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Insurance: NAIC 2026 Summer meeting

Issues & Trends | September 2026

We report on actions and discussions on conference calls and at the NAIC 2026 Summer meeting.

Applicability

  • All insurance companies

Key impacts

During its Summer meeting and on calls before it, the National Association of Insurance Commissioners (NAIC) adopted the following guidance:

  • SSAP No. 61 to clarify that derecognized net positive interest maintenance reserve (IMR) increases reinsurance collateral requirements but net negative IMR does not decrease reinsurance collateral requirements for unauthorized or certified reinsurers. 
  • Modifications to the risk-based capital (RBC) treatment of collateralized loan obligations.  
  • Revisions to RBC charges for collateral loans reported on Schedule BA based on the type of underlying collateral, previously adopted by the Statutory Accounting Principles Working Group, and align RBC and asset valuation reserve factors with the risk characteristics of those assets.  

The NAIC exposed revisions to the following guidance:

  • SSAP No. 7, and a new issue paper, to include new guidance for IMR and revisions to other impacted SSAPs.
  • SSAP No. 100 to remove the exclusion for investments accounted for under the equity method from the fair value financial of instruments disclosures.
  • A revised proposed SSAP No. 109 and corresponding issue paper for interest rate hedging derivatives that do not qualify as effective hedges under SSAP Nos. 86 or 108 but are used for asset-liability management. 
  • Proposed required documentation for application of VM-22 to inforce policies.   

Report contents

  • Meeting highlights
  • Accounting highlights
  • Actuarial highlights
  • Risk-based capital
  • Invested Assets
  • Other developments

Download the document

Insurance: NAIC 2026 Summer meeting

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Olga Roberts
Managing Director, Dept. of Professional Practice, KPMG US
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Leigh Wilson Gasparovic
Partner, Dept. of Professional Practice, KPMG US

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