28, 2026. |
| 2025-30 | Updates Notes 12 to indicate retirement plan assets valued using net asset value (NAV) are to be separately identified. | Modified and adopted for year-end 2026. |
| Editorial listing. | Adopted. |
The editorial listing is mainly minor corrections. However, some of the items are a little more substantive in nature; for example, the adding of an electronic reporting column and its instructions that were inadvertently overlooked when adding a new reporting section to a schedule. Keep in mind that any editorial items affecting 2026 quarterly reporting are not included in the already published quarterly blank and instructions, although the statement software vendors incorporate those editorial changes into their software.
The following actions were taken on newly introduced items.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-01 | Updates Notes 26 instructions for the handling of an existing intercompany pooling arrangement involving the transfer of assets with fair values different from statement value. | Exposed for comment through April 28, 2026. |
| 2026-02 | Revises Notes 11 to add a crosscheck between Notes 11B and General Interrogatory #26. | Exposed for comment through April 28, 2026. |
| 2026-03 | Addresses the reporting of valuation standards for VM-22 requirements for principle-based reserves for non-variable annuities business. Affects various reporting in the Life/Fraternal quarterly and annual statements and adds an annual VM-22 supplement. | Exposed for comment through April 28, 2026. |
| 2026-04 | Provides a new reporting section to Notes 11 disclosing funding agreements backing funding agreement-backed notes (FABNs). Adds footnote to Life/Fraternal Exhibit 7. | Exposed for comment through April 28, 2026. |
The Working Group received a memorandum from SAPWG regarding which reinsurance assets are to be reported in the Life/Fraternal, Schedule S – Part 8. SAPWG clarified that the final adoption narrowed the original scope of the reporting to include only assets that are subject to funds withheld or modified coinsurance arrangements where investment risk is transferred. The revisions were not meant to change the way that assets subject to those arrangements are factored into the Life/Fraternal RBC calculation.
The group also received a memorandum from the Macroprudential Working Group regarding FABNs and other structures. The memorandum explains the development of reference item 2026-04 above, as well as a corresponding referral sent to SAPWG.
The chair reminded everyone of possible additional exposures occurring after the NAIC Spring National Meeting, His prediction was correct. A March 27 email announced additional exposures. Most of these exposures were the result of activity taken by SAPWG and have a comment deadline of April 28, 2026. Exposures apply to all statement types unless otherwise noted.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-05 | Requires explicit identification where NAV is used in Schedules D and BA. | Exposed. |
| 2026-06 | Adds a reconciling line to Notes 5L(1) identifying assets pledged under multiple agreements. | Exposed. |
| 2026-07 | Instructional clarifications for Schedules D and BA regarding payment due at maturity, the origination balloon payment percentage, and stated maturity date. | Exposed. |
| 2026-08 | Enhances Schedule T reporting by including a status code of “O – Other” for entities having a unique, restricted license type not applicable to one of the existing categories; adds field explanation of “O.” | Exposed. |
Reporting entities that have a unique, restricted license type not fitting into the other categories will use this field. For example, captive insurers, international insurers, or other insurers that are authorized in a U.S. jurisdiction but do not qualify as full admitted carriers and don’t qualify for the other provided categories. In addition, the revision edits the use of the current “N” from “none of the above” to “none.”
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-09 | Provides additional reporting line in Five-Year Historical data for short-term and cash equivalent affiliated investments. | Exposed. |
| 2026-10 | Updates instructions for Liabilities page and Schedule S (Li/F) regarding use of book adjusted carrying value to value funds withheld assets. (See 2026-02 in SAPWG summary below.) | Exposed. |
| 2026-11 | Revises Notes 5A for mortgage loans to disclose mortgage loans acquired through a qualifying investment in a qualifying statutory trust. | Exposed. |
The next meeting of the BWG is May 28, 2026. That is the meeting that usually finalizes all reporting requirements for year-end 2026.
Life RBC Working Group – March 22, 2026
The Working Group received written, but not verbal, updates from its following subgroups: Generator of Economic Scenarios (GOES), Longevity Risk, and Variable Annuities Capital and Reserve.
