While industry was wrapping up and filing its second quarter statement filings by August 15 (OK, technically August 17 because the 15th fell on a weekend), the NAIC conducted its Summer National Meeting. Most of the below summarizes activity occurring during that meeting. However, one group, the Blanks Working Group, did not meet at the National Meeting, but instead conducted a meeting late in August. In addition, there were some email notifications that occurred before and after the National Meeting.
Capital Adequacy Task Force – Via Email Notification, August 6, 2026
The Task Force sent out notification of a conducted e-vote. During that e-vote, the Task Force adopted the following:
- 2027 proposed charges
- Meeting minutes from its Spring National Meeting, May 14 and June 30 meetings, and minutes of the joint meeting with the Risk-Based Capital (RBC) Model Governance Task Force on June 18
- Working group minutes
The Task Force did not meet at the NAIC Summer National Meeting.
Finance Standards & Regulations (F) Committee – August 12, 2026
The Committee summarized, as much as possible, regulator-to-regulator sessions. The Committee conducted a session discussing state-specific accreditation issues and voted to continue accreditation of the Arkansas, District of Columbia, Indiana, and Michigan insurance departments. The Accreditation Scope and Alignment Working Group held a series of regulator-to-regulator meetings trying to determine if there are any multistate companies/activities not currently covered in the program’s scope. After reporting, the Working Group was then disbanded as it was unable to come to a consensus on any needed actions.
Statutory Accounting Principles Working Group – August 12, 2026
Surprisingly, many of the items that were expected to be adopted during this meeting were re-exposed. Below is a summary of the meeting activity. Complete details of referenced items can be found on SAPWG’s webpage.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-07 | Clarifies reporting of equity subsidiary, controlled, or affiliated (SCA) common stock in the Asset Valuation Reserve (AVR). | Adopted. |
With this adoption, there were no revisions to any Statement of Statutory Accounting Principles (SSAP). NAIC staff will prepare a proposal for the Blanks Working Group to clarify the correct reporting instructions for Life/Fraternal companies. Specifically, the clarification distinguishes between:
- SCA Stocks – Certain Other Subsidiaries; AVR, Line 15
- Investments with the Underlying Characteristics of Common Stock – Affiliated Certain Other; AVR, Line 68
- SCA Stocks – Other; AVR, Line 16
- Investments with the Underlying Characteristics of Common Stock – Affiliated Other – All Other; AVR, Line 69
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-06 | Eliminates the disclosure exclusion for “equity method investments” from the aggregate disclosure under SSAP No. 100 – Fair Value. | Re-exposed through October 2. |
Let’s be clear on what this says. Currently, the disclosure under SSAP No. 100 excludes “investments accounted for under the equity method.” This mirrors the U.S. GAAP treatment. However, regulators have questioned the exclusion because fair values are required for these investments in both Schedule D and Schedule BA. The proposal, if adopted, means these investments would now be included in Notes to Financials #20. It would also mean that the disclosure would be subject to audit for the company’s audited financials, and insurers would have to be able to justify the reported fair values. Since these investments usually fall in level three of the fair value hierarchy, fair values (defined as true exit value) are not readily available. The goal is to have this in place beginning year-end 2026 reporting, which is still doable as the reporting format for Note #20 is a variable line format, not requiring format changes to the statement blanks.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-05 | Revisions to SSAP No. 1, paragraph 23c clarify that security lending restricted asset reporting is to reflect securities lent that are reported on the insurer’s investment schedules, not collateral received. | Adopted effective immediately. |
| 2026-02 | Modifies SSAP No. 61 for the valuation of funds withheld asset liabilities under reinsurance agreements that are recorded for Life and Health entities. | Re-exposed through October 2. |
| 2026-04 | Rejection of Accounting Standards Update 2025-10 and revisions to SSAP No. 24 clarifying government grants are accounted for as an contingency. | Re-exposed through October 2. |
| 2023-14 | SSAP No 7 – AVR and Interest Maintenance Reserve (IMR) revisions and issue paper. | Re-exposed through October 2. |
The IMR Ad Hoc Group has been working on the above for about two years. It is now near completion. There are a lot of accounting revisions that, accordingly, will result in several statement reporting changes. The proposed effective date has now been changed to January 1, 2028. When adopted, the revisions will result in the following (this is not a complete listing):
- A new capital gain/loss exhibit, which will most likely separate reported gains/losses allocated to the IMR and the AVR.
