The Agenda Shifts, Not Shrinks

Martha Leiper - Head of Insurance Advisory

Highlights from the National Association of Insurance Commissioners (NAIC) Summer Meeting, held in Columbus, on August 11-14, 2026.

Due to scheduling conflicts, I attended this year’s NAIC summer meeting virtually.  While I would rather attend in person, the sessions were easy to follow, and it is nice to have the virtual option.

On a more relevant note, there was a noticeable shift in content. After years of discussion, actuarial studies and feedback from the industry, we have accepted our fate on the CLO RBC factors and moved on to other pressing matters. The regulatory agenda remains just as full, with attention now turning to credit ratings, negative IMR, and emerging questions around residential mortgage loans and corporate-owned life insurance.

At a glance

1. Corporate Due Diligence Framework introduces a quantitative and qualitative process to assess NRSRO ratings, with the Working Group reviewing 90 pages of comments before preparing a revised exposure.
2. Negative IMR admittance cap remains in place, with the current interim guidance extended through 2027 and the effective date for revised IMR guidance pushed to 1/1/2028.
3. Residential mortgage loan reporting faces scrutiny, with referrals underway to evaluate classification consistency and potential RBC implications for loans exhibiting commercial mortgage loan characteristics.
4. Corporate-owned life insurance referred to the Capital Adequacy Task Force to assess whether current reporting appropriately reflects underlying investment risk.
    

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