Client Alert August 25, 2026
The 2026 Summer National Meeting (the “Summer National Meeting”) of the National Association of Insurance Commissioners (the “NAIC”) was held in Columbus, Ohio, from August 11 to August 14, 2026. Highlights from the Summer National Meeting include:
- Insurance regulators continue to focus on insurer investments, particularly in the area of private credit, with the Investment Analysis (E) Working Group seeking enhanced reporting requirements with respect to the fair value of assets and residential mortgage loan investments.
- The NAIC adopted new C-1 (asset risk) factors for CLO, CBO and CDO investments in the Life RBC formula effective for year-end 2026.
- The Financial Condition (E) Committee has proposed revisions to the Life RBC formula to address reinsurance recapture and counterparty risk and is considering model law reporting changes with respect to unaffiliated reinsurance transactions.
- HCA Model revisions are underway to clarify states’ authority to assess the fairness and reasonableness of attorney-in-fact management fees with respect to reciprocal insurance exchanges.
- Continuing its work related to IMR, the Statutory Accounting Principles (E) Working Group adopted revisions to SSAP No. 61—Life, Deposit-Type and Accident and Health Reinsurance, exposed for public comment revisions to SSAP No. 7—Asset Valuation Reserve and Interest Maintenance Reserve and related materials, and extended the interim guidance INT 23-01: Net Negative (Disallowed) Interest Maintenance Reserve through year-end 2027.
- The Third-Party Data and Models (H) Working Group exposed a proposed regulatory framework for thirdparty data and model vendors used in property and casualty pricing and underwriting.
- The Privacy Protections (H) Working Group exposed for public comment a comprehensive draft of the revised Privacy of Consumer Information Model Act (#672).
The report below summarizes key activities at the Summer National Meeting, and certain interim developments leading up to the Summer 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.