The following activity occurred for items that had already been exposed.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-17-L | Adds Scope clarifications for C-3 cash flow testing. | Adopted for 2026. |
| 2025-14-L | C-3 (GOES) implementation, including a question and answer document. New material highlighted in yellow. | Re-exposed through April 13, 2026. |
Most of the meeting was devoted to the above item. With the adoption of GOES for life reserving, the Working Group has been discussing how to implement GOES into RBC. Because of previously expressed concerns regarding the use of the Net Asset Earned Rate (NAER) methodology, the American Council of Life Insurers (ACLI) presented a counter proposal suggesting the use of the 10-year U.S. Treasury rate combined with a fixed net spread of 85 basis points. This would replace the original NAIC proposal use of 105% of the after-tax one-year U.S. Treasury rate. The ACLI proposal would be an interim refinement in place while a longer-term NAER alignment is decided upon. During the discussion, the Working Group appeared to be comfortable with the use of the 10-year rate but had several questions/concerns regarding the discount. Further discussion will take place with the goal still being a 2026 implementation.
| Reference # | Subject | Disposition |
|---|---|---|
| Any 2025-16-L | Use of a “look-through” to the underlying collateral of collateral loans reported in Schedule BA. | Re-exposed for comment through April 13, 2026. |
The use of a look-through for these assets is supported by the Working Group. Comments received indicated that the applicable factors should be reduced according to the amount of any over collateralization. The re-exposure includes cover questions to be addressed. It was decided that the above proposal, when adopted, would not be implemented until year-end 2027.
The Academy gave a brief presentation (the meeting was already running over the allotted time) on its Authorized Control Level (ACL) RBC ratio and impairment risk research project. The information included all insurer types. In summary, the research showed:
- ACL RBC ratios show little meaningful relationship with impairment experience.
- Predictive patterns are more stable after excluding companies with very low and extremely high capital levels.
- ACL RBC ratios exceeding 100% become materially less informative of impairment risk.
The Academy has some continued work to do on the analysis, in particular sensitivity testing and using other factors besides the ACL RBC ratio. This information (and more) was provided at all of the RBC Working Group meetings, as well as at the Capital Adequacy Task Force, and the RBC Model Governance Task Force.
Statutory Accounting Principles Working Group – March 23, 2026
As is usual, the meeting was divided into two different parts; a hearing which addresses items that have previously been exposed for comment and a “regular” meeting for the introduction of new items and updates on various projects.
During the hearing, the following activity took place. Unless otherwise noted, all adoptions are effective immediately and all items exposed for comment have a May 1, 2026 deadline.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-25 | Through SSAP No. 56 revisions, incorporates the concept of nonadmitted assets for Separate Accounts reporting. (BWG reference 2025-23.) | Adopted. |
| 2025-30 | Revises SSAP No. 47 and Notes #18B disclosure requirement for administrative services contracts. (BWG reference 2025-24.) | Adopted. |
| 2025-31 | Changes to Interpretation (INT) 05-05 delete references to the discontinued Medicare Part D Coverage gap discount program and adds reference to the federal CMS manufacturer’s discount program. | Adopted. |
| 2025-32 | Removes shaded, outdated text from SSAP Nos. 40 and 90 and the How to Use document. | Adopted. |
| 2025-33 | Modernizes expense descriptions and categories—no accounting change, statement reporting only. (BWG reference 2025-06.) | Adopted. |
| 2025-34 | Updates SSAP Nos. 3, 51, and 52 guidance revisions for optional implementation of economic scenario generator and non-variable annuities. (BWG reference 2025-25.) | Adopted. |
| 2025-01 | Amends SSAP No. 22, clarifying that restrictions placed on sale/leaseback assets (including cash) received from the sale disqualifies the transaction from sale/leaseback accounting; financing accounting must be used. | Adopted. |
| 2025-22 | Impact of net negative IMR on reinsurance collateral. | Deferred waiting response from Reinsurance Task Force. |
| 2025-23 | Revises SSAP No. 7 for IMR proof of reinvestment. | Adopted. |
