b'INSURANCE REGULATORY|US/NAIC2022, with a proposed effective date of January 1,jurisdiction. In December 2021, the NAIC Executive 2026. Perhaps surprisingly, the GCC accreditation(EX) Committee and Plenary adopted a Process for standard deviates from the GCC-relatedEvaluating Jurisdictions That Recognize and amendments to the NAICs Model InsuranceAccept the Group Capital Calculation document, Holding Company Systems Act and Modelpursuant to which the NAICs Mutual Recognition of Insurance Holding Company Systems ModelJurisdictions (E) Working Group will evaluate Regulation (the Model Holding Companywhether non-US jurisdictions meet this criterion. Amendments) in that it does not require anPursuant to the requirements of the Model Holding insurance group to submit a GCC filing to its leadCompany Amendments, the NAIC will publish a list state regulator at least once before requesting anof non-US jurisdictions that recognize and accept exemption from further GCC filing requirements.the GCC. This list will not be binding on the states, During the meeting of the NAIC Accreditation (F)but a state insurance regulator that makes a Committee in the summer, committee membersdetermination as to a particular jurisdiction that made it clear that states will not be prohibited fromdiffers from the NAIC list is required under the enacting more restrictive requirements than thoseModel Holding Company Amendments to provide included in the accreditation standardi.e., a statethoroughly documented justification to the NAIC that requires insurance groups to submit a GCCand the other states.filing at least once prior to qualifying for an exemption will be in compliance with the proposedUpdate on IAIS Initiativesaccreditation standard.While the NAICs work on developing the GCC Separately from the accreditation requirement, thecontinues, the US insurance industry and state NAIC has urged all states that are group-wideinsurance regulators also remain keenly aware of the supervisors of insurance groups that havework being undertaken by the International operations in the European Union or the UK toAssociation of Insurance Supervisors (IAIS) to adopt the Model Holding Company Amendmentsdetermine whether the aggregation methodology in by not later than November 2022, in order to enablethe GCC will produce comparable (i.e., substantially the US to meet its obligations under the Coveredthe same) outcomes to the IAISs Insurance Capital Agreements it has executed with those jurisdictions. Standard (ICS). The IAIS initially intended to publish its comparability criteria for determining Process for Evaluating Jurisdictionswhether the aggregation methodology in the GCC that Recognize and Accept thewill be comparable to the ICS in the fourth quarter GCC Adopted of 2021, but that timeline has now slipped to the first half of 2022. The IAISs goal is to conduct the The Model Holding Company Act Amendmentscomparability assessment in 2023 and early 2024 provide an exemption from the GCC requirementsand to make a determination as to comparability by for a non-US insurance group whose group-wideyear-end 2024 (which will also mark the end of the supervisor recognizes and accepts the GCC forfive-year monitoring period for the ICS).US insurance groups doing business in its 96|Global Insurance Industry Year in Review 2021'