NAIC Spring 2026 Meeting Covers CLO RBC, SVO Backlog, Investment Framework

April 22, 2026

Highlights from the NAIC Spring 2026 National Meeting

Dan Brown, John Feeney, Daniel McCarty, Daren Moreira, John Pruitt, Cynthia Shoss Eversheds Sutherland (US) LLP + Follow Contact LinkedIn Facebook X ;) Embed

The National Association of Insurance Commissioners (NAIC) held its 2026 Spring National Meeting from March 22-25 in San Diego, California. As has become the norm, a number of relevant NAIC working groups and task forces met virtually in the weeks prior to (or just after) the National Meeting. Consequently, in this report, we highlight notable developments from the Spring National Meeting and other recent meetings of NAIC working groups and task forces.

I. Investment-Related Initiatives and Developments

a. Invested Assets (E) Task Force and Investment Designation Analysis (E) Working Group Hold their First Public Meetings

The Invested Assets (E) Task Force and the Investment Designation Analysis (E) Working Group met jointly at the Spring National Meeting, marking their first public meetings since assuming responsibilities previously handled by the Valuation of Securities (E) Task Force.

During the meeting, NAIC staff reported a significant increase in Securities Valuation Office (SVO) filings during 2025, particularly with respect to privately rated securities, which has strained existing SVO resources and resulted in a backlog of carryover filings. Regulators emphasized that addressing these operational pressures is a priority under the NAIC’s broader review of the regulatory framework for insurer investments, including efforts to expand SVO staffing and enhance supporting systems. As part of the NAIC’s Holistic Review of the Framework for Regulation of Insurer Investments, the NAIC has committed to increasing SVO staffing and resources.

b. RBC Model Governance Task Force Continues its Review of Potential RBC Framework Adjustments

The Risk-Based Capital Model Governance (EX) Task Force continues its work to develop a process for analyzing both retrospective and future adjustments to the RBC framework, consistent with the Principles of Risk-Based Capital Requirements that the Task Force adopted in December 2025.

During the Spring National Meeting, the Task Force heard a presentation from Bridgeway Analytics on perceived gaps and inconsistencies in the RBC framework (see Attachment Three). A dozen comment letters from interested parties identified areas for improvement with respect to RBC framework governance and related NAIC processes, as well as inconsistencies across life, property/casualty and health RBC formulas, and areas for improvement with respect to investment- and reinsurance-related RBC charges. The Task Force is expected to discuss the identified issues further in future meetings to determine whether they are real, material, and worthy of further work.

The Task Force has requested input on a draft RBC adjustment process flowchart that is intended to ensure that policy questions are clearly addressed before a technical group is asked to begin extensive work on a proposed change to the RBC framework (see Attachment Four). In addition to the steps set out in the flowchart, during the National Meeting, the Task Force discussed the importance of first determining whether a potential RBC issue should be addressed by RBC at all or if it should be addressed in another area of the regulatory toolbox.

c. RBCIRE Working Group Releases Proposed Common Attributes of CLOs for Public Comment

On March 2, 2026, the Risk-Based Capital Investment Risk and Evaluation (E) Working Group (RBCIRE WG) received a long-awaited update from the American Academy of Actuaries (Academy) on whether collateralized loan obligations (CLO) have comparable attributes that can be used as a basis for setting C-1 (asset risk) RBC factors for life insurance companies. The Academy has concluded that CLO debt tranches can be sorted (and resulting C-1 RBC factors could be assigned) based on two attributes: credit rating and tranche thickness (with tranche thickness only relevant for CLO debt tranches rated Baa3 and lower). The Academy also proposed that tranche thickness be treated in a simplified manner, by dividing each rating into just two categories: tranche thickness greater than 4% and tranche thickness less than 4%. Preliminary C-1 RBC factors based on rating alone and a combination of rating and tranche thickness were presented to the Working Group (see slides 12 and 13 of the Academy presentation). The Academy’s presentation was released for a 45-day public comment period that ended on April 16, 2026.

During the RBCIRE WG meeting at the Spring National Meeting, the Academy provided further support for the conclusions in its March 2nd presentation, explaining why 4% was selected as the dividing line for tranche thickness and how reinvestment horizon impacts the RBC factor for A3 rated CLO tranches. Regulators and interested parties discussed the relative merits of the Academy’s conclusions and how they could be implemented for year end 2026 (which is the Working Group’s stated goal). Notably, the RBCIRE WG discussed how the Academy’s work to date has been limited to broadly syndicated loan (BSL) CLOs, and has not considered middle market (MM) CLOs. As a result, there are questions as to whether the CLO attributes the Academy has identified (4% tranche thickness, in particular) should apply to MM CLOs.