The concept for the “proof” was adopted; however, an actual template for use and the revisions to SSAP No. 7 will not be finalized until the future release of an issue paper and the revised SSAP No. 7. The proposed template was part of this adoption; however, further consideration may occur when the issue paper is released for comment (planned to happen prior to the NAIC Summer National Meeting in August.) A life/fraternal insurance company would have to pass the proof of reinvestment to move into a net negative IMR position or an increase in the net negative IMR in the general account or for any book-value separate accounts. Insurers that do not complete the template or do not pass the test will recognize losses exceeding gains from sales immediately as a capital loss. Whether or not to include the template as a part of the annual statement, as a supplement, or in some other format has not yet been decided.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-24 | Clarifies disclosure of commitments and contingent commitments; defines commitment. | Deferred pending further work by NAIC staff. |
| 2025-26 | Comprehensive review of SSAP No. 48 equity valuation methods. | Deferred; NAIC staff to work with industry on review. |
| 2025-27 | Requests comments on whether to retain restricted asset codes; particular interest in regulators’ point of view. | Re-exposed for comment. |
| 2025-28 | Allows admission of long-term repurchase agreements through SSAP No. 103 revisions. | Adopted. |
| 2025-29 | Provides clarification on reporting of debt securities—no accounting change. (BWG reference 2025-07.) | Adopted. |
The meeting agenda included the following. Items exposed for comment have a deadline of May 1, 2027.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-13 | Draft issue paper documenting recent changes to residential mortgage loans held in qualifying statutory trusts. (BWG reference 2025-28.) | Exposed for comment. |
| 2026-01 | Disclosure of funding agreement-backed notes (FABNs) and other similar funding agreement-backed structures. (BWG reference 2025-04.) | Exposed for comment. |
| 2026-02 | SSAP No. 61 clarification that funds withheld liabilities should be the book/adjusted carry value of funds withheld assets; statement instructions revisions for Schedule S. (BWG reference 2025-10.) | Exposed for comment. |
| 2026-03EP | Editorial changes and maintenance update. | Exposed for comment. |
| 2024-15 | Draft SSAP and issue paper incorporating new guidance allowing amortized cost measurement method for qualifying derivatives program. | Exposed for comment. |
The Working Group then turned its attention to a referral from the Financial Condition Committee regarding possible further education of how permitted practices may be used to address transition issues for 2024-06 – Risk Transfer Analysis of Combination Reinsurance Contracts and if any tools were needed to accommodate states or jurisdictions that do not allow permitted practices as a matter of policy. After receiving the referral, SAPWG conducted a survey of the jurisdictions, with responses from 47 of the jurisdictions indicating no additional information/tools were needed.
An update from the IMR Ad Hoc Subgroup indicated that a revised SSAP, draft issue paper, and other needed SSAP or reporting instructional changes should be available to the Working Group sometime after the Spring National Meeting.
Previously, the Life/Fraternal Working Group had sent a referral to SAPWG regarding the reporting of “Other Long-Term Assets” in the AVR. NAIC staff will be working with industry on this issue.
SAPWG has scheduled another meeting for May 18, 2026.
Joint Meeting of Catastrophe Risk Subgroup & Property/Casualty RBC Working Group – March 23, 2026
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-19-CR | Creates separate reporting for earthquake and hurricane experience data in the PR100s pages. | Adopted effective year-end 2026. |
| 2025-20-CR | Adds wildfire as an official part of formula. | Adopted effective year-end 2026. |
| 2025-08-CR | Eliminates questions D13 and D14 from interrogatories in the catastrophe (Rcat) section. | Exposed for comment through April 22, 2026. |
Questions D13 and D14 currently ask for certain information that occurs in “convective storm prone areas.” Elimination of the questions is recommended because there are currently no clearly defined areas that are considered prone to convective storms.
The groups heard an update on severe convective storms impact analysis. The vendor model review is expected to begin in April.
The groups briefly discussed flood peril as a possible addition to the RBC; in particular, the availability and affordability of appropriate models. The NAIC is working with FEMA on this concept as well as monitoring the National Flood Insurance Program funds, which is still being considered by the federal government.
The discussion then turned to the premium and loss concentration factors. This included a review of the RBC action level in the current formula compared to the Academy’s suggested change to 45% premium and 65% loss concentration factors.
