Washington – September 24, 2026 -- State insurance regulators leading the National Association of Insurance Commissioners (NAIC) responded to a letter from U.S. Senator Elizabeth Warren (D-Mass.) by detailing a series of capital and oversight changes made in recent years to address insurers' shifting investment strategies, ownership structures, and risk-transfer arrangements.
Regulators impose a 45% risk-based capital charge on structured security residuals
NAIC leadership confirmed it instituted a 45% risk-based capital charge specifically for residual interests in structured securities, a move designed to ensure capital requirements reflect the investment risk embedded in these complex holdings.Actuarial Guideline 53 tightens testing standards for higher-yielding assets
The framework strengthens asset-adequacy testing through Actuarial Guideline 53 (AG 53), aiming to create greater consistency in how regulators evaluate risks tied to complex and higher-yielding assets backing life insurance business.Actuarial Guideline 55 raises the bar on reinsurance transaction scrutiny
Regulators are intensifying oversight of certain life insurance and annuity reinsurance transactions under Actuarial Guideline 55 (AG 55), setting higher expectations for both asset-adequacy analysis and reserve adequacy.A new formal review process targets credit rating provider methodologies
The NAIC has created a formal process to evaluate whether credit rating providers' methodologies and rating mappings remain appropriate for regulatory purposes, adding a layer of scrutiny to inputs used in solvency assessments.NAIC leadership stated that 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." The organization framed the response as evidence that the state-based regulatory system, in place for more than 150 years, continues to adapt through collaboration and coordination among the chief insurance regulators of the 50 states, the District of Columbia, and five U.S. territories.