NAIC Advances RBC Alignment, SSAP Revisions, and Cybersecurity Referrals Ahead of 2026

In November, the National Association of Insurance Commissioners (NAIC) experienced an increase in activity leading up to its Fall National Meeting in December. Key discussions centered around proposal 2025-12-IRE, which proposes alignment of three types of Securities Valuation Office (SVO) identified funds concerning Risk-Based Capital (RBC) formulas. While initially developed for the Life/Fraternal RBC, the possibility of a uniform approach across all RBC formulas was considered. However, the decision was postponed due to questions regarding fund handling within sections C-1cs and C-1o. Referral discussions are ongoing with Property/Casualty and Health RBC Working Groups for formula-specific reporting guidance. The Statutory Accounting Principles Working Group (SAPWG) adopted its 2026 working agenda, declined a meeting during the Fall National Meeting, and has a comment period extending to early 2026 for editorial revisions affecting year-end reporting. Proposed revisions to SSAP No. 61 concerning risk transfer analysis of combination reinsurance contracts remain unresolved due to divergent feedback from regulators and industry, with a final decision expected in December. The Life/Fraternal RBC Working Group set a timeline for incorporating collateralized loan obligations into its investment risk framework by mid-2026. Enhancements to cybersecurity considerations related to mergers and acquisitions have been referred to multiple NAIC working groups. A substantive restructuring proposal (2025-15-CA) for the H-2 Underwriting Risk section based on recommendations from the American Academy of Actuaries was released for a 75-day comment period, with further factor changes anticipated. Potential revisions to the Health Annual Statement Exhibit 7 to include a new Part 1B detailing provider transactions were also exposed for comment. The Life/Fraternal RBC covariance calculation saw detailed industry feedback urging a cautious approach, citing interdependent ongoing NAIC activities and the need for company-specific impact analysis. The Task Force on Life and Health Capital Markets Issues adopted updates to catastrophe event listings and discussed conceptual exposure on collateral loans, deciding the proposal is not pertinent to Property/Casualty and Health RBC formulas. Overall, the NAIC continues to progress methodological, structural, and regulatory revisions to RBC frameworks and statutory accounting principles to reflect market complexities and enhance regulatory oversight for the 2026 reporting year and beyond.