Health RBC Working Group – March 23, 2026
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-15-CA | Accident & Health (A&H) underwriting risk change for all statements. | Referred to Capital Adequacy Task Force. |
This proposal would change the reporting format of the A&H underwriting risk in all of the formulas. Although this has been adopted for the Health RBC, it needs to go through the Capital Adequacy Task Force exposure and adoption process since it would also apply to Life/Fraternal and Property/Casualty RBC for insurers offering A&H coverages.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-03-CA | Not only would this proposal provide the annual update for investment income but also would slightly change the reporting format of the underlying risk. | Exposed for comment through April 22, 2026. |
The Academy presented an impact analysis regarding immediate versus a three-year phase-in period for new underwriting risk factors (associated with new reporting under 2025-15-CA). The presentation was then exposed for comment through April 22, 2026. Future considerations include a possible diversification credit.
The Academy also provided an update on its RBC impairment project, as well as updates from the Long-Term Care Committee and the Stop-Loss Working Group.
Life Insurance & Annuities (A) Committee – March 23, 2026
The Committee adopted reports of the following groups:
- Life Actuarial Task Force
- Annuity Buyer’s Guide Working Group
- Life Insurance and Annuities Illustrations Working Group
The Committee heard a presentation on annuity illustrations and discussed its priorities for 2026 market data and scanning as used in market regulation.
Financial Regulation Standards & Accreditation (F) Committee – March 23, 2026
This is a standalone Committee with no task forces or working groups reporting to it. The day before this meeting, the Committee met in a regulator-to-regulator meeting and discussed state-specific accreditation issues, as well as voted to award continued accreditation to the insurance departments of New Jersey and Tennessee.
During this meeting, the group adopted revisions to NAIC publications made during 2025 that were required for accreditation purposes. A referral was sent to the National Treatment and Coordination Working Group asking it to consider enhancements to the Company Licensing Best Practices Handbook and the Uniform Certificate of Authority Application. The Committee also referred a Schedule T proposal to BWG requesting the addition of the status indicator of “O – Other.”
International Insurance Relations (G) Committee – March 24, 2026
The G Committee adopted the report of the Aggregation Method Implementation Working Group, which included a potential timeline of its review of U.S. group solvency regulation and exposure of a draft review of U.S. group solvency regulation for a 45-day comment period.
Updates on International Association of Insurance Supervisors’ committee activities were provided as well as an update on international cooperation activities.
Capital Adequacy Task Force – March 24, 2026
The Task Force adopted its working groups’ reports. The Task Force then addressed the following items, most of which had previously been adopted by the various RBC working groups. Task Force approval is needed for finalization. Items that only affect one of the RBC formulas can be adopted by the Task Force without further exposure. If a proposal affects more than one of the formulas, the Task Force exposes the proposal for a comment period before considering adoption.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-17-L | Scope clarifications for C-3 cash flow testing. | Adopted effective year-end 2026. |
| 2025-19-CR | On PRBC separating earthquake and hurricane lines experience data PR100s. | Adopted effective year-end 2026. |
| 2025-20-CR | Implements wildfire as an official part of PRBC. | Adopted effective year-end 2026. |
| 2025-15-CA | A&H underwriting risk format change for all insurer types. | Exposed for comment through April 23, 2026. |
| 2026-05-CA | Elimination of the look-through approach for investment subsidiaries. | Exposed for comment through April 23, 2026. |
The above originated from a referral from SAPWG and an associated change to statement reporting. The reporting change no longer allows valuation of investment subsidiaries by using a look-through approach to the assets held by the subsidiary. In addition, there is no longer a separate reporting category for investment subsidiaries; they are to be reported in the “Other Affiliates” category. Since the RBC currently uses the previous statement approach, SAPWG felt that the formula needed to be revised to mirror statement reporting.
The final agenda item was the Academy’s RBC ratio and impairment risk research project as mentioned in the Life/Fraternal summary above. Since time was allotted for that summary during this meeting, regulators were able to ask additional questions. As mentioned previously, the Academy will continue its analysis and have more information available as that research progresses.
Accounting Practices & Procedures Task Force – March 24, 2026
This was a routine meeting that adopted the minutes of SAPWG and the BWG. There was no other business to be addressed.
Joint Meeting of the Investment Designation Analysis Working Group & the Invested Assets Task Force – March 24, 2026
This was the inaugural public meeting for both these groups. As a reminder, the Valuation of Securities Task Force was disbanded beginning this year and was replaced by the Invested Assets Task Force and three working groups.
