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The insurer’s money, the group’s business

Illustration for the analysis: The insurer’s money, the group’s business

Loans, funds and affiliated investments at Apollo, Brookfield and KKR insurers. An investigation into borrowers, transaction prices and conflicts of interest.

dated revision: October 23, 2026French originalprimary sourcesno tracker

When funds buy insurers · Article 4/8 · Documentary investigation as of 23 October 2026

At Apollo, Brookfield and KKR, insurance provides a durable source of capital that can also finance businesses within the same corporate family. Their accounts reveal several of these connections, provided we distinguish the manager choosing the investments, the vehicle holding them and the company responsible for repayment.

Following the investigations into insurer acquisitions and the Jackson–Athene treaty, this fourth article traces investments between related parties through to the borrower and the transaction price.

On 7 May 2026, a subsidiary of Brookfield Infrastructure Partners refinanced a $450 million loan with subsidiaries of Brookfield Wealth Solutions, the insurance group within the wider Brookfield organisation. The transaction also appears in the accounts of American National Group Inc. and its subsidiaries, which sit within that insurance business. Lender and borrower thus publish two parts of the same story: an insurance group holds a claim on businesses in the Brookfield family, carrying a fixed interest rate of 6.33% and a final maturity in 2036. 9, 10

This is a tangible connection between a promise to a policyholder and the financing of a business. The insurer invests its resources to meet future benefits; a company borrows and agrees to pay interest. Their place within the same wider organisation raises a further question: who protects the insurer’s terms when the financing also serves the interests of its shareholder or business partners?

That connection can take very different forms. An insurer may pay its manager to buy a bond issued by an independent company, invest in a fund organised by that manager, acquire an asset sold by a related company, or lend directly to its parent. The reports examined at Athene, Global Atlantic and Brookfield describe each of these situations. Putting them all behind a single arrow would obscure the essential information: whose ability to pay determines repayment. 1, 13, 9, 12

One label, several destinations

The term “related party” sounds as though it identifies a destination. It actually identifies a relationship, whose nature still needs to be established. US reporting rules distinguish, among other things, control, a connection to the issuer, an affiliated company’s role in arranging an investment and the involvement of a related manager. These disclosures help identify potential conflicts even when the underlying claims are on businesses outside the group. 23, 24, 21

Athene, part of Apollo, provides an especially useful breakdown. At 30 June 2026, it classified $44.025 billion of net invested assets as related party, within a net portfolio of $314.090 billion. The largest category, at $24.778 billion, consists of securitisations of unaffiliated assets managed by Apollo or a related platform. A securitisation pools claims in a vehicle that issues securities for investors to buy; Athene explains that, in this category, the collateral, borrower or other obligor is generally unaffiliated with Athene. 1

The manager therefore sits at the centre of the decisions and fees, while payment comes from the assets being financed. The reader needs to look through the vehicle: which companies pay the interest, which properties generate the rent, which claims supply the repayments? The Apollo connection may matter for asset selection, fees and the choices made along the way; credit quality also depends on those ultimate borrowers.

Athene’s other three categories comprise $8.468 billion invested in Apollo funds, $7.061 billion in platforms that arrange or provide financing, and $3.718 billion in retirement and insurance platforms. Together, they amount to $19.247 billion. A fund interest provides exposure to a portfolio; an equity stake bears the results of a business; a debt security confers a right to payment according to its seniority and security. This classification gives the investigation a starting point for tracing exposures, separating manager relationships from direct loans to Apollo. 1