- A revised IMR form.
- Requires re-investing of IMR-qualifying fixed income investment sale proceeds into another qualifying fixed income investment or the insurer cannot amortize any gain/loss through the IMR but must recognize it immediately. This only applies to entities with admitted net negative IMR.
- Proof of reinvestment in statement reporting.
As part of the exposure, revisions to other SSAPs have also been included. Most changes are for reference revisions; however, some are detailed revisions to reflect concept changes in allocating gains/losses to the IMR (for example, SSAP No. 43). Due to the numerous proposed accounting/reporting changes, the proposal should be reviewed carefully. Unlike some exposures, there are a total of six documents that are all part of the proposal.
Note: Since implementation of SSAP No. 7 revisions have been delayed until 2028, INT 23-01 – Net Negative (Disallowed) IMR, which was due to expire on December 31, 2026, has been extended through December 31, 2027. In addition, the actual changes to the statement reporting are not part of the exposure. NAIC staff will work with industry to develop the new reporting formats and instructions.
| Reference # | Subject | Disposition |
|---|---|---|
| 2024-15 | Creates a new SSAP No. 109 – Asset-Liability Management (ALM) Derivatives. | Re-exposed through October 2, 2026. |
An issue paper is also part of this exposure. During the meeting, a new effective date of January 1, 2028 was announced. The re-exposure incorporates several suggestions from industry. The Working Group also sent a referral to the Life Actuarial Task Force requesting a review of the proposed guidance and consideration of a pilot program in early 2027. NAIC staff was instructed to proceed with the development of a statement blanks proposal to incorporate new reporting lines in Schedule DB.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-08 | Asks for input regarding reporting corporate-owned life insurance (COLI/ICOLI). | Exposed through October 2, 2026. |
This is considered a concept exposure. That is, it is asking for feedback prior to presenting specific revisions. The request asks if amounts realizable under insurer company-owned life insurance policies should be captured in Schedule BA to capture investment risk. Currently, ICOLI is reported on the Assets page of the statement as a “write-in for other-than-invested assets.”
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-09 | Reviews and questions accounting/reporting of replication synthetic asset transactions (RSATs). | Exposed through October 2, 2026. |
This is an example of how one project can lead to another and is also considered a concept exposure. During the IMR project (see discussion above), proposed revisions were considered clarifying when realized gains/losses can be allocated to the IMR from the RSAT derivative and the cash component. About the same time, the Securities Valuation Office (SVO) noted an increase in RSAT filings. The proposal presents several different issues and asks for feedback on each.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-10 | Changes to SSAP No. 26 indicating how to classify non-self-liquidating asset-backed securities. | Exposed through October 2, 2026. |
| 2026-11 | Clarifies definition of residential mortgage loans in SSAP No. 37 and as a concept exposure asks if more information should be provided in the reporting. | Exposed through October 2, 2026. |
| 2026-12 | Expose revises SSAP No. 62 to add new guidelines for retroactive reinsurance. | Exposed through October 2, 2026. |
| 2026-13 | Specifies in SSAP Nos. 47 and 54 that Medicaid contract payments classified as capitated payments are reported as insured plans. | Exposed through October 2, 2026. |
| 2026-14 | Nullifies INT 18-03 effective January 1, 2027, and incorporates guidance into SSAP No. 101. | Exposed through October 2, 2026. |
| 2026-15 | Removes Canadian exception for foreign currency translations from SSAP No. 23. | Exposed through October 2, 2026. |
| 2025-22 | Revisions to SSAP No. 61 indicate that net positive IMR increases reinsurer collateral requirements, but net negative IMR does not decrease collateral reinsurer requirements. | Adopted effective immediately. |
With the 2025 implementation of the principles-based bond definition, the Working Group heard a report on errors and non-compliance with the changes. The NAIC has found a significant percentage of errors, which might be expected with the scope of that change. In particular, many of the Schedule BA items (57%) reported as having SVO-assigned designations did not and/or items that were misreported indicated a more favorable designation. Industry was reminded that Schedule BA items are not allowed to report as filing exempt (FE) designation; the designation must be assigned by the SVO.