The Investment Designation Analysis Working Group met first and took the following actions for proposed amendments to the Purposes and Procedures Manual of the NAIC’s Investment Analysis Office.
| Subject | Disposition |
|---|---|
| Name change of HR Ratings de Mexico, SA de CV to HR Ratings LLC on the credit rating providers listing. | Exposed for comment through April 24, 2026. |
| Update language to indicate other methodologies are permitted for the analysis of parent-subsidiary situations other than what is discussed in the manual. | Exposed for comment through April 24, 2026. |
The group approved referrals to the BWG, the Capital Adequacy Task Force, and SAPWG regarding a proposed statement revision combining the use of the CUSIP, CINS, PPN, and ISIN information into a new Security Identifier paired with a Security Identifier Type field. These identifiers are included in S&P Global’s Global Instruments Cross Reference Service (GICRS), which the NAIC is in the process of integrating into its systems. A proposal will be submitted to the BWG.
The Securities Valuation Office (SVO) provided its annual carryover report. The report covers 2025 investments that were properly filed with the SVO but whose review was not completed during 2025. In addition, the report compares 2025 to previous years. The report showed an overall 19.9% increase in filings for 2025, attributed mainly to the 49.9% increase in private letter rating filings. Of the total 23,319 filings, 2,177 were not completed during 2025 and 1,143 were still classified as carryover as of February 26, 2026. That is an overall 9.3% increase from 2024. However, the SVO felt the increase in private letter rating filings distorted the percentage. Removing the private letter rating filings indicated an increase in carryover filings by 19.7%, indicating the SVO’s resources are being directed away from “regular” SVO filings because of the private letter ratings.
It was then time for the meeting of the Invested Assets Task Force. The Task Force received status reports from its three working groups. The Credit Rating Provider (CRP) Working Group met in a regulator-to-regulator session to receive an update from PricewaterhouseCoopers on its proposed CRP due diligence framework. The Investment Analysis Working Group had also met in a regulator-to-regulator session to discuss its six to nine months working agenda and to refer a proposal to the BWG (2026-05) requiring identification in the fair value hierarchy of instances where NAV is used for valuation purposes. It will be scheduling an open public meeting in April.
As part of its ongoing educational goal, the Task Force heard a presentation from Neuberger Berman regarding insurance companies increasing investments in mortgage loans, including unique risks. The Task Force then received reports from SAPWG and the RBC Investment Risk and Evaluation Working Group projects that were investment related.
RBC Model Governance Task Force – March 24, 2026
The Task Force highlighted its activities of 2025, which were mostly establishing RBC governance policies. Attention then turned to 2026 where the primary focus will be a comprehensive gap analysis and consistency assessment of RBC formulas. As part of this process, in February the Task Force had asked for the submission of comments to help it focus on these goals. There was a good response to the request as the Task Force received 12 letters providing feedback. Bridgewater Analytics summarized those comments and presented them during the meeting. Comments touched on the process in general, to very specific comments for each of the formula types.
Next on the agenda was a draft RBC adjustment process flowchart with requested input on possible improvements. The discussion came down to the following considerations/questions:
- What is the problem and is RBC the correct tool to address that problem?
- In addressing a situation, should policy appropriateness be determined prior to sending an issue to the technical working group? In other words, should the discussion start at the top (this Task Force) and flow downward to the technical groups, or should the flow be from the bottom up?
In understanding the nature of these questions, one needs to remember this Task Force is composed of insurance commissioners or their equivalents. Many of them do not have detailed exposure to RBC issues. Some members indicated the decision should always be from the top down. Many regulators, however, indicated they needed input from their technicians to better understand an issue in making an informed decision. Therefore, discussion and flow determination really should be a combined effort. All agreed what is not desirable is to have something begin at the bottom and then work its way up only to find it falls outside of established policies.
Executive Committee – March 24, 2026
The Committee adopted the report of the joint meeting of the Executive Committee and the Internal Administration Subcommittee. This joint meeting is always regulator-to-regulator. The Committee adopted the reports of two task forces and the Government Relations Leadership Council.
Attention then turned to a request to approve the development of a model law to establish a Department of Insurance-Based Mitigation Program. The request was approved.