Athene: related-party assets and reporting scopesAt 30 June 2026 Athene reports $314,090 million of net invested assets, a non-GAAP measure, including $44,025 million classified as related party: $24,778 million in Apollo-managed securitization vehicles, $8,468 million in Apollo funds, $7,061 million in origination platforms and $3,718 million in retirement services platforms. The four categories total $44,025 million; 44,025 / 314,090 rounds to 14.0%. For securitizations the relationship is with the vehicle manager; collateral, borrower or other credit party is generally unaffiliated with Athene. Funds may also finance external borrowers. The $70,616 million GAAP view includes consolidated vehicles and funds-withheld reinsurance receivables: valuation and scope differ. Fund interests, platform bonds and holding-company loans create distinct claims. Bars start at zero on a common scale; values in US$ million.l0g / 0123.10.2026Athene: related-party asset scopes30.06.2026 · US$m · net non-GAAP$314,090m net invested$44,025m related party · 14.0%Apollo-managed securitizations24,778Apollo funds8,468Origination platforms7,061Retirement services platforms3,7180$44,025mGAAP view: $70,616mDifferent scope and valuationSources:S01
Athene: related-party assets and reporting scopesAt 30 June 2026 Athene reports $314,090 million of net invested assets, a non-GAAP measure, including $44,025 million classified as related party: $24,778 million in Apollo-managed securitization vehicles, $8,468 million in Apollo funds, $7,061 million in origination platforms and $3,718 million in retirement services platforms. The four categories total $44,025 million; 44,025 / 314,090 rounds to 14.0%. For securitizations the relationship is with the vehicle manager; collateral, borrower or other credit party is generally unaffiliated with Athene. Funds may also finance external borrowers. The $70,616 million GAAP view includes consolidated vehicles and funds-withheld reinsurance receivables: valuation and scope differ. Fund interests, platform bonds and holding-company loans create distinct claims. Bars start at zero on a common scale; values in US$ million.l0g / 0123.10.2026Athene: related-partyassets and reporting scopes30.06.2026 · US$m · net non-GAAP$314,090m net invested$44,025m related party · 14.0%Apollo-managed vehicles24,778Apollo funds8,468Origination platforms7,061Retirement platforms3,7180$44,025mGAAP view: $70,616mDifferent scope and valuationSources:S01
FIG. 01 Four categories within one net measure[S01]
Method and scope

Athene at 30 June 2026, US$ million: 24,778 + 8,468 + 7,061 + 3,718 = 44,025 of related-party net invested assets, within 314,090 in total. Shares are calculated within this net measure alone; the wider GAAP presentation of 70,616 has a different scope. The underlying assets and obligors in the first category are generally unaffiliated with Athene.

The platform disclosures make the distinction more concrete. At the end of 2025, Athene described its MidCap Financial exposure as including investments through funds and fixed-income securities. MidCap may also originate or source loans to which Athene gains exposure by buying securities issued by MidCap affiliates, retain some of the origination fees paid by borrowers and act as agent for the lenders. A single business relationship can therefore bring together invested equity, credit and paid services. Understanding what the insurer earns requires following each role and each payment to its recipient. 2

The qualification “net invested assets” matters here. Athene also publishes a broader presentation of related-party investments under US generally accepted accounting principles (GAAP) totalling $70.616 billion. For its net measure, the company looks through funds-withheld reinsurance portfolios to the underlying assets, adjusts consolidated vehicles and includes its economic share of ACRA investments while excluding other investors’ share. Valuation bases also differ. The $70.616 billion and $44.025 billion figures therefore answer different questions about the scope of the accounts; the overall investment reconciliation describes these adjustments across the portfolio. Our chart uses the four components of the same net measure, whose sum can be checked. 1

A mandate gives discretion; a purchase transfers rights

An investment mandate gives a manager authority to choose investments. Its size indicates the reach of that service. Brookfield Asset Management, or BAM, reported $150 billion of fee-bearing capital from Brookfield Wealth Solutions at the end of June 2026, divided among liquid credit, non-fund private investment and private funds. This breakdown measures the asset-management business. Identifying the insurers’ borrowers requires tracing the securities held and the assets financed. 11, 12

The legal structure deserves as much attention as the name above the door. In the June 2026 accounts, BAM is the manager and BWS the insurance group. Brookfield Corporation accounts for its BWS investment using the equity method and holds all its Class C shares, which carry the residual economic interest after distributions to Class A and B shareholders. BAM’s management relationship with BWS is therefore distinct from Brookfield Corporation’s economic rights. 8

Buying an interest in a fund creates another relationship. The insurer acquires an economic interest in the vehicle’s investments, while the manager continues to oversee their selection and monitoring. If the interest is purchased from a group company, that company is also the seller; the transfer price then determines how value is divided between two related parties.