The group received a referral from the Life RBC Working Group indicating RBC reforms taking place for collateral loans and asking SAPWG to incorporate additional disclosures on the independent verification of collateral fair value, details of the verification, and the range of the valuations. Another referral from the Life Actuarial Task Force was received regarding coordination between the Valuation Manual and the Accounting Practices and Procedures Manual. Updates were received on the SSAP No. 48 project discussions, commitment and contingencies disclosure discussions, and current U.S. GAAP exposures.
The group will next meet on October 7 for further discussion of proposed revised issues related to the IMR.
Credit Rating Provider (CRP) Working Group – August 12, 2026
The entire purpose of this meeting was the discussion of the NAIC CRP Due Diligence Framework – Whitepaper (Framework), which had previously been exposed for comment on May 4. When implemented, the Framework will contain a quantitative and qualitative process assessing ratings from the CRPs. The NAIC will use the Framework to ensure reasonability in the assessment of investment risk by the CRPs.
Those that had submitted comment letters were given time to summarize their comments. In general, the comments were supportive of the NAIC’s intent to create a CRP due diligence framework for regulatory purposes, while also pointing out several areas where additional details should be provided before the white paper is adopted and the framework is applied. No decisions were made at this meeting. Regulators announced they would continue to review the comments and work with NAIC staff and industry to produce a revised version of the Framework.
Accounting Practices & Procedures Task Force – August 13, 2026
No surprises here; it was business as usual. The Task Force adopted its 2027 proposed charges, the minutes from the Statutory Accounting Principles Working Group and the Blanks Working Group, and adjourned.
Investment Designation Analysis Working Group – August 13, 2026
After adopting its 2027 proposed charges, the Working Group took the following actions.
| Subject | Disposition |
|---|---|
| Revisions to the Purposes and Procedure Manual of the NAIC Investment Analysis Office (AP&P manual) to list the new SEC-approved change of the CRP LLC de Mexico, S.A. de C.V. to HR Ratings. | Adopted. |
| AP&P Manual clarification on the assessment of parent-subsidiary situations. | Adopted. |
Currently, in section three, paragraph 38 of the AP&P Manual, specific information is provided for assessing a subsidiary issuer using the audited financials of the parent holding company. Since some entities have interpreted this guidance as the only way for assessment, the amendment emphasizes the SVO can also rely on other information.
| Subject | Disposition |
|---|---|
| Exposure to update the FE treatment of collateralized loan obligations (CLOs). | Exposed for comment through September 14, 2036. |
After adopting the 2024 concept that CLOs would be modeled by the Structured Securities Group (SSG) (with implementation delayed several times), CLOs are now being removed from the SSG modeling process. Actually, the process never really began but now will not be implemented. This is the result of a referral regarding CLOs being sent to the RBC Investment Risk and Evaluation Working Group (RBCIRE) and, in turn, analysis performed by the American Academy of Actuaries (Academy). Accordingly, the Academy recommended the NAIC rely upon CRP ratings instead of SSG modeling and developed appropriate RBC factors. CLOs will be eligible for the NAIC FE policy, with the SSG assigning NAIC designations to CLOs falling outside of the FE policy scope.
| Subject | Disposition |
|---|---|
| Request from Pacific Credit Ratings (PCR) to become an NAIC CRP, making it eligible for the FE process. | Deferred and referred to Credit Rating Provider Working Group. |
The request from PCR was deferred until after the NAIC’s Credit Rating Provider Due Diligence Framework is approved. The Framework will provide for a new process to assess new CRPs; however, it is only in the discussion phase at this point. It might be sometime before the Framework is in place.