The RBCIRE WG also released for public comment Proposal 2025-22-IRE CLO Modified RBC Structure with Tranche Thickness, which would update Life and Fraternal RBC formula blanks and instructions to reflect the Academy’s proposed approach to CLO RBC based on rating and tranche thickness. The proposal makes clear that the proposed RBC factors for CLOs would also apply to collateralized bond obligations (CBO) and collateralized debt obligations (CDO). The public comment period ended on April 17, 2026.

During an April 10, 2026 meeting, the RBCIRE WG received a further update from the Academy focused exclusively on residual tranches of BSL CLOs. The Academy presented the results of its modeling analysis assessing whether there is a sufficient analytical basis to modify the existing RBC treatment for residual CLO investments, which are currently subject to a 45% pre tax C-1 charge. Based on its analysis, the Academy concluded that the modeling results do not support a change to the existing factor, recommending that the current RBC charge applicable to residual CLO tranches be retained. As a result, the Academy’s analysis would allow certain deeply subordinated speculative grade CLO debt tranches to carry higher RBC charges than CLO residual tranches.

Regulators expressed interest in a clearer explanation of the modeling mechanics underpinning the Academy’s conclusion, particularly the comparative treatment of residual versus speculative grade debt tranches. In response, the Academy agreed to incorporate additional illustrative comparison materials into its presentation. Once revised, the updated materials are expected to be exposed for a 60 day public comment period. The Academy also noted that it is evaluating the feasibility of conducting a similar residual tranche analysis for MM CLOs, subject to data availability, and will seek regulatory guidance on potential next steps if that work moves forward.

The RBCIRE WG is next scheduled to meet on May 6th, where the Working Group will consider public feedback on the exposers referenced above and consider the RBC charges that apply to CLOs if the Academy’s recommendation is implemented.

d. Life RBC Working Group Delays Look Through Treatment for Collateral Loan RBC to 2027

The Life Risk-Based Capital (E) Working Group has been considering a proposal to require look through treatment for collateral loans backed by joint venture (JV)/limited partnership (LP)/limited liability company (LLC) interests and residual traches for purposes of calculating collateral loan RBC charges. Several Working Group members have been advocating for a 2026 year-end effective date for the proposal. During the Spring National Meeting, following a split vote, the Working Group agreed to delay implementation of the proposal to year-end 2027.

The Working Group also released for public comment a modification proposed by the American Council of Life Insurers (ACLI) that would reduce the RBC charge for affected JV/LP/LLC- or residual tranche-backed collateral loans from 10%-90% based on the level of loan overcollateralization. Some Working Group members have raised concerns with this proposal based on the lack of publicly available information on collateral levels, and the Working Group has requested input on possible solutions (or edits to the ACLI proposal) to address these concerns. The public comment period ended on April 13, 2026.

e. Financial Stability (E) Task Force Advances Enhanced Transparency Framework for Funding Agreement Backed Notes

The Financial Stability (E) Task Force (FSTF) took additional steps toward implementing enhanced reporting for funding agreement backed notes (FABNs) and similar structures by advancing coordinated referrals to the Statutory Accounting Principles (E) Working Group (SAPWG) and the Blanks (E) Working Group (BWG). The referrals stem from work conducted by the Macroprudential (E) Working Group, which concluded that existing statutory reporting does not adequately distinguish funding agreements that support FABNs or other special purpose vehicle issued liabilities, limiting regulators’ ability to assess potential financial stability transmission channels.

As part of this effort, the Statutory Accounting Principles (E) Working Group (SAPWG) met on March 24, 2026, and voted to expose Ref #2026-01, which proposes targeted revisions to SSAP No. 52 — Deposit Type Contracts. The proposal would require insurers to disclose the total number and aggregate amount of funding agreements supporting FABNs and related structures, including more granular reporting for foreign currency denominated funding agreements, funding agreement backed repurchase agreements (FABRs), and puttable FABNs. In parallel, BWG exposed a companion proposal (Agenda Item # 2026-04BWG) that would add corresponding note disclosures and reporting lines to statutory blanks to align annual statement reporting with the proposed accounting changes. The public comment period for Ref #2026 01 runs through May 1, while comments on the BWG proposal are due by April 28.