Global Atlantic supplies a dated example. In January 2024, it bought minority interests in two funds from its ultimate parent, KKR: $555 million in Diversified Core Infrastructure Fund and $353 million in KKR Property Partners Americas. The published purchase prices therefore total $908 million. The transaction transferred interests already held by KKR; the note reviewed does not specify how the purchase was settled. Describing the price as a management fee, or as a new subscription invested entirely in projects, would change the nature of the transaction. 14

Transfers can also run in a different direction. In the first half of 2026, Global Atlantic received $247 million of capital contributions from its parent in the form of interests in debt securities and funds, recorded at fair value on contribution. These assets entered its accounts through a capital transaction. Their subsequent appearance in a related-party portfolio is therefore insufficient evidence of a cash outflow from the insurer to KKR. 13

Global Atlantic: sale and in-kind contributionIn January 2024 KKR sells Global Atlantic interests in DCIF, the Diversified Core Infrastructure Fund, for $555 million and KPPA, KKR Property Partners Americas Fund, for $353 million, totaling $908 million. Fund interests move from KKR to Global Atlantic; sale consideration moves the other way, with the settlement method not detailed. In the first half of 2026 KKR contributes $247 million of debt securities and fund interests to the capital of the insurance business, measured at fair value. Solid lines show asset transfers; the dashed line shows sale consideration. Transaction flows at two distinct periods; arrows are not scaled by value.l0g / 0223.10.2026Global Atlantic: sale and in-kind contributionDisclosed transactions · US$mJAN 2024 · SALE OF INTERESTSKKRSellerGlobal AtlanticBuyer$908mDCIF 555 + KPPA 353 = $908mConsideration · settlement unspecifiedH1 2026 · IN-KIND CONTRIBUTIONKKRContributorGlobal AtlanticCapital received$247m$247m · debt and fund interests at fair valueSources:S13,S14
Global Atlantic: sale and in-kind contributionIn January 2024 KKR sells Global Atlantic interests in DCIF, the Diversified Core Infrastructure Fund, for $555 million and KPPA, KKR Property Partners Americas Fund, for $353 million, totaling $908 million. Fund interests move from KKR to Global Atlantic; sale consideration moves the other way, with the settlement method not detailed. In the first half of 2026 KKR contributes $247 million of debt securities and fund interests to the capital of the insurance business, measured at fair value. Solid lines show asset transfers; the dashed line shows sale consideration. Transaction flows at two distinct periods; arrows are not scaled by value.l0g / 0223.10.2026Global Atlantic: saleand in-kind contributionDisclosed transactions · US$mJAN 2024 · SALE OF INTERESTSKKRSellerGlobalAtlanticDCIF 555 + KPPA 353 = $908mConsideration · settlement unspecifiedH1 2026 · IN-KIND CONTRIBUTIONKKRContributorGlobalAtlantic$247m · fair valueDebt and fund interests into capitalArrows not scaled by valueSources:S13,S14
FIG. 02 Purchases and capital contributions[S13][S14]
Method and scope

Global Atlantic bought minority interests from KKR in January 2024: DCIF for $555m and KPPA for $353m, totalling $908m. In the first half of 2026, its parent contributed interests in debt securities and funds as capital at a fair value of $247m. These are separate dates and transaction types. Arrows describe the direction of transferred rights, with no monetary scale or assumption of cash settlement.

These two events, more than two years apart, show why a balance-sheet snapshot needs the history of the asset alongside it. A holding may originate in a purchase, a capital contribution or a restructuring. Assessing the 2024 price would require the valuations and terms offered to comparable third parties; assessing the 2026 contribution would require examining the assets received, their valuation and their ability to generate the expected cash flows. The public notes establish the transactions and their accounting treatment, while leaving that economic assessment to further investigation.

