Industry Updates
NALC Comment Letter, Actuarial Guideline for Reinsurance Asset Adequacy Testing 3/23/25
April 25, 2025
Submitted electronically to NAIC Life Actuarial (A) Task Force (LATF) and the Minnesota Department of Commerce
Chair Hemphill and Mr. Andersen:
This letter is submitted on behalf of the National Alliance of Life Companies (NALC). The NALCis a trade association of more than fifty life insurance companies and associates that represents the interests of smaller and mid-sized life insurers, specialty insurers, and their policyholders. Thank you for the opportunity to provide our comments on the most recent exposure draft of ActuarialGuideline for Reinsurance Asset Adequacy Testing (the Guideline).
We appreciate concerns that have been expressed regarding U.S. based life insurers engaging in asset intensive, offshore reinsurance transactions. The NALC supports effective solvency regulation and giving U.S. regulators the tools they need to ensure that reinsurance assets are adequately tested to cover future liabilities.
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