II. Innovation and Technology Initiatives and Developments

a. Big Data and Artificial Intelligence (H) Working Group Provides Updates on the AI Systems Evaluation Tool Pilot

The Big Data and Artificial Intelligence (H) Working Group (BDAIWG) provided updates on regulator use of the AI Systems Evaluation Tool, a regulator resource intended to help assess insurers’ governance and oversight practices for artificial intelligence (AI) and machine learning (ML) systems. During the Spring National Meeting, regulators described how participating pilot states are deploying the Tool across a range of supervisory contexts, including market conduct examinations, financial examinations, and financial analysis activities. Pilot participation has focused primarily on life and property and casualty insurers that are domiciled in the reviewing states, with regulators exercising discretion over which components of the Tool to use and generally prioritizing Exhibit A (insurer AI inventory and governance information). BDAIWG Chair Commissioner of Insurance Nathan Houdek (WI) also emphasized that the pilot is being conducted with an express focus on state DOI coordination, including efforts to minimize duplicative information requests where insurers operate across multiple states and to generate meaningful feedback from both regulators and participating companies.

The BDAIWG framed the Tool as complementary to the NAIC’s AI Model Bulletin, which reflects regulators’ expectations regarding insurer governance, risk management, and internal controls for AI systems used in insurance practices. Looking ahead, the BDAIWG indicated that it will continue to gather feedback from pilot use of the Tool and provide additional public updates at upcoming NAIC national meetings and related interim sessions, with updated materials to be posted to the BDAIWG webpage as the Tool continues to be refined.

b. Third Party Data and Models (H) Working Group Discusses Revisions to Draft Third Party Regulatory Framework

The Third Party Data and Models (H) Working Group (TPDMWG) continued its work on a proposed Third Party Regulatory Framework (Framework), which is intended to establish regulatory expectations for insurer reliance on third party data and predictive models. Discussion centered on several key themes emerging from regulator and stakeholder feedback, including:

• The Framework will continue to require a compulsory registration mechanism to facilitate a direct relationship between regulators and vendors serving the insurance industry in their jurisdictions, although several regulators urged consideration of a voluntary approach as a means to move forward quickly and without the need to adopt new legislation.
• The Framework will prioritize reviews of vendor governance as the primary basis of the registration process, as opposed to intensive evaluations of individual models or datasets. State regulators may request more extensive reviews of models or datasets outside the Framework.
• The Framework initially will focus on just models and datasets used in pricing and underwriting, as opposed to the full range of insurance practices. The TPDMWG also acknowledged stakeholder concerns regarding confidentiality, data security, and protection of proprietary and trade secret information that may be submitted as part of any registration or review process. Regulators indicated that these concerns will be considered as the Framework is further refined, including with respect to information sharing protocols and safeguards.

Finally, the TPDMWG reiterated that the exact form of the eventual regulatory deliverable remains under consideration. In particular, regulators left open whether the concepts reflected in the Framework would ultimately be implemented through a model law, model bulletin, or other guidance, and emphasized that additional drafting work and stakeholder engagement are expected before any determination is made regarding implementation.

c. Privacy Protections (H) Working Group (PPWG) Continues Developing Revisions to Model 672

The Privacy Protections (H) Working Group (PPWG) continues its work to revise the Privacy of Consumer Financial and Health Information Model Regulation (Model 672), building on the Chair’s Draft revisions that were previously exposed. As previously reported, the PPWG determined in 2024 to forgo development of a standalone privacy model law in favor of modernizing Model 672 and received an extension of time through the 2026 Fall National Meeting to complete this work.

