The NAIC’s 2026 Spring and Summer National Meetings delivered one of the most consequential slates of statutory accounting and capital reforms in recent memory. The common thread is that an insurer’s investment structure increasingly determines its statutory accounting, risk-based capital (RBC) and reporting outcomes that follow.
Several headline items, including the ALM hedging derivative standard (SSAP No. 109) and the interest maintenance reserve revisions, were re-exposed at the Summer meeting and now point to 2028. But three adopted changes will take effect at year-end and deserve attention today.
1. A New Capital Framework for CLOs
For many insurers, the most significant RBC development is the new treatment of collateralized loan obligations. CLOs are now carved out of the long-term bond category and reported separately, with a parallel new CLO section in the Asset Valuation Reserve and a new Schedule D footnote showing book/adjusted carrying value by NAIC designation.
The Life RBC framework also adopted the American Academy of Actuaries’ recommended CLO factors, including an 11.77% surcharge on broadly syndicated loan CLO tranches rated NAIC 2.C or below with a tranche thickness of 4% or less. Because the surcharge turns on attachment and detachment points, insurers holding thin tranches will need to source that data to report correctly. The changes take effect at year-end 2026.
2. Deeper Private Placement and Debt Security Disclosures
Beginning December 31, 2026, insurers must identify whether private placement securities are SEC-registered, issued under an exemption such as Rule 144A, Regulation D, or Section 4(a)(2), or not subject to SEC registration. Expanded note disclosures will also capture book/adjusted carrying value, fair value with a Level 2/3 split, deferred and PIK interest, and amounts supported by private letter ratings.
A companion package standardizes the location and frequency of debt security disclosures and adds residual-interest reporting. For teams managing sizeable private portfolios, this is fundamentally a data and process challenge, and year-end is closer than it appears.
3. Look-Through Treatment for Residential Mortgage Loans in Statutory Trusts
Revisions to SSAP Nos. 37 and 40 allow residential mortgage loans held in a qualifying statutory trust to be captured within SSAP No. 37 and reported on Schedule B, effective January 1, 2027, with early adoption permitted. The practical effect is treatment as directly-owned mortgage loans for statutory accounting, reporting and RBC purposes, resolving long-standing uncertainty for insurers that originate residential mortgages through trust structures.
The topic remains active, with further accounting clarification and potentially revised capital treatment for certain larger or development-stage exposures still under review.
The Bigger Picture
Taken together, these changes create a compressed implementation timeline, with CLO capital and private placement disclosures taking effect at year-end 2026, and residential mortgage trust treatment following in 2027. They also signal sustained regulatory scrutiny of complex and private-equity-linked investment strategies. Early assessment of elections, systems, and data sourcing will separate the prepared from the scrambling.
Want the full picture? Our executive briefing, NAIC 2026: Key Developments & Recent Guidance, covers these items and more, including collateral loan RBC, the elimination of the investment subsidiary concept, SSAP No. 109 and IMR, and C-3 alignment with the new economic scenario generator. Download the full Brief or contact us at to speak with an expert.
This post is provided for informational purposes only and does not constitute legal, accounting, actuarial, tax, or investment advice. NAIC guidance is evolving; effective dates and eligibility conditions apply. Please confirm current status with your own qualified advisors. ©2026 SS&C Technologies Holdings, Inc.