Industry Updates

The Annual Meeting of the members of the National Alliance of Life Companies shall be held Friday, April 24, 2026, at 11:30 a.m. at the Grove Park Inn & Spa, Asheville, North Carolina.

The business of the Alliance shall include the election of members to fill vacancies on the Board of Directors.

Scott Harrison
Chief Executive Officer

Submitted electronically to Jason Lapham, Chair, Third Party Data and Models (H) Working Group, National Association of Insurance Commissioners

Chairman Lapham,

This comment letter is submitted on behalf of the National Alliance of Life Companies (NALC).  We welcome the opportunity to comment on the Working Group’s Risk-Based Regulatory Framework for Third-Party Data and Model Vendors exposure draft (the “Exposure Draft”).

The NALC is a national trade association whose members include smaller, mid-sized and specialty life and health insurers.   The NALC was formed in 1992 to address concerns that existing trade associations were not adequately representing the interests of member companies and their policyholders.   Unlike many larger life insurers, NALC members serve regional markets and specific demographics, including working-class families, rural communities, and small business owners.   Our members and their policyholders depend upon regulatory frameworks that are appropriately scaled, do not create artificial barriers, and preserve competitive market dynamics.

We appreciate the work that the Working Group and other NAIC committees are doing to develop regulatory frameworks applicable to insurance carrier use of AI and advanced analytics.  The NALC supports regulators having the tools they need to ensure that insurance companies’ use of AI Systems complies with applicable state insurance laws and regulations.

Read Full Letter

Submitted electronically to Michael T. Caljouw, Commissioner of Insurance, Massachusetts Division of Insurance

Commissioner Calijouw:

I am writing on behalf of the National Alliance of Life Companies (NALC) regarding the Commonwealth’s recently issued RFR for a producer licensing exam provider. As this process moves forward, NALC would urge the Division to ensure that the procurement decision about vendor selection for future examinations does not unintentionally become a policy decision about how high or low the bar will be set to enter the insurance profession in the Commonwealth.

The NALC is a national trade association whose members include smaller, mid-sized and specialty life and health insurers. The NALC was formed in 1992 to address concerns that existing trade associations were not adequately representing the interests of smaller companies and their policyholders. Unlike many larger life insurers, NALC member companies serve regional markets and specific demographics, such as working class families, rural communities, and small business owners. Our members depend on a licensing system that is fair, consistent and grounded in what an entry-level producer must know. Smaller companies feel the impact of issues in licensing more quickly than others because they rely on a steady flow of new agents and consumer-facing staff.

The Commonwealth’s first-time Life exam pass rate is 41 percent. This pass rate has been trending downward for years and is currently one of the lowest in the country. A pass rate this low might be justified if it reflected what is required to protect consumers. Experience in other states does not support a correlation in Massachusetts between lower pass rates and improved consumer protection.

Read Full Letter

Submitted electronically to David Fish, Executive Director, Legal and Regulatory Services, New Jersey Department of Labor and Workforce Development

Mr. Fish:

This letter is submitted on behalf of the National Alliance of Life Companies (NALC), to address the New Jersey Department of Labor and Workforce Development’s proposed new NJAC 12:11 (the “proposed rule”, or “proposal”), which would apply the statutory “ABC test” to the question of independent contractor status in New Jersey. We appreciate the opportunity to provide our comments.

The proposed ABC test offered by the Department is fatally flawed with respect to the life insurance industry. The proposal does not address, distinguish, or incorporate New Jersey‘s long history of statutory and regulatory exemptions for independent insurance agents from the scope of the ABC test. This radical change would, without cause, have a devastating impact on the millions of New Jersey residents who rely upon independent insurance agents for financial protection for themselves and their families. It would also cause significant economic harm and loss of income for the thousands of New Jersey residents who currently work as independent insurance agents.

Read Full Letter

Submitted electronically to NAIC Life Actuarial (A) Task Force (LATF) and the Minnesota Department of Commerce

Submitted electronically to Representative Martin Carbaugh, Indiana House of Representatives and Senator Justin Busch, Indiana State Senate

Submitted electronically to NAIC Life Actuarial (A) Task Force (LATF) and the Minnesota Department of Commerce

To: NALC Members
From: Jim Hodges, Executive Director

I wanted to share a memo on the 2024 elections for the membership, and what it could mean for your personal and business interests moving forward.

Read Full Memo

Attn: Rodney Good & Ralph Villegas, National Association of Insurance Commissioners

Thank you for the opportunity to provide feedback on the Financial Analysis Solvency Tools
Working Group’s (“FASTWG”) proposed revisions to the Financial Analysis Handbook
(“Handbook”) applicable to Form A Procedures.

I serve as Executive Director of the National Alliance of Life Companies (the “NALC”), a trade group of more than fifty (50) life and health insurers and associates. We represent our members on issues of interest to small and mid-sized life and health insurers across the United States.

The NALC fully supports a well-regulated insurance industry. This includes quantifiable and
measurable standards that ensure a level playing field for all insurance companies while adhering to our primary goal of protecting policyholders and insurance consumers. A rigorous solvency framework that is consistently applied across all states and all companies benefits both the regulated industry and its policyholders.

Read Full Letter

Submitted Electronically to the fhfa.gov

Dear Sir or Madam:

This letter is submitted on behalf of the members of the National Alliance of Life Companies (the “NALC”), a trade group of more than fifty (50) life and health insurance companies and associates from across the United States. Our core mission is to protect and promote the interests of small and mid-sized life and health insurance companies and their policyholders.

The NALC appreciates the opporutnity to comment on the REquest for Information (“RFI”) from the Federal Housing Finance Agency (“FHFA”) regarding its current mission and activities statement with respect to the importantn forle of the Federal Home Loan Bank (“FHLB”) system and its eleven (11) regional institutions.

Read Full Letter