After a brief summary of the requirements for an organization to be added to the NAIC’s listing of Nationally Recognized Statistical Rating Organizations (NRSROs) to be used to administer the NAIC’s list of Qualified U.S. Financial Institutions (QUSFI List), it was announced that Morningstar/DBRS had been approved for the list as of June 22, 2026. The QUSFI List appears on the SVO webpage.
Risk-Based Capital Model Governance Task Force – August 13, 2026
After summarizing what has already been accomplished, the chair presented a workplan for the remaining work the Task Force hopes to accomplish by year-end 2026. The document was released for comment through September 12, 2026. It is hoped the workplan will outline completing the Task Force’s existing charges, establishing an orderly transition (for disbanding the group), and avoiding new technical workstreams.
The document emphasizes that technical work should remain with NAIC groups possessing relevant expertise but does recommend the organization of a commissioner-level steering group to coordinate issues crossing multiple disciplines.
The workplan lists four distinct outcomes to be accomplished.
- Provide a means of applying the framework established through the RBC Preamble and the Model Governance Principles after the disbanding of the Task Force.
- Complete and distribute educational and public messaging materials.
- Develop a focused two-year RBC priority agenda consisting of five to seven identified material RBC gaps. This is meant to provide planning but not require completion of every project within a two-year time frame.
- Recommend a commissioner-level solvency-policy steering function. The exposed document contains two options for consideration.
The Task Force heard a presentation from Bridgeway Analytics on the most material RBC gaps for further consideration. The presentation included a listing of gaps to be considered for the future, which was released for a comment period ending September 12, 2026. The Task Force would like to condense that listing to five to seven items by the next NAIC National Meeting in November.
Invested Assets Task Force – August 13, 2026
The Task Force adopted the reports of:
- Investment Designation Analysis Working Group
- Credit Rating Provider Working Group
It then received a report from the Investment Analysis Working Group. As a policy, this Working Group mostly meets in regulator-to-regulator sessions. The report included summaries of two such sessions. During one session, the Working Group received a presentation on mortgage loans, including the increase in the Life industry’s investment in residential mortgage loans. As a result, the Task Force sent referrals to SAPWG and the Life RBC Working Group with recommendations. SAPWG has already begun the process of proposing some of the suggestions into statutory accounting (see the SAPWG summary above).
During the other session, the group heard a presentation from NAIC committee support on investments categorized as level three in the fair value hierarchy. This too resulted in a referral to SAPWG, which has begun addressing some of the noted issues.
During this meeting, members of the NAIC/American Institute of CPAs Working Group provided information concerning the auditing of private credit and fair value estimates for certain investments (specifically, assets with a fair value hierarchy of level three).
Executive Committee – August 13, 2026
The Executive Committee can be thought of as the group that oversees the activities of the NAIC as an organization. The Committee approved a request for model law development to amend the Annuity Disclosure Model Regulation (#245). An update on the NAIC data security incident was provided and the group received a status report on model law development. The National Insurance Producer Registry (NIPR) and the Interstate Insurance Product Regulation Commission (Compact) also provided status reports.
Financial Condition (E) Committee – August 14, 2026
The Committee adopted the meeting minutes from its various task forces and working groups and announced which of its groups met in regular-to-regular sessions.
The Mutual Recognition Jurisdictions Working Group provided an update on its work. The Working Group only meets annually and has not yet met this year. However, it has received applications from three different jurisdictions asking to be evaluated for inclusion on the NAIC listing of jurisdictions that recognize and accept the NAIC’s group capital calculation. A decision will be made later regarding those requests.
Next on the agenda was the adoption of a referral to the Life RBC Working Group regarding reinsurance recapture and counterparty risk. The Committee is concerned about the increasing number of life insurers ceding large portions of their business to non-U.S. jurisdictions. In particular, there is concern that companies ceding to unauthorized reinsurers may have greater capital strain if the ceded business has to be recaptured or if the reinsurer experiences solvency issues. Accordingly, the Committee is directing the Life RBC Working Group to develop a recapture RBC factor to be applied to ceded reserves and modified coinsurance balances for reinsurance located outside of reciprocal jurisdictions (considering any overcollateralization) and to modify the current reinsurance methodology in the life formula for recoverability risk. The Committee wants changes in place by year-end 2027.
