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NAIC Advances Initiatives on Insurance Company Investments at Spring National

Insurance companies, sponsors and other interested parties should take note of key developments concerning investments by insurers at the National Association of Insurance Commissioners’ (NAIC) Spring National Meeting, held...more

NYDFS Updates Regulated Firms on Upcoming Cyber Requirements

Financial firms doing business in New York should be mindful of a recent e-blast sent by the state’s financial regulator concerning cybersecurity requirements that become effective in less than two months. The New York...more

Corporate Governance: 2024 Year-End Review

As 2025 begins, we cover several significant corporate governance developments that occurred in the second half of 2024 and since our Corporate Governance: 2024 Midyear Review was published in August. We first highlight...more

Parametric Insurance Allowed in New York

Insurers writing catastrophic coverage in New York should take note of legislation signed by Gov. Kathy Hochul in December 2024 and becoming effective on Jan. 12, 2025, that allows the use of parametric insurance in the...more

IAIS Adopts Group Capital Standard

Internationally active insurance groups (IAIGs) should take note of a critical new group capital standard adopted by a global insurance standard-setting body. This could have an effect on capital requirements for these large...more

NY Department of Financial Services Releases AI Cybersecurity Guidance

The New York Department of Financial Services (DFS) issued guidance recently concerning cybersecurity risks associated with artificial intelligence (AI) and measures that covered entities (generally, banks, insurers and other...more

NAIC Committee Adopts New Procedures Allowing Discretion on Rated Securities

Insurers and other capital markets participants, including sponsors of structured assets, should note an important development from the National Association of Insurance Commissioners (NAIC) that could result in regulatory...more

DOL Issues Pension Risk Transfer Guidance, Focuses on PE Ownership of Insurers

Sponsors of defined-benefit pension plans contemplating taking steps to de-risk their plans should consider recent guidance from the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) on pension...more

VOSTF Exposes Revised Draft of Procedures for NAIC Challenge of Ratings

At its June 18 meeting, the Valuation of Securities Task Force (VOSTF) of the National Association of Insurance Commissioners (NAIC) voted to expose a new draft of its controversial proposal, available here, to allow the...more

NAIC Group Issues Guidance on Corporate Restructurings

Insurers with unwanted runoff blocks of business should consider the latest guidance from insurance regulators on potential transactional structures that could mitigate this issue. On May 13, the Restructuring Mechanisms (E)...more

NAIC Body Issues Guidance on Affiliated Investment Management for Insurers

Insurers that outsource investment management to affiliates should consider new guidance from insurance regulators on such arrangements. On March 19, 2024, following its March 16 session at the National Association of...more

Department of Financial Services Issues Guidance on Group Capital Calculation Exemptions

New York-domiciled insurers should consider new guidance from the New York Department of Financial Services (DFS) to determine whether they might be exempt from group capital calculation (GCC) requirements. In its proposed...more

NAIC Adopts ESG Statement

On Feb. 21, 2024, the National Association of Insurance Commissioners (NAIC) announced that it had adopted the NAIC Statement on Environmental, Social, and Governance Policies for the insurance sector. The 50-plus state and...more

NCOIL Advances Public Adjuster Model Law

On Feb. 2, 2024, the Property & Casualty Insurance Committee of the National Council of Insurance Legislators (NCOIL) adopted a new Public Adjuster Professional Standards Reform Model Act (the Act). The Act goes before...more

Fed Issues Final Rule on RBC Requirements for Depository Institution Holding Companies Engaged in Insurance

On Nov. 27, 2023, the Board of Governors of the Federal Reserve System (the Fed) published a final rule, available here, on risk-based capital (RBC) standards for depository institution holding companies that are...more

NY Department of Financial Services Finalizes Significant Amendments to Its Cybersecurity Regulations

The New York State Department of Financial Services (NYDFS) adopted comprehensive amendments to its cybersecurity regulations (known as Part 500) on Nov. 1. The draft amendments were first published in July 2022 and finalized...more

Letters of Credit in Reinsurance — In the Wake of Fraud Allegations, Focusing on the Fundamentals

Widely reported allegations of fraud at an offshore company this past summer have drawn attention to the use of letters of credit (LOCs) to secure reinsurance obligations. The company, now in bankruptcy, specialized in...more

Insurance Regulators’ Working Group Adopts Key Bond Definition, Providing Guidance for Equity-Based ABS

Culminating a four-year-long process, a key working group of insurance regulators has adopted new standards for determining whether an investment held by an insurance company should be characterized as a “bond” evidencing a...more

NY DFS Addresses Discrimination in the Writing of Life and Annuity Products

New guidance from the New York Department of Financial Services (DFS) takes aim at improper discrimination by life and annuity writers in the state. DFS Insurance Circular Letter No. 6, issued on July 17, explains that New...more

IAIS Solicits Feedback on Capital Standard, Relaxes Requirements on Callable Instruments

Large insurers that operate across national borders should consider recent guidance on capital standards from the International Association of Insurance Supervisors (IAIS), in particular on the kinds of instruments that make...more

Senate Committee Questions Insurers on Climate

Property-casualty insurers should take note of letters sent by the U.S. Senate Budget Committee on June 9 to prominent insurers seeking information on climate-related matters. The letters are available here and seek...more

DFS Issues Guidance on Surprise Billing Disputes

Accident and health (A&H) insurers and health maintenance organizations (HMOs) doing business in New York should consider new guidance from the New York Department of Financial Services on the independent dispute resolution...more

SVB Disqualified as a Letter of Credit Provider for Reinsurance Credit

As of March 11, the Securities Valuation Office of the National Association of Insurance Commissioners (NAIC) has removed Silicon Valley Bank (SVB) from the list of approved banks (“qualified U.S. financial institutions,” or...more

IAIS Releases Comparability Criteria between Aggregation Method and Insurance Capital Standard

On March 9, the International Association of Insurance Supervisors (IAIS) announced the criteria, available here, that will be used to assess whether the Aggregation Method, or AM, provides comparable outcomes to the...more

NAIC Announces 2023 Priorities

The National Association of Insurance Commissioners (NAIC) recently announced its regulatory priorities for 2023. Insurers should consider the extent to which these matters impact them and the prospect that insurance...more

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