A loan traced from both ends

The Brookfield refinancing takes us further in identifying the credit relationship. In its June 2026 accounts, American National Group Inc., or ANGI, reported approximately $3.8 billion of private loans to Brookfield subsidiaries. BWS, which indirectly includes ANGI, reported approximately $4.1 billion. These are overlapping scopes: the second figure covers a larger group containing the first. The $450 million loan cited in both reports is one named example of these relationships. 7, 9

The accounts of Brookfield Infrastructure Partners, or BIP, specify the refinancing terms: fixed interest of 6.33% a year, an anticipated repayment date of 7 May 2031 and a final maturity of 7 May 2036. They state that the loan is non-recourse to the BIP partnership and describe it as having been agreed at arm’s length on market terms. That last assessment is the borrower’s published position; the documents collected contain neither competing offers nor an independent valuation that would allow it to be verified for this transaction. 10

The absence of recourse to BIP marks a useful boundary. The group name may suggest a shared pool of financial strength, but the creditor must exercise the contractual rights it holds against the borrowers and any guarantees or security supporting the loan. Readers cannot assume that the partnership would repay on their behalf. The notes reviewed leave the individual signatory subsidiaries, the debt’s seniority, its security and the precise rights attached to the anticipated 2031 repayment date still to be established. 9, 10

Brookfield: loan principal, recourse and repayment datesOn 7 May 2026 ANGI and subsidiaries, within the BWS insurance scope, refinance a $450 million loan to subsidiaries of Brookfield Infrastructure Partners L.P. The fixed annual interest rate is 6.33%. Anticipated repayment is 7 May 2031 and final maturity is 7 May 2036. The loan is non-recourse to Brookfield Infrastructure Partners L.P.; the borrowing subsidiaries are the debtors. A common timeline runs from 2026 to 2036. At 30 June 2026 BWS private loans to Brookfield subsidiaries total approximately $4.1 billion, including approximately $3.8 billion at ANGI and subsidiaries. These reporting scopes are nested rather than added. Exact signatories and collateral are not detailed in the selected disclosures. Refinancing does not measure new net cash. Frames and arrows are not scaled by value.l0g / 0323.10.2026Brookfield: loan terms and repayment dates7 May 2026 · $450m refinanced6.33% / year · fixed interestANGI + subsidiariesBWS reporting scopeBIP subsidiariesBorrowersInterestNon-recourse to BIP partnership20267 MayRefinanced20317 MayAnticipated20367 MayFinal maturityBWS: ~ $4.1bn private loansBrookfield · 30.06.2026ANGI: ~ $3.8bnSources:S07,S09,S10
Brookfield: loan principal, recourse and repayment datesOn 7 May 2026 ANGI and subsidiaries, within the BWS insurance scope, refinance a $450 million loan to subsidiaries of Brookfield Infrastructure Partners L.P. The fixed annual interest rate is 6.33%. Anticipated repayment is 7 May 2031 and final maturity is 7 May 2036. The loan is non-recourse to Brookfield Infrastructure Partners L.P.; the borrowing subsidiaries are the debtors. A common timeline runs from 2026 to 2036. At 30 June 2026 BWS private loans to Brookfield subsidiaries total approximately $4.1 billion, including approximately $3.8 billion at ANGI and subsidiaries. These reporting scopes are nested rather than added. Exact signatories and collateral are not detailed in the selected disclosures. Refinancing does not measure new net cash. Frames and arrows are not scaled by value.l0g / 0323.10.2026Brookfield: loan termsand repayment dates7 May 2026 · $450m refinanced6.33% / year · fixed interestANGI +subsidiariesBIPsubsidiariesInterestNon-recourse to BIP partnership20267 MayRefinanced20317 MayAnticipated20367 MayFinal maturityBWS: ~ $4.1bn private loansANGI: ~ $3.8bnIncluded balance · 30.06.2026Sources:S07,S09,S10
FIG. 03 One refinancing, its dates and reporting boundaries[S07][S09][S10]
Method and scope

Existing $450m loan refinanced on 7 May 2026, at a fixed 6.33% annual rate, with an anticipated repayment date of 7 May 2031 and final maturity on 7 May 2036, according to BIP. The loan is non-recourse to the BIP partnership. At 30 June 2026, about $3.8bn of private loans reported by ANGI sits within the wider $4.1bn BWS scope; both reports mention the $450m loan. Arrows identify relationships rather than measuring new net cash flows.

