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ARTICLE · 19 JUNE 2020

NAIC Issues Draft Guidance On Group Capital Calculation

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Controlling persons of insurance companies would be required to file an annual group capital calculation (GCC) with state insurance regulators, and such information would be subject to confidentiality...

United StatesInsurance

Controlling persons of insurance companies would be required to file an annual group capital calculation (GCC) with state insurance regulators, and such information would be subject to confidentiality protections, under new proposed guidance from the National Association of Insurance Commissioners (NAIC).

Insurers should be carefully analyzing whether they would be subject to these requirements and, if so, what the effects of the NAIC's GCC requirements and methodologies will be on them.

On June 16, the NAIC's GCC Working Group exposed for public comment draft amendments to the NAIC's model Insurance Holding Company Systems Regulatory Act (the Holding Company Act), the states' principal tool for regulating controlled insurance companies. The amendments would incorporate the use of a GCC, which has been developed over the past several years as an additional tool that allows regulators to oversee an insurance group's financial health. Comments on the NAIC draft are

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