The PPWG has taken a piecemeal approach, exposing individual articles of the revised model for public comment with the intent of releasing a full revised draft only after all articles have been separately exposed. To date, the PPWG has released revised provisions addressing, among other matters, third party service provider arrangements, consumer notice obligations, opt in and opt out requirements, limits on the disclosure and sale of nonpublic personal information, and the treatment of sensitive personal information. However, several key articles have not yet been exposed for comment, including Article I (Definitions) and Article VIII (Miscellaneous Provisions). The release of proposed definitions as part of Article I is expected to be particularly significant, as a number of key terms included in previously exposed articles are currently undefined and central to evaluating the scope and effect of the revised model. The final two articles are expected to be exposed in the coming months, after which the PPWG intends to release a comprehensive revised draft of Model 672 for public comment.

d. Cybersecurity (H) Working Group Advances Centralized Cybersecurity Event Notification Portal

The Cybersecurity (H) Working Group met to advance its work on a proposed centralized cybersecurity event notification portal intended to facilitate consistent and efficient reporting of cybersecurity events by insurers. The Working Group framed the portal as a tool designed to support state adoption and implementation of the Insurance Data Security Model Law (Model Law 668), particularly the notification requirements applicable to licensed insurers following a cybersecurity event.

As part of its efforts, the Working Group adopted a project proposal request form that would permit the Working Group to begin building a centralized cybersecurity event notification portal. The proposal contemplates a push system under which licensed insurers reporting a cybersecurity event would fill out a standardized notification form (an initial draft of which has been developed) and select which state insurance departments would receive the notification. Use of the portal would be limited to those states that have adopted the notification provisions substantially as provided in Model 668. Interested parties have expressed concern about the security risks that establishing a central repository of sensitive cybersecurity event related information stored by a third party could pose. The proposal is expected to be approved by the Innovation, Cybersecurity and Technology (H) Committee at an upcoming meeting.

III. Life Insurance-Related Initiatives and Developments

a. Life Actuarial (A) Task Force Discusses Retrospective Application of VM-22

The Life Actuarial (A) Task Force (LATF) received an update and discussed public comments on the proposed retrospective application of the Valuation Manual VM 22 (VM-22) framework to in force non variable annuity business. VM 22 establishes a principles based reserving framework for non variable annuities that applies prospectively to new business beginning January 1, 2026, subject to optional implementation timing.

During the Spring National Meeting, the LATF discussed comment letters from the Academy and ACLI. The Academy’s letter outlined considerations associated with each of the proposed retrospective application approaches, identifying potential benefits and challenges from an actuarial and operational perspective and responding to questions posed in the exposure. The ACLI letter expressed support for an optional, company elected approach to retrospective application, emphasizing concerns regarding the maturity of the VM 22 framework, model readiness, and the potential burden associated with mandatory implementation for existing business.

The ACLI letter also presented an enhanced version of Approach E, under which application of VM‑22 to in‑force annuity business would be optional at the insurer’s election, subject to notification to and review by the domestic regulator. Under the ACLI proposal, VM‑22 could be elected at the policy‑form level, supporting analysis could be performed on an aggregate basis where appropriate, and an election to apply VM‑22 would generally be irrevocable once accepted. Following discussion, the LATF expressed general support, in concept, for this enhanced optional election framework, recognizing that it would balance regulatory oversight with operational feasibility, while noting that additional technical questions would need to be resolved before any final recommendation is made.

To that end, the LATF exposed a set of technical questions related to optional election of VM‑22 requirements for a 90‑day public comment period ending June 22. The VM‑22 (A) Subgroup is expected to continue developing the optional election framework, informed by stakeholder input, before returning to the LATF with further recommendations.

b. Life Actuarial (A) Task Force Exposes Proposed Revisions to VM 22 Reinvestment Guardrail for PRT Business

The LATF also exposed proposed revisions to VM-22 relating to the reinvestment guardrail applicable to pension risk transfer (PRT) business. The proposed revisions would permit recognition of an additional illiquidity spread in reinvestment assumptions, subject to conditions intended to promote conservative application and alignment with asset characteristics. The exposure was released together with a supporting principles document prepared by the Academy, which outlines considerations relevant to determining an appropriate illiquidity premium under a PRT reinvestment guardrail, including liability variability, asset liquidity, and stress scenario analysis.

During discussion, regulators noted that the proposal raises several policy questions that remain under consideration, including whether the additional illiquidity spread should be available only where supported by company specific evidence or could be applied more broadly across PRT business. The LATF did not take action on the proposal at the Spring National Meeting. Public comments on the exposure are due by May 7, after which the LATF is expected to evaluate feedback and determine next steps.

c. Life Risk-Based Capital (E) Working Group Exposes Modified GOES Implementation Proposal

The Life Risk Based Capital (E) Working Group discussed comments received on Proposal 2025 14 L (MOD) concerning implementation of revised Generator of Economic Scenarios (GOES) assumptions used to calculate C-3 capital requirements under the Life Risk Based Capital framework. GOES provides the prescribed interest rate and economic scenarios used by life insurers to model interest rate risk and determine required capital for products sensitive to changes in market conditions.