A memorandum asking for input for possible revisions to NAIC Model #285 – Disclosure of Material Transactions Act was exposed for a 45-day comment period ending September 28, 2026. At issue here is the fact that unaffiliated reinsurance agreements are not typically subject to regulatory review by the cedent’s domestic regulator (material affiliated reinsurance is already covered).
The National Catastrophe Risk and Resilience Task Force submitted a request to continue its collaboration with the Committee on solvency-related data by incorporating catastrophe reinsurance interrogatories and forward-looking scenarios analysis withing the Property/Casualty RBC Rcat forms. In addition, the Task Force asks that the existing sunset for the scenario analyses in the Rcat be extended through year-end 2030. The requests were exposed for comment for 45 days, ending September 28, 2026.
The RBC Investment Risk and Evaluation Working Group provided an update on its future work plan. The Working Group will be reviewing 2025 annual statement asset-backed securities data to determine which asset class, if any, should be reviewed next. The goal is to use information provided in the statement and not to require information from “company records.” Once that review is completed, a list of possibilities and work priorities will be exposed for comment. In addition, the Working Group has asked the American Academy of Actuaries (Academy) to further review the three sensitivities identified in its previous work on CLOs. As part of that process, the Working Group will release for comment part of a previous Academy presentation identifying and discussing those sensitivities. (This was later released for comment via email on August 21. See summary below.) It was also announced that beginning in 2027, Illinois (Matt Cheung) will become the chair with the District of Columbia (Philip Barlow) staying on as vice chair of the Working Group.
An update from the Invested Assets Task Force included activities of its various working groups (see summaries included above). Emphasis was placed on the CRP Due Diligence Framework’s current status and next steps. Also briefly mentioned was previous work on mortgage loan investments in the life industry and its newer project, the reviewing of reported fair values for assets on level 3 of the fair value hierarchy.
The last update was on the Artificial Intelligence (AI) System Evaluation Pilot. The goal of the evaluation is a tool (the AI Risk Evaluation Supplement) providing a structured way for states to review AI systems in use by insurers. The pilot began in March with 12 states participating. The pilot will continue through September, go through a review and possible revision process, and possibly be adopted for use by the end of 2026.
Joint Meeting of the Executive Committee & Plenary – August 14, 2026
Minutes from the Spring National Meeting were adopted by consent. Reports from the following committees were received. Please note that these are not formal minutes from this National Meeting, but rather summaries of activities. The full meeting minutes will be prepared and presented for adoption at the next NAIC National Meeting.
- Executive Committee
- Life Insurance and Annuities (A) Committee
- Health Insurance and Managed Care (B) Committee
- Property and Casualty Insurance (C) Committee
- Market Regulation and Consumer Affairs (D) Committee
- Financial Condition (E) Committee
- Financial Regulation Standards and Accreditation (F) Committee
- International Insurance Solutions (G) Committee
- Innovation Cybersecurity and Technology (H) Committee
The following items were adopted:
- Amendments to the 2027 Valuation Manual
- Title Insurance Shopping Tool Template
- Pharmacy benefit manager licensure and regulation guidelines for regulators
- Revised RBC Preamble – all RBC formulas
- RBC proposal 2026-12-IRE – factors to be applied to CLOs beginning year-end 2026
- RBC proposal 2025-16-L – updated collateral loan reporting for the Life RBC beginning 2027
A report of the state implementation of NAIC adopted model laws and regulations was received.
The following activities occurred in August, but after the Summer National Meeting.
RBC Investment Risk & Evaluation (IRE) Working Group – Via Email August 21, 2026
This group did not meet during the NAIC Summer National Meeting but did release an item for comment shortly thereafter. Entitled just IRE Exposure, the release was a previous presentation given to the group in December 2025. In that presentation, the Academy suggested the possible addition of sensitivity tests, with emphasis on CLOs. The exposure period was very short, with the deadline set for September 4. The presentation is available on the Working Group’s webpage. (Also see an update provided to the Financial Conditions Committee above.)