Prior to the Spring National Meeting, the Executive Committee had announced it was holding a public hearing on the NAIC’s Policy Statement on Open Meetings. That hearing took place during this session. Seven comment letters were received. Those submitting comments were given an opportunity to summarize their remarks. Although all commentors began by praising the NAIC for a good record of holding open meetings in comparison to other organizations, all also indicated they were uncomfortable with the seemingly rising number of regulator-to-regulator meetings being held. In addition, it “felt like” public meetings were often just presenting what had already been decided in closed meetings with no additional input. All of the comments provided suggestions for improvement; many of those suggestions were identical. The Committee is now taking those comments and suggestions under consideration, with the discussion continuing at a later date.
The Committee was provided a status report on model law development efforts, and reports from the National Insurance Producer Registry (NIPR) Board of Directors and the Interstate Insurance Product Regulation Commission (Compact).
Financial Conditions (E) Committee – March 25, 2026
The Committee adopted reports of its following groups:
- Accounting Practices and Procedures Task Force
- Capital Adequacy Task Force
- Financial Stability Task Force
- Invested Assets Task Force
- Reinsurance Task Force
The Innovations, Cybersecurity, and Technology (H) Committee provided an update on its artificial intelligence (AI) systems evaluation tool and pilot project. The tool is meant to help regulators with the evaluation of an insurer’s use of AI. It works in a similar manner as an audit program checklist. Several states are currently testing the pilot program, which just started in March. Domestic regulators determine which companies will participate in the pilot program.
The Committee approved RBC proposal 2025-20-CR (Wildfire Rcat Implementation) and received information on proposed RBC collateral loan changes for life insurers.
Market Regulation & Consumer Affairs (D) Committee – March 25, 2026
The Committee adopted reports from the following groups:
- Antifraud Task Force
- Producer Licensing Task Force
- Advisory Organization Working Group
- Market Actions Working Group
- Market Analysis Procedures Working Group
- Market Conduct Annual Statement Blanks Working Group
- Market Conduct Examination Guidelines Working Group
- Market Information Systems Working Group
- Market Regulation Certification Working Group
- Pharmacy Benefit Management Working Group
- Speed to Market Working Group
The Committee appointed the Market Conduct Regulation Modernization Working Group and adopted its charges. The Pharmacy Benefit Manager (PBM) Licensure and Regulations Guidelines for Regulators was adopted and will serve as a guide for state insurance regulators considering PBM licensure or regulation.
Health Insurance & Managed Care (B) Committee – March 25, 2026
The Committee adopted reports from the following groups:
- Regulatory Framework Task Force
- Consumer Information Working Group
- Health Care Affordability and Mitigation Working Group
- Health Actuarial Task Force
- Senior Issues Task Force
The committee heard a presentation on health insurance affordability issues and state options to address them. CMS provided remarks on how to improve state/federal coordination and collaboration on Medicare Advantage program issues. The federal Center for Consumer Information and Insurance Oversight provided an update on its recent activities.
Innovation, Cybersecurity, & Technology (H) Committee – March 25, 2026
The Committee heard reports from its working groups and subgroups on the following topics:
- Updating the privacy model law.
- Development of a cybersecurity event notification portal.
- Pilot testing of an AI systems evaluation tool.
- The third-party data and model regulatory framework.
- Efforts to create data analytic teams.
- Work to inventory NAIC data to assist with a gap analysis.
The Committee heard a presentation on insurance AI trends.
Joint Meeting of the Executive Committee and Plenary – March 25, 2026
Adoption by consent of Committee, Subcommittee, and Task Force Minutes from Fall National (December 8–11, 2025) Meeting kicked off the session.
Reports of the following groups’ Spring National Meeting activity were received. As a reminder, minutes from this National Meeting will not be formally adopted until the next National Meeting.
- Executive Committee
- Life Insurance and Annuities (A) Committee
- Health Insurance & Managed Care (B) Committee
- Property & Casualty Insurance (C) Committee
- Market Regulation and Consumer Affairs (D) Committee
- Financial Conditions (E) Committee
- With separate adoption of the Restructuring Mechanisms White Paper
- Financial Regulation Standards and Accreditation (F) Committee
- International Insurance Relations (G) Committee
- Innovation, Cybersecurity, and Technology (H) Committee
Also received was a report of state implementation of NAIC-adopted model laws and regulations.
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