During the Spring National Meeting, the Working Group considered comments submitted by the ACLI addressing the exclusion of the Net Asset Earned Rate (NAER) methodology from the current proposal. As an interim refinement, ACLI recommended replacing the existing discount rate proxy – 105% of the after tax one year US Treasury rate – with a structure based on the ten year US Treasury rate combined with a fixed net spread, which the ACLI asserted would better reflect insurer asset strategies while longer term NAER alignment work proceeds.

Following discussion, the Working Group expressed support for modifying the proposal to reference the ten year Treasury rate in place of the one year Treasury rate, but did not support adoption of a fixed net spread amount as proposed. The Working Group subsequently voted to re expose the revised proposal for a public comment period that ended April 13. The Working Group is scheduled to meet on April 23 to receive and discuss comments on the exposed proposal before considering whether further refinements are warranted.

d. Life Insurance and Annuities (A) Committee Explores Use of Technology to Enhance Annuity Market Regulation

At its March 23, 2026 meeting, the Life Insurance and Annuities (A) Committee discussed the potential role of technology in enhancing regulators’ ability to oversee annuity advertising, marketing, and sales activities and exposed a question for public comment. Specifically, the Committee sought input on whether technological tools could enable regulators to adopt a more proactive (rather than retrospective) approach to market regulation, including tools to compare projected accumulations shown in annuity illustrations at the time of sale with subsequent actual performance, monitor independent marketing organization (IMO) compensation incentives, and evaluate what consumers actually see in sales and marketing materials. The Committee also requested feedback on whether findings could be aggregated to provide earlier feedback to industry and encourage real time course correction, as well as any additional ideas or suggestions stakeholders believe merit consideration. Responses to the exposed prompts are due April 30, 2026.

e. Annuity Suitability (A) Working Group Exposes Draft Resource Document Framework

The Annuity Suitability (A) Working Group met in advance of the Spring National Meeting to discuss its 2026 charges and to expose a draft framework for a Resource Document intended to summarize observed industry practices related to compliance with the annuity suitability and best interest standard under the Suitability in Annuity Transactions Model Regulation (Model #275) The Resource Document is intended to serve as a supervisory reference for regulators and a practical compliance resource for insurers by describing methodologies and practices that insurers have implemented to satisfy their supervisory obligations, while recognizing the principles based nature of Model 275 and the need for flexibility across business models and distribution channels.

The Working Group indicated that the draft framework is designed to solicit input on both effective supervisory practices and areas where insurers have experienced compliance challenges. Public comments on the draft are due May 11, 2026, after which the Working Group expects to prepare a more detailed guidance document or white paper informed by stakeholder feedback and expose a subsequent draft for further consideration.

f. Annuity Buyer’s Guide (A) Working Group Exposes Draft Revised Buyer’s Guide on Deferred Annuities

The Annuity Buyer’s Guide (A) Working Group exposed a draft revised Buyer’s Guide on Deferred Annuities, intended to modernize and enhance consumer-facing disclosures regarding annuity products. The draft Buyer’s Guide includes proposed revisions to clarify key concepts, highlight common consumer decision points, and incorporate examples and supplemental materials drawn from existing state resources. The Working Group indicated that it aims to complete revisions to the Buyer’s Guide later in 2026. The public comment period ended on April 16.

IV. Property & Casualty Insurance-Related Initiatives and Developments

a. NAIC Issues Homeowners Market Data Call

During the Spring National Meeting, the NAIC announced the issuance of a long-awaited nationwide data call to collect granular information on homeowners insurance markets across the United States. The Homeowners Market Data Call Template and Definitions, which were adopted by Executive and Plenary in December, represent a significant expansion of the Property and Casualty Insurance Market Intelligence (PCMI) Data Call first issued in 2024 in collaboration with the Federal Insurance Office. The 2026 Homeowners Data Call covers policy years 2018–2025 and applies to insurers writing at least $50,000 in relevant premium. The data call requests information at a granular level, including policy type (homeowners, renters, condominium, and mobile home), premiums, claims and losses by peril, deductibles, cancellations, non renewals, coverage limits, replacement cost and actual cash value, and mitigation discounts. Covered insurers are required to respond to the data call on or before June 15, 2026. The NAIC anticipates using the data collected to prepare a public report, with an initial version expected to be exposed for public comment in early 2027.

b. Property and Casualty Insurance (C) Committee Receives Update on Affordability and Availability Playbook

The Property and Casualty Insurance (C) Committee met on March 25, 2026, and received an update on the drafting status of the Affordability and Availability of Homeowners Insurance Playbook (A/A Playbook), a multi part resource intended to assist state insurance regulators in responding to growing availability and affordability challenges in homeowners insurance markets. The current working draft is available here.