Blanks Working Group – August 26, 2026
Usually, the main goal of this meeting is to finalize reporting changes for the next year’s quarterly statement, as well as to begin work on adopting items for the next year’s annual statement. Some items on the agenda could not be previously considered, as final resolution by SAPWG was needed first.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-29 | Adds restricted asset codes to the investment schedules. | Withdrawn. |
| 2026-10 | Clarifies on the Life/Fraternal liability page, lines 24.03 and 24.07 should report book/adjusted carrying value. | Deferred. |
| 2026-13 | Requires an active status code in the Cybersecurity Insurance Coverage Supplement and the Private Flood Insurance Supplement to identify the status in each state. | Adopted beginning annual 2027. |
| 2026-14 | Updates Schedule P instructions in the Property/Casual statement. | Adopted beginning annual 2027. |
| 2026-15 | Renames the CUSIP column to the Security Identifier column, adds a Security ID Type column, clarifies what should be reported in each, and deletes existing columns that would be duplicates. | Adopted beginning first quarter 2027. |
The new Security Identifier column is to include one of the following:
- CUSIP – committee on uniform securities Identification procedures
- CINS – CUSIP international numbering system
- PPN – private placement number
- ISIN – international securities identification number
- LXID – Standard & Poor’s LoanX ID used in syndicated loan and private credit markets
- FIGI – financial instrument global identifier
- ICEID – intercontinental exchange, inc. identifier
The Security ID Code column indicates which of the above have been entered in the Security Identifier column.
- C - CUSIP and CINS (including syndicated loans with a CUSIP)
- P - PPN
- L - LXID
- I - ISIN (including syndicated loans with an ISIN)
- F - FIGI
- E - ICEID
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-16 | Revises Notes to Financial Statements (Note) 20C. | Withdrawn. |
This was one of the items that needed finalizing by SAPWG. However, SAPWG and industry are still working on any revisions to the accompanying accounting. It is expected this will be resubmitted later.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-17 | Rewords General Interrogatories 25.04 and 25.05 changing “amount of collateral” to “assets lent” and Note 5L(1) replacing “collateral held under security lending agreements” to “assets lent under securities lending agreements.” | Adopted beginning first quarter 2027. |
| 2026-18 | Adds identification in the investment characteristics column of investments having a rating from a CRP that is a SVO excluded rating. | Exposed for comment through November 3, 2026. |
| 2026-19 | Expands the definition of qualified health actuary to include meeting the requirements in the Knowledge Statements for Appointed Actuary for Health Blank. | Exposed for comment through November 3, 2026. |
The Health Knowledge Statements were adopted earlier this year by the NAIC and can be found on the Health Actuarial Task Force webpage under the Documents tab.
| Reference # | Subject | Disposition |
|---|---|---|
| 2026-20 | Additional question series 40.1 in General Interrogatory – Part 1 asking if the reporting entity has residuals. A yes response requires answering questions 40.2 and 40.3, as appropriate. | Exposed for comment through November 3, 2026. |
Several editorial changes were adopted, most of which apply beginning with the 2026 annual statements. The discussion then turned to the NAIC’s Financial Data Repository (FDR) Modernization Project. The FDR is where all the annual and quarterly reporting is stored. Some deadlines were provided regarding future meta data freeze periods, with the goal of implementing the new system for use by 2029.
Another meeting has been scheduled for December 3, 2026, which is after the NAIC Fall National Meeting. It is anticipated that SAPWG will present several blanks proposals for 2027 annual reporting.
Life RBC Working Group, August 26, 2026
The Working Group held a brief meeting to discuss a referral from the Financial Conditions Committee directing the group to create a reinsurance recapture charge for reinsurance to entities in non-reciprocal jurisdictions, starting year-end 2027. The concept is to account for additional capital that would be required if a ceding company had to recapture those reserves. The Working Group is to determine the methodology to be used, as well as what types of assets, if any, can be used as collateral to offset the new RBC recapture charge. (See the Financial Conditions Committee meeting summary above for more information.) The referral was exposed for comment through September 23, 2026.
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