NAIC Spring Meeting Notes: The Regulatory Agenda is Full

Martha Leiper, CFA®, CPA - Head of Insurance Advisory

Highlights from the National Association of Insurance Commissioners (NAIC) Spring Meeting, held in San Diego on March 22-25, 2026.

I got a wealth of information at the NAIC Spring Meeting in San Diego on items that could impact policy, capital and portfolio positing. There is a lot going on in the regulatory arena resulting in a meaty agenda. Many of the topics covered below are in discussion stages or are still out for comment.

I am frequently asked for insight into the NAIC CLO project which is top of mind because of the potential to impact RBC, as well as the potential for scope creep beyond BSLs. This was an item front and center at the meeting.

Other key topics included the framework for future adjustments to RBC, Collateral Loans, Long-term repos, ALM Derivatives, additional disclosures around FABNs, Economic Scenario Generator implementation for RBC C3, IMR and an educational session on RBC ratios and Impairment Risk.

At a glance

• CLO C1 Factor Modeling update presented by the American Academy of Actuaries, with proposed factors for Broadly Syndicated Loan CLOs and exposure open through April 17.
• RBC Model Governance Task Force advances framework for future RBC adjustments, with Bridgewater Analytics conducting a comprehensive gap analysis.
• Collateral loans proposal moves from flat RBC factor to a look-through approach reflecting underlying collateral risk, with target adoption effective 12/31/2027.
• Long-term repurchase agreements over one year adopted as admitted assets under revised statutory guidance.
• Proposed SSAP 109 guidance for ALM derivatives would allow qualifying hedging derivatives to be carried at amortized cost with gains and losses deferred over time.
• Additional disclosures proposed for Funding Agreement Backed Notes and similar funding agreement backed structures.
• Economic Scenario Generator implementation for C3 RBC calculations continues, with interim changes targeting 2027 and NAER discount rate by 2028.
• IMR Reinvestment Template recommended as a required component for admitting negative IMR balances.
• IMR treatment in reinsurance collateral calculations deferred pending feedback from the Reinsurance Task Force.
• American Academy of Actuaries study examines correlation between RBC ratios and insurer impairment, with Phase 2 findings expected by year-end 2026.

Read More from Nuveen

This material is not intended to be a recommendation or investment advice, does not constitute a solicitation to buy, sell or hold a security or investment strategy and is not provided in a fiduciary capacity. The information provided does not take into account the specific objectives or circumstances of any particular investor, or suggest any specific course of action. Investment decisions should be made based on an investor's objectives and circumstances and in consultation with their financial advisors. Financial professionals should independently evaluate the risks associated with products or services and exercise independent judgment with respect to their clients.
 
Nuveen, LLC provides investment solutions through its investment specialists.
 
5140019
5301214