New Handbook Proposal Underscores NAIC’s Private Asset Focus

Developments at the National Association of Insurance Commissioners (the “NAIC”) continue regarding private credit asset managers and insurance company investors seeking to invest in private credit securities. Most recently, on July 30, 2026, the NAIC’s Financial Analysis Solvency Tools (E) Working Group (the “Working Group”) exposed for comment revisions to the NAIC’s Financial Analysis Handbook (the “FAH”) with enhanced guidance for insurance regulators assessing private asset exposures.

     I. Background

The current proposal resulted from a referral to the Working Group from the Financial Analysis (E) Working Group (“FAWG”), which meets in regulator-only sessions to support multistate efforts in addressing solvency problems, including identifying adverse industry trends. FAWG’s referral notes that in reviewing December 31, 2025 insurer financial results, regulators “continued to note an ongoing increase in the amount of private assets held by U.S. domestic insurers,” and highlights that “the potential lack of transparency related to private assets can complicate the assessment of credit quality and reduce the liquidity of the portfolio.” Accordingly, FAWG is recommending “enhancements to NAIC financial analysis tools (e.g., updated metrics, industry benchmarks, peer group averages) and supporting handbook guidance to assist financial regulators in identifying and assessing risks and concentrations in these areas.”

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