NAIC Report: 2025 Summer National Meeting

The 2025 Summer National Meeting (the “Summer National Meeting”) of the National Association of Insurance Commissioners (the “NAIC”) was held in Minneapolis, Minnesota from August 10 to August 13, 2025. In remarks at the meeting’s opening session, NAIC President and North Dakota Insurance Commissioner Jon Godfread highlighted the work of the Risk-Based Capital Model Governance (EX) Task Force (“RBC (EX) Task Force”) as one of the NAIC’s most significant initiatives of the year, and discussed its goal to modernize RBC in light of a growing interest in alternative assets that presents opportunity for insurers but “raises the stakes” for how regulators oversee capital strength.

Commissioner Godfread also discussed Actuarial Guideline LV – Application of the Valuation Manual for Testing the Adequacy of Reserves Related to Certain Life Reinsurance Treaties (“AG 55”), which Executive and Plenary adopted at the Summer National Meeting, as a critical component of the life insurance regulatory framework to address the movement of assets in offshore reinsurance transactions.

Other highlights from the Summer National Meeting include:

• The NAIC is taking steps to implement its Framework for Regulation of Insurer Investments—A Holistic Review (the “Investment Framework”), including by adopting a proposal to rename and restructure the work of the Valuation of Securities (E) Task Force (“VOSTF”) and commencing work on a due diligence framework for the use of credit rating providers (“CRPs”) in evaluating investment risk.
• The Statutory Accounting Principles (E) Working Group (“SAPWG”) extended its interim IMR rule, INT 23-01 Net Negative (Disallowed) Interest Maintenance Reserve, until December 31, 2026.
• The Big Data and Artificial Intelligence (H) Working Group continues to consider the appropriate regulatory framework for governing the use of AI by insurers.
• The Financial Condition (E) Committee (the “(E) Committee”) voted to form a Reciprocal Exchanges (E) Working Group to modify the HCA Models to clarify that fees charged to reciprocals by their attorneys-in-fact are subject to approval under the “fair and reasonable” standard.

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.