NAIC Letter Details Proactive State Oversight of Evolving Insurance Landscape

WASHINGTON, Sept. 24, 2026 /PRNewswire/ -- In response to a letter from U.S. Senator Elizabeth Warren (D-Mass.), state insurance regulators leading the National Association of Insurance Commissioners (NAIC) today detailed how the state-based regulatory framework is evolving alongside insurers' changing investment strategies, ownership structures, and risk-transfer arrangements.  

"Rather than relying on a static regulatory framework, regulators have regularly updated capital requirements, reporting standards, supervisory tools, and analytical capabilities to address emerging risks while maintaining a consistent focus on insurer solvency and policyholder protection," said NAIC leadership.

Among other actions, this work includes:

• Strengthening asset-adequacy testing through Actuarial Guideline 53 (AG 53) to provide greater consistency in evaluating the risks associated with complex and higher-yielding assets supporting life insurance business.
  
  
• Intensifying oversight of certain life insurance and annuity reinsurance transactions through Actuarial Guideline 55 (AG 55), including setting higher expectations for asset-adequacy analysis and reserve adequacy.
  
  
• Instituting a 45% risk-based capital charge for residual interests in structured securities to ensure that capital requirements appropriately recognize investment risk.
  
  
• Creating a formal process for evaluating whether credit rating providers' methodologies and rating mappings remain appropriate for regulatory purposes.

As NAIC leaders noted, "State insurance regulators continually evaluate whether the solvency framework appropriately captures emerging and changing risks."

This adaptive approach, built on collaboration and coordination, has enabled state-based insurance regulation to lead for more than 150 years and will continue to guide it in an ever-changing insurance landscape.

Resources

Full Letter

NAIC Resource Center: Private Credit and Insurance Regulation

State-Based Regulatory Timeline for NAIC's Solvency Oversight

About the National Association of Insurance Commissioners

As part of our state-based system of insurance regulation in the United States, the National Association of Insurance Commissioners (NAIC) provides expertise, data, and analysis for insurance commissioners to effectively regulate the industry and protect consumers. The U.S. standard-setting organization is governed by the chief insurance regulators from the 50 states, the District of Columbia and five U.S. territories. Through the NAIC, state insurance regulators establish standards and best practices, conduct peer reviews, and coordinate regulatory oversight. NAIC staff supports these efforts and represents the collective views of state regulators domestically and internationally.

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SOURCE NATIONAL ASSOCIATION OF INSURANCE COMMISSIONERS