NAIC Report: 2025 Spring National Meeting

Client Alert

Indianapolis, Indiana hosted the 2025 Spring National Meeting (the “Spring National Meeting”) of the National Association of Insurance Commissioners (the “NAIC”) from March 23 to March 26, 2025.

In the opening session, NAIC President and North Dakota Insurance Commissioner Jon Godfread noted that a central initiative for the NAIC in 2025 will be the work of the new Risk-Based Capital Model Governance (EX) Task Force (“RBC (EX) Task Force”), which will include a comprehensive review of the RBC framework to ensure that regulatory guardrails are clear, consistent and effective, and that the NAIC continues to be a leader in effective capital standards governance.

Other highlights from the Spring National Meeting include:

  • The RBC (EX) Task Force discussed its charges to identify gaps in the current RBC framework and develop guiding principles for future RBC adjustments.
  • The Life Actuarial (A) Task Force (“LATF”) exposed a revised draft of its reinsurance asset adequacy testing guideline for comment until April 24, 2025, targeting adoption of a final draft by the NAIC by summer 2025.
  • The new Aggregation Method Implementation (G) Working Group discussed its charges to review group capital regulation of U.S. groups in order to implement the international Insurance Capital Standard via the U.S. aggregation method.
  • The Statutory Accounting Principles (E) Working Group (“SAPWG”) continued to search for a permanent IMR solution given the impending nullification of its interim IMR rule, INT 23-01 Net Negative (Disallowed) Interest Maintenance Reserve, on January 1, 2026 absent contrary action.
  • The Big Data and Artificial Intelligence (H) Working Group (the “Big Data WG”) provided a “road map” to developing a full regulatory framework governing the use of AI by insurers.

The report below further summarizes key activities at the Spring National Meeting, and certain interim conference calls and other developments leading up to the Spring National Meeting, that may be of interest to our clients in the insurance industry.

To read the full version of this client alert, please click here.