The word “refinancing” prevents another misreading. The transaction concerns an existing loan; its $450 million amount does not automatically represent an equivalent additional outflow during the half-year. Measuring the net movement in cash would require reconciling repayment of the old financing, funding of the new loan and any fees. A transaction amount, a closing balance and money collected from policyholders describe three different stages.

Risk analysis then begins with the borrower. If its income can cover debt service over time, the insurer may secure an investment suited to its liabilities. If that income weakens, the loan’s value depends on the assets, its seniority, the security and negotiations with other creditors. A shared corporate affiliation may make information easier to obtain and financing easier to arrange; it may also complicate the defence of the lender’s interests when other companies in the family hold competing positions.

BWS acknowledges this possibility in its annual report. Different Brookfield accounts may occupy different levels of the same company’s capital structure, one as creditor and another as shareholder. The group describes position limits and, in certain circumstances, a passive strategy that leaves tranche decisions to the third-party investors controlling it or an independent agent acting for its investors. Establishing the procedure used for this loan would require the decision specific to the transaction. 6

A claim belongs to a particular company

Athene discloses an even more direct relationship: its holding company, AHL, had a $279 million receivable from Apollo Global Management at 30 June 2026. The loan sits within a $500 million unsecured revolving credit facility. It carries the applicable US federal mid-term rate and matures on 13 December 2028, or earlier if AHL requests repayment. A facility in the opposite direction, allowing Athene to borrow from Apollo, had no outstanding balance at that date. 1

Here, the parent company is the borrower, and the facility’s contractual capacity is distinct from the amount actually lent. The identified creditor is a holding company: the documents do not trace the $279 million back to an individual insurance contract, or establish that it can be added to the $44.025 billion of net related-party investments without a specific reconciliation. It deserves its own line on the map, naming both companies and showing the direction of the debt. 1

At Apollo group level, internal balances and transactions are eliminated on consolidation, as its accounting policy explains. This presentation shows the group as a whole in its dealings with the outside world. It can, however, obscure an individual company’s liquidity needs for a reader moving too quickly through the accounts: in that company’s own accounts, a claim on its parent remains a right to payment dependent on a borrower. Consolidation does not replace the contract governing that payment. 3

Athene and Apollo: the holding-company loanAt 30 June 2026 AHL, Athene Holding Ltd., has lent $279 million to AGM, Apollo Global Management, Inc., under a $500 million facility, leaving $221 million undrawn. The reverse AGM-to-AHL facility has $500 million capacity and zero outstanding. The loan is unsecured, bears interest at the US mid-term applicable federal rate, and matures on 13 December 2028, or earlier at AHL’s request. AHL records a receivable as an asset and AGM a payable as a liability. Apollo consolidated accounts eliminate the intercompany receivable and payable; the AHL–AGM contract remains in place. Bars use the $500 million contractual capacity. The holding-company loan is presented separately from $44,025 million of related-party investments.l0g / 0423.10.2026Athene and Apollo: the holding-company loan30.06.2026 · US$mAHLLenderAGMBorrower$279m279 drawn221 undrawn0Capacity: $500mAGM → AHL: $0m of $500mAHL → AGM: unsecuredUS mid-term applicable federal rate13.12.2028 or earlier at AHL requestAHLAsset: receivable$279mAGMLiability: payable$279mConsolidatedInternal balanceseliminatedSources:S01,S03
Athene and Apollo: the holding-company loanAt 30 June 2026 AHL, Athene Holding Ltd., has lent $279 million to AGM, Apollo Global Management, Inc., under a $500 million facility, leaving $221 million undrawn. The reverse AGM-to-AHL facility has $500 million capacity and zero outstanding. The loan is unsecured, bears interest at the US mid-term applicable federal rate, and matures on 13 December 2028, or earlier at AHL’s request. AHL records a receivable as an asset and AGM a payable as a liability. Apollo consolidated accounts eliminate the intercompany receivable and payable; the AHL–AGM contract remains in place. Bars use the $500 million contractual capacity. The holding-company loan is presented separately from $44,025 million of related-party investments.l0g / 0423.10.2026Athene and Apollo:the holding-company loan30.06.2026 · US$mAHLLenderAGMBorrower279 drawn221 undrawn0Capacity: $500mAGM → AHL: $0m of $500mAHL → AGM: unsecuredUS mid-term applicable federal rate13.12.2028 or earlier at AHL requestAHL$279m receivableAGM$279m payableConsolidatedInternal balances eliminatedSources:S01,S03
FIG. 04 A holding-company claim on its parent[S01][S03]
Method and scope

