Industry Updates
NALC Comment Letter, Financial Analysis Solvency Tools Working Group (E) – Complex Ownership Structures
August 8, 2024
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.