April 2026

US NAIC Spring 2026 National Meeting Highlights: Reinsurance (E) Task Force

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The Reinsurance (E) Task Force (“RTF”) of the US National Association of Insurance Commissioners (“NAIC”) held a virtual meeting on March 2, 2026 in lieu of meeting in person at the NAIC Spring 2026 National Meeting. In addition to routine matters such as adoption of the minutes from the RTF’s December 9, 2025 meeting covered the following matters.

Certified and Reciprocal Jurisdiction Reinsurers

The RTF received and adopted a report from the Reinsurance Financial Analysis (E) Working Group (“ReFAWG”). ReFAWG meets in regulator-to-regulator sessions to assess certified and reciprocal jurisdiction reinsurers for passporting. As of March 2, 2026, ReFAWG has approved 107 reciprocal jurisdiction reinsurers (unchanged since ReFAWG last provided a report to the RTF on December 9, 2025) and 45 certified reinsurers (an increase of three since December 9, 2025) for passporting. ReFAWG reported that 49 states and two territories have already passported at least one reciprocal jurisdiction reinsurer.

“Passporting” is the process under which a reinsurer applies to an initial or “lead” state for recognition as a reciprocal jurisdiction reinsurer or certified reinsurer, following which ReFAWG evaluates and makes its recommendation concerning the status (and any related rating for the reinsurer). Other states can then choose to defer to the lead state’s determination for recognizing a reinsurer as a reciprocal jurisdiction reinsurer or certified reinsurer, which leads to administrative efficiency in obtaining and maintaining that status in multiple states given the reduced level of information that must be submitted to states other than the “lead” state. The list of passported reinsurers can be found on the NAIC’s Certified and Reciprocal Jurisdiction webpage.

Mutual Recognition of Jurisdictions (E) Working Group

The RTF received a status report from the Mutual Recognition of Jurisdictions (E) Working Group (“Mutual Recognition WG”), but did not adopt it, as the Mutual Recognition WG now reports directly to the Financial Condition (E) Committee rather than to the RTF. The Mutual Recognition WG last met on October 21, 2025, when it reapproved Bermuda, France, Germany, Ireland, Japan, Switzerland, and the United Kingdom as qualified jurisdictions, and Bermuda, Japan, and Switzerland as reciprocal jurisdictions. The European Union and the United Kingdom qualify as reciprocal jurisdictions based on the existing respective Covered Agreements. According to the Mutual Recognition WG, Bermuda, Japan, and the United Kingdom are in the process of making changes to their regulatory systems; the NAIC staff are monitoring the implementation of these changes and will report any findings to the Mutual Recognition WG.

Statutory Accounting Principles (E) Working Group Referral

The RTF discussed a referral it received from the Statutory Accounting Principles (E) Working Group (“SAP WG”) on December 18, 2025 informing the RTF of an agenda item exposed by the SAP WG for comment concerning the treatment under SSAP 61 (Life, Deposit-Type and Accident and Health Reinsurance) of derecognized net positive Interest Maintenance Reserves (“IMR”) in relation to reinsurance collateral requirements for unauthorized or certified reinsurers. A copy of the referral was included as Attachment B to the Agenda for this meeting of the RTF. The SAP WG asked in its referral that the RTF consider and share input on whether the treatment of derecognized IMR should be to reduce collateral requirements symmetrically to collateral increases caused by derecognized positive IMR or if the treatment should instead be asymmetrical (i.e., with derecognized net negative IMR not reducing collateral requirements). The SAP WG characterized the exposed agenda item as supporting asymmetrical treatment, and serving to “strengthen the current guidance that all net positive IMR derecognized as a reinsurance transaction shall be a factor in the reinsurance collateral calculation but excludes all derecognized net negative IMR from influencing the collateral requirement.”

The IMR Ad Hoc Group has been considering issues related to IMR, including the deferred recognition of realized gains and losses resulting from changes in interest rates. Existing provisions in SSAP 61 require derecognized positive IMR to be captured as an increase in the reinsurance collateral for qualified or certified reinsurers. However, SSAP 61 does not address whether derecognized net positive IMR should correspondingly decrease applicable collateral requirements. While US-domiciled assuming entities are required to recognize a corresponding amount of IMR for statutory accounting purposes as part of a reinsurance transaction, non-US reinsurers do not recognize IMR. The SAP WG received a presentation on the issue by the IMR Ad Hoc Group and, after no consensus was reached among industry and regulators, made its referral to the RTF of the matter together with its exposure of the agenda item.