Athene Holding Ltd. at 30 June 2026: $279m receivable from Apollo Global Management under a $500m unsecured revolving facility. Maturity is 13 December 2028, or earlier at AHL’s request, at the applicable US federal mid-term rate. The reverse facility had no amount outstanding. The receivable belongs to the holding-company scope, and intragroup balances are eliminated in Apollo’s consolidated accounts; the detailed origin of the funds remains to be established.

The same change of scope matters for revenue. A fee charged by the manager to the insurance business is income for one and an expense for the other; simply adding their separate accounts does not measure group profit. Within a fund, further charges may affect the return reaching the insurer. A revenue map therefore needs to identify the payer, recipient, vehicle and accounting eliminations. It lays the groundwork for investigating how returns are shared, without inferring that division from assets under management alone. 3, 11

The US affiliated-investment universe: $321 billion

A publication from the NAIC, the association of US state insurance regulators, places these cases in a wider context. Published in September 2026, it identifies approximately $321 billion of affiliated investments held by US life insurers at the end of 2025, or roughly 5% of their cash and invested assets. The data cover four reporting schedules and encompass several types of securities and ownership interests. 22

Within that same scope, approximately 28% is reported as credit exposure to an affiliate. The difference between this figure and the total demonstrates the value of the distinction followed throughout this article. The relationship criteria used to monitor a portfolio extend beyond debt owed by a related company. The remaining 72% may still carry economic, governance or management dependencies that this statistic does not quantify; presenting it as free of all group-related risk would be equally misleading. 22

NAIC: the affiliated investment reporting scopeUS life insurers, year-end 2025 balances at book or adjusted carrying value. The NAIC study published in September 2026 reports $321 billion of affiliated investments, about 5% of all US life insurers’ total cash and invested assets. The rounded table shows $322 billion while the text gives $321 billion. Four schedules define the scope: D part 1 section 1, issuer credit obligations; D part 1 section 2, asset-backed securities; BA, other long-term investments; DA, short-term investments. About 28% represents credit exposure to an affiliate; the calculated 72% complement covers other affiliation relationships, including a securitization manager, a fund or another investment structure. Shares are rounded; no precise credit amount is inferred. Classification identifies the relationship to examine; risk depends on the borrower, underlying assets, instrument seniority and contractual terms.l0g / 0523.10.2026NAIC: affiliated investment scopeUS life insurers · year-end 2025 · book or adjusted carrying value$321bn affiliated · about 5%D · 1 · 1Issuer creditobligationsD · 1 · 2Asset-backedsecuritiesBAOther long-terminvestmentsDAShort-terminvestments~ 28% credit to an affiliate~ 72% other affiliationsText: $321bn · rounded table: $322bnSources:S22
NAIC: the affiliated investment reporting scopeUS life insurers, year-end 2025 balances at book or adjusted carrying value. The NAIC study published in September 2026 reports $321 billion of affiliated investments, about 5% of all US life insurers’ total cash and invested assets. The rounded table shows $322 billion while the text gives