Comments on NAIC Insurance Holding Company System Regulatory Act Revisions Due March 11, 2015; ORSA Subgroup Initiatives Absorbed Into Group Solvency Parent

Feb 13, 2015


Proposed amendments to three sections of the National Association of Insurance Commissioners’ (“NAIC’s”) 2015-2016 Financial Analysis Handbook were released for public comment by the Group Solvency Issues Working Group (“Working Group”) after its meeting today, February 13, 2015. 

The sections are:

  • Holding Company Analysis for Use of Group Reporting Template
  • Supervisory College Guidance
  • Supervisory College Best Practices

The proposed changes, which relate to the NAIC’s Insurance Holding Company System Regulatory Act (#440) and  Insurance Holding Company System Model Regulation (#450), are intended to address issues that have arisen subsequent to the models’ adoption in 2010. 

The markup drafts approved for comment are attached for review.  For those who wish to propose changes,  the NAIC requests that the existing revisions within the document be “accepted,” and the proposed modifications added using the Microsoft Word “track changes” function.   

Due by the close of business on March 11, 2015, any comments submitted will be discussed at the Working Group’s meeting during the NAIC Spring 2015 National Meeting.


NAIC’s ORSA Subgroup Activities Absorbed by Group Solvency Issues Working Group

Group Solvency Issues Working Group Chairman and Texas Senior Associate Commissioner Danny Saenz reminded regulators yesterday that the NAIC’s Own Risk and Solvency Assessment (“ORSA”) Subgroup (part of the Financial Condition Committee) has been disbanded, but all of its charges are now incorporated into the Working Group itself.

Accordingly, information from last year’s ORSA Pilot industry feedback was moved to the Working Group’s Web page

To go directly to the ORSA feedback information, click on the hyperlinks below.

Going forward, any work and work product of the ORSASubgroup will now be completed and maintained by the Working Group.

Specifically, the Working Group is now charged with the following projects, both of which are deemed essential:

  • Finalize the ORSA Pilot Project that began in 2014 and complete applicable outputs from it, including a report to Financial Condition Committee
  • Development of an enterprise risk management education program for regulators that is designed to maximize the benefit of such training for the ORSA 2015 effective date

The ORSA Subgroup disbanding and the inclusion of these charges in the Working Group’s initiatives is largely the result of timing, Chairman Saenz explained. 



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