The A/A Playbook is intended to serve as a practical reference, rather than prescriptive guidance, and is organized into four parts addressing: (1) consumer impacts, macro level trends, and affordability drivers; (2) cross peril and peril specific state actions; (3) emerging and evolving risks (including atmospheric river events); and (4) implementation strategies and practical regulatory considerations. The Committee requested feedback on the working draft by April 10, 2026, after which the drafting group plans to reconvene to evaluate comments and prepare a revised version. A near-final version of the A/A Playbook is expected to be exposed in late June, with comments due in advance of the NAIC Summer National Meeting.

Relatedly, the Casualty Actuarial and Statistical (C) Task Force met on March 23, 2026, and discussed the development of a complementary Homeowners Insurance White Paper focused on rate regulation. NAIC staff noted increasing federal attention to homeowners insurance affordability and academic criticism of state rate regulation processes, and described the White Paper as an effort to position state based insurance regulation as an effective response to systemic market pressures. While the Task Force did not adopt a formal timeline or workplan, regulators characterized the initiative as a priority and indicated that further work is expected in 2026.

c. Cannabis Insurance (C) Working Group Receives Federal Developments Report and Insurer Experience Presentation

The Cannabis Insurance (C) Working Group received updates on recent federal policy developments affecting cannabis and hemp markets, as well as a high level presentation on insurer experience underwriting cannabis-related risks. With respect to federal developments, presenters highlighted recent congressional and executive actions that materially narrow the scope of federally lawful hemp products by replacing the prior delta-9 THC threshold with a “total THC” standard, imposing per product THC caps, and prohibiting certain synthetic and converted cannabinoids. The Working Group also discussed federal efforts to reschedule cannabis from Schedule I to Schedule III under the Controlled Substances Act, and the potential implications of rescheduling for federally compliant cannabis businesses, including reduced tax burdens and increased market stability.

V. Other Notable Initiatives and Developments

a. Executive and Plenary Adopt Restructuring Mechanisms White Paper

During the final day of the Spring National Meeting, the NAIC Executive (EX) Committee and Plenary adopted the Restructuring Mechanisms White Paper. The White Paper updates and consolidates earlier NAIC guidance addressing alternative mechanisms for managing legacy insurance liabilities, including insurance business transfers (IBTs) and corporate divisions (CDs). Among other things, it surveys the evolving state legislative landscape, outlines key solvency, consumer protection, and guaranty association considerations, and describes factors regulators may consider when reviewing restructuring transactions. The White Paper is intended to serve as a reference tool to inform state regulatory analysis and discussion, rather than to prescribe specific outcomes or substitute for state specific legal authority.

b. Aggregation Method (G) Working Group Discusses US Group Solvency Regulation Report for ICS

The Aggregation Method Implementation (G) Working Group met on March 23, where it discussed a timeline for its 2026 deliverables. Those deliverables include continued implementation and monitoring of the Aggregation Method (AM), analysis of life insurer sensitivity to interest rate changes, and review of US group solvency regulation in light of the IAIS comparability assessment. During the meeting, the Working Group discussed a draft Review of US Group Solvency Regulation (US Group Solvency Regulation Report), which is intended to address concerns regarding whether US state insurance regulators’ approach to calculating group capital for internationally active insurance groups (IAIG) produces outcomes that are comparable to the Insurance Capital Standard (ICS) developed by the International Association of Insurance Supervisors (IAIS). A November 2024 IAIS Comparability Assessment concluded that the AM provides comparable outcomes to the ICS, but identified certain areas — including sensitivity to changes in interest rates and triggers for supervisory intervention based on group capital adequacy — where further work may be warranted to promote convergence for US life IAIGs. The Working Group voted to expose the draft US Group Solvency Regulation Report for a public comment period ending May 11.

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