The RTF held a regulator-only meeting on February 18, 2026 to discuss the issue and concluded that more information was needed to understand the practical differences between the symmetrical and asymmetrical approaches. At the March 2, 2026 meeting, the RTF invited comments on the issue from interested parties. Notably, a representative of the American Academy of Actuaries (the “Academy”) discussed the Academy’s proposal to follow a symmetrical approach with “guardrails” whereby regulators would (i) allow negative IMR as part of the collateral calculation; (ii) require the ceding company actuary to demonstrate that the level of collateral would be sufficient to mature the reinsurer’s liabilities under moderately adverse scenarios (with the collateral floored at the policy reserves if no testing is performed); and (iii) post collateral less than that developed by the cedent’s actuary result in a reduction in the reserve credit equal to the difference between the test collateral amount and the amount actually held. The Academy emphasized that any revisions to collateral requirements should avoid unintentionally discouraging reinsurers from entering into sound risk-reducing agreements. After no consensus was reached following discussion of the Academy’s proposal and other comments from industry and regulators, the RTF resolved to take more time to consider the referral from the SAP WG, without specifying an exact date by which the RTF would provide a response.

Ongoing NAIC Projects That Affect Reinsurance

The RTF heard a report regarding the following current projects at the NAIC that affect reinsurance:

The RTF received an update from the Life Actuarial (A) Task Force Working Group (“LATF”) on implementation of the new actuarial guideline developed by LATF requiring asset adequacy testing (“AAT”) to be performed using a cash flow-testing methodology for certain life and annuity reinsurance transactions. The Actuarial Guideline LV (“AG 55”) was adopted by LATF in June 2025, by the Life Insurance and Annuities (A) Committee in July 2025 and by the Executive Committee and Plenary on August 13, 2025. The aim of AG 55 is to gain insight into asset adequacy when business is ceded offshore, in order to address the risk that reinsurance transactions may reduce transparency regarding the reserves held for the reinsured business as well as the risks associated with the assets supporting those reserves. Since the NAIC’s adoption of AG 55 on August 13, 2025, LATF has adopted templates permitting regulators to receive, in a digestible manner, key information on: (i) the assuming company; (ii) key risks; (iii) assets supporting the transaction; (iv) assumed net yields on those assets; (v) cash flow testing results; (vi) attribution analysis showing any reasons for reserves going down as a result of the transaction; and (vii) mortality and policyholder behavior assumptions before and after the transaction. The guidelines and the templates are available on the LATF webpage. Regarding implementation, the first reports will be due April 1, 2026. Reports will be provided to the domestic regulator upon request and to the Minnesota Department representing the Valuation Analysis (E) Working Group. Filing instructions for AG 53 and AG 55 were scheduled to be distributed in early February 2026, based on 2024 Schedule S data, and companies should verify their inclusion on the distribution list. The Valuation Analysis Working Group plans to review these filings as soon as they come in, and will begin to report on initial general findings at the Summer 2026 National Meeting.
As previously reported, the RTF is continuing to conduct internal discussions in preparation for a potential proposal to address concerns regarding offshore life reinsurance. In 2025, the NAIC held two regulator-only, informal education sessions on this issue. Although next steps are still being formulated, it has been emphasized that any type of proposal will go through the regular public process, and that there will be sufficient opportunities for public comment.
As previously reported, the Macroprudential (E) Working Group adopted a reinsurance worksheet in June 2023. The worksheet is an optional tool for state insurance regulators to understand reinsurance transactions of the insurance companies that they regulate; however, neither the Financial Analysis Handbook nor the Financial Examiner’s Handbook will require the use of the worksheet, and it will not affect the policies or procedures of the RTF. (The Financial Condition (E) Committee adopted the worksheet at the NAIC Summer 2023 National Meeting.) Further, the information provided to state regulators through the reinsurance worksheet will remain confidential. The RTF asked for feedback from those who had used the worksheet.
The Valuation Analysis (E) Working Group is conducting its third year of reviews of Actuarial Guideline LIII—Application of the Valuation Manual for Testing the Adequacy of Life Insurer Reserves (“AG 53”), which covers AAT for life insurers. The RTF has focused on this process from the perspective of reinsurance issues for the Covered Agreements with the European Union and the United Kingdom. The review is ongoing and being conducted by a wide range of people, including actuaries from the NAIC, regulators, investment experts, financial staff, and other subject matter experts.
Principle-based reserving under VM-22 was adopted by LATF prior to the NAIC Summer 2025 National Meeting. The Longevity Risk (E/A) subgroup convened in July 2025 to request proposals to develop a longevity risk C-2 factor for longevity reinsurance. The subgroup received and discussed four proposals at the NAIC Fall 2025 National Meeting, and LATF exposed them for comment on December 8, 2025. All proposals involved structural changes to the Life Risk-Based Capital blanks. For year-end 2026 reporting, the submission deadline for proposals to the Life Risk-Based Capital Working Group was March 1, 2026.
The Risk-Based Capital Model Governance Task Force (the “RBCMG TF”) was formed in 2025. As previously reported, the RBCMG TF held its inaugural meeting on March 17, 2025, and met again most recently on March 24, 2026. The RBCMG TF’s mission is to develop a set of guiding principles for the Risk-Based Capital framework to ensure a consistent approach to future adjustments. These principles will serve as a strategic foundation to ensure that all revisions to the framework are enhancements that uphold its integrity, adaptability and global competitiveness and further this principle of “equal capital for equal risk.”