The Latest in the Evolving Landscape of Insurer Investment Regulation

Over the last five years, insurance regulators have observed shifts in insurance company investment strategies toward “more private assets, more structured assets and more complex assets,” particularly for life insurers, leading the National Association of Insurance Commissioners (the “NAIC”) to review many aspects of the regulatory framework applicable to insurance company investments. In this alert, we summarize the key milestones to date and current activities in insurer investment regulation.

I. Background

The NAIC has consistently observed that the low-interest rate environment following the 2008 financial crisis “created an industry trend to search for yield in investment portfolios and a material shift in the complexity of insurers’ investment strategies, resulting in more market and credit risk than historically normal.” During the same period, “there has been a notable increase in private capital.”

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