NAIC 2025 Fall Meeting: Key Updates Shaping the Insurance Landscape
The NAIC's 2025 Fall National Meeting, held in Hollywood, Florida, from December 7-11, brought pivotal changes to the insurance industry. Key regulatory updates and initiatives emerged, affecting various market sectors. Several working groups and task forces met before and after the meeting to discuss these developments. Here's a concise overview of the primary regulatory and operational updates.
Investment-Related Initiatives
The Valuation of Securities Task Force concluded and will distribute responsibilities to new groups. They approved amendments delaying the classification of collateralized loan obligations as modeled securities until the end of 2026, allowing the American Academy of Actuaries to complete its risk-based capital analysis.
Additionally, the RBC Investment Risk and Evaluation Working Group is adjusting the RBC framework for CLOs. RBC modeling for CLOs is postponed until the end of 2026 for thorough examination. Public input has been solicited on RBC reporting proposals for CLOs.
A new RBC Principles Document has been adopted to guide RBC requirements. This document addresses emerging risks and equitable capital considerations. Meanwhile, the Macroprudential Working Group extended comment periods on funding agreement-backed notes to enhance regulatory compliance proposals.
Innovation and Technology Initiatives
The NAIC is revising its AI Systems Evaluation Tool with industry feedback and plans for a 2026 pilot with several states. Progress continues on a cybersecurity event notification portal aligned with the Insurance Data Security Model Law, enhancing technical security specifications.
Regulatory frameworks for third-party data and model vendors are open for discussion to ensure alignment with regulatory standards. Moreover, updates to the privacy model law focus on evolving data protection needs within consumer financial and health information frameworks.
Life Insurance Developments
Proposals revising risk transfer rules in reinsurance transactions were adopted, addressing reserve credit overestimations. Annuity regulatory guidance on best interest standards clarifies supervisory roles under current suitability models.
Updates to AG 49-A were adopted, impacting the illustration of indexed universal life products for better transparency. The utilization of the Valuation Manual-22 framework for non-variable annuity contracts is under review to streamline integration processes.
Property and Casualty Insurance Updates
Amendments to the Model Holding Company Law are underway to clarify control and affiliation issues. A new data collection framework for homeowners insurance is set to launch, enhancing previous efforts to provide comprehensive market insights.
The Climate and Resiliency Task Force is reorganizing to focus more on natural catastrophe risks, including ongoing flood insurance initiatives. Additionally, the Aggregation Method is undergoing continued analysis for comparability with ICS standards, reinforcing international regulatory alignment.
Finally, proposals on statutory accounting, specifically on interest maintenance reserves, have been made public for feedback, seeking to refine the treatment related to investments. These updates, alongside the election of NAIC's 2026 officers, highlight the ongoing regulatory enhancements shaping the insurance landscape, ensuring robust compliance and improved operational strategies throughout the industry.