The National Association of Insurance Commissioners (NAIC) concluded its 2025 Summer National Meeting in Minneapolis, August 10–14, unveiling sweeping measures across insurer investments, capital standards, reinsurance oversight, technology, and consumer protections. Key actions included adoption of Actuarial Guideline LV (AG 55), requiring asset adequacy testing for asset-intensive life and annuity reinsurance transactions beginning at year-end 2025. The guideline, disclosure-only through 2026, aims to ensure reserve sufficiency under adverse conditions. Regulators also advanced reforms to the risk-based capital (RBC) framework, seeking more precision in investment risk while guarding against weak capitalization, with updated guiding principles expected in the coming weeks. The Capital Adequacy Task Force considered clarifying amendments to the RBC preamble, reinforcing confidentiality and limiting RBC’s use to identifying financially vulnerable insurers.
On investments, the Valuation of Securities Task Force proposed delaying financial modeling of collateralized loan obligations (CLOs) until January 2026 to allow further study by the American Academy of Actuaries, while a reorganization of NAIC’s investment oversight created a new Invested Assets Task Force and specialized working groups. The Financial Condition Committee deferred updates to risk-transfer rules for reinsurance combining coinsurance and yearly renewable term (YRT), leaving open questions about grandfathering older contracts.
Technology and consumer initiatives featured prominently. Regulators debated whether to pursue a model law governing insurers’ use of artificial intelligence, alongside continued development of an AI Systems Evaluation Tool. Work advanced on a new privacy model law expanding consumer rights over personal data, while the Cybersecurity Working Group exposed revisions to its Insurance Data Security Model Law compliance guide, with adoption expected later this year. Parallel discussions continued on oversight of third-party data and predictive models, with regulators stressing the need for greater transparency from outside vendors.
Other developments included approval to revisit the Insurance Holding Company Act to address attorney-in-fact fee conflicts in reciprocal exchanges, initial work on a revamped homeowners insurance data call covering more product lines and claims details, and adoption of Valuation Manual-22 for non-variable annuity reserves, effective 2026. Regulators also released proposed updates to indexed universal life policy illustrations and new annuity suitability safe harbor guidance for public comment.
The event was punctuated by protests during the opening session, as consumer advocates from Public Citizen unfurled banners and called for divestment from fossil fuels, while also pressing regulators on affordability, availability of property insurance, and potential conflicts of interest. Despite the disruption, NAIC leadership emphasized their focus on advancing solvency standards, consumer protections, and modernization of insurance regulation.
