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NAIC Launches New Regulatory Wing on Market Conduct Oversight

Members of the National Association of Insurance Commissioners’ Market Regulation and Consumer Affairs (D) Committee appointed the Market Conduct Regulation Modernization (D) Working Group and adopted its charges at the 2026...more

Under the Microscope: A Closer Look at Regulators’ Life and Annuities Priorities

After the Life Insurance and Annuities Illustrations (A) Working Group dissected annuity illustrations, it reported its findings to the A Committee. The working group discovered that the use of high illustrated rates and the...more

NAIC Heads Back to the Lab on Annuity Suitability

After the National Association of Insurance Commissioners’ (NAIC) Annuity Suitability (A) Working Group published its 2025 technical report, aimed at insurers, on “Annuity Best Interest Regulatory Guidance and...more

Next Round of Testing: NAIC Clarifies Third-Party Oversight Plan

Continuing its goal of mapping out the regulatory landscape that would apply to insurers’ use of third-party models and data, the National Association of Insurance Commissioners’ Third-Party Data and Models (H) Working Group...more

NAIC Readies Launch of New Illustration Requirements

On March 31, Ben Slutsker, chair of the National Association of Insurance Commissioners’ Life Insurance and Annuities Illustration Working Group, made clear that “it is a go” to “address annuity illustrations, and...more

Regulators Open the Door to Revising Annuity Illustration Requirements

On February 24, 2026, the National Association of Insurance Commissioners’ Life Insurance and Annuities Illustrations Working Group made its debut appearance. As a prelude, Ben Slutsker, director of life actuarial valuation...more

Expect Focus - Volume I, January 2026

Just before the October federal government shutdown, the SEC staff issued a no-action letter providing some clarity as to when a state-regulated banking or trust institution can serve as a “qualified custodian” under the...more

NAIC’s Third-Party Data and Model Vendors Regulatory Framework Strikes Some Sour Notes

The National Association of Insurance Commissioners’ (NAIC) Third-Party Data and Models (H) Working Group issued a preview of its breakout single: a proposed risk-based regulatory framework for third-party data and model...more

NAIC Fall Meeting Lineup: Key Acts to Watch

At the National Association of Insurance Commissioners (NAIC) Fall National Meeting, new updates and activities from various NAIC groups stepped up to the main stage. Here are the headliners for life insurance and...more

Expect Focus - Volume III, August 2025

At the beginning of July, SEC Chair Paul Atkins painted a picture: tokenization was the “next step” in the evolution of securities. Generally, tokenization entails creating a digital representation of a real-world asset —...more

NAIC Working Group Begins Sculpting a Framework to Assess Third-Party Data and Models

After taking a brief hiatus since the 2024 Fall National Meeting, the National Association of Insurance Commissioners’ Third-Party Data and Models (H) Working Group began shaping its focus. Based on a regulatory survey of...more

NAIC Working Group Paints a Picture of Insurer Oversight Expectations

On August 7, 2025, the National Association of Insurance Commissioners’ Annuity Suitability (A) Working Group released draft safe harbor regulatory guidance that paints a clearer picture of how insurers should oversee third...more

Working in Two Mediums, NAIC Big Data and Artificial Intelligence Working Group Conceptualizes Tools for Regulators and AI Model...

Since the Spring National Meeting, the National Association of Insurance Commissioners’ Big Data and Artificial Intelligence (H) Working Group has been conceptualizing new tools for regulators and exploring whether and to...more

NAIC Annuity Suitability Working Group Issues Guidance on Insurers’ Oversight of Third-Party Supervising Entities

On August 7, 2025, the National Association of Insurance Commissioners’ Annuity Suitability (A) Working Group issued draft safe harbor regulatory guidance with a comment period that ends on September 22, 2025. The draft...more

Expect Focus - Volume II, May 2025

Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more

States Build the Next Mile of Artificial Intelligence Regulation

Since the start of 2025, the following states have added to the roadwork on artificial intelligence regulation in insurance by implementing the NAIC’s model bulletin on the use of AI systems by insurers...more

NAIC Big Data Working Group Continues Building a Regulatory Structure

During the NAIC Spring National Meeting, the Big Data and Artificial Intelligence (H) Working Group reviewed its blueprint to build an overarching regulatory edifice to oversee insurers’ use of artificial intelligence...more

Expect Focus - Volume I, January 2025

The Mysterious Boundary Beyond Which “Personal” Relationships Jeopardize a Director’s Independence - In a recent enforcement action, the SEC concluded that the relationship between James Craigie and an officer of Church &...more

States Decode Their Expectations on Insurers’ Use of AI

States continue to decode their expectations regarding insurers’ use of artificial intelligence (AI) systems. Since our last report, the following states have issued bulletins based on the National Association of Insurance...more

Will Insurers Be Required to Don a Deerstalker? The Case of Third-Party Vendors in Insurance

Regulators are growing concerned about the delegation of various insurance company functions, prompting a closer examination of third-party vendors. Several groups within the National Association of Insurance Commissioners...more

Expect Focus - Volume IlI, September 2024

Gone With the Wind? Closed-End Funds Risk Extinction - Shares of SEC-registered closed-end funds (CEFs) have long held significant potential advantages for some investors. For example, unlike shares of mutual funds...more

NAIC Still Juggling Multiple AI and Machine Learning Initiatives

The many balls that the various National Association of Insurance Commissioners groups currently have in the air focusing on life insurers’ use of artificial intelligence and machine learning were reflected in the reports...more

Illustration Requirements May Be Up in the Air Again

At the National Association of Insurance Commissioners’ Summer 2024 National Meeting, the Life Insurance and Annuities (A) Committee received a report of its Life Actuarial (A) Task Force and a presentation on indexed...more

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