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ARTICLE · 09 APRIL 2026

NAIC Spring 2026 Meeting Update: Life Risk-Based Capital (E) Working Group

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On March 22, 2026, the NAIC Life Risk-Based Capital (E) Working Group met for the Spring 2026 Meeting.

United StatesFinance and Banking
Chad M. Tucker
Chad M. Tucker
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Summary and Takeaways

  • The Life Risk-Based Capital (E) Working Group is considering Proposal 2025-16-L MOD on collateral loans, which would reject look‑through treatment for loans backed by JVs/LPs/LLCs or residual interests, instead calibrating RBC to loan-to-value (with a proposed generic haircut) and continuing existing treatment for mortgage-backed collateral loans under Proposal 2024-15-L, while key AVR items remain set to zero pending actuarial input.
  • Regulators and industry commenters generally support refining collateral loan RBC but differ on timing and calibration: some argue current rules under-recognize risk yet view the proposal’s charges as too punitive or insufficiently tied to structural features; they urge empirically grounded, proportional charges, more reliance on look-through where appropriate, and an implementation date no earlier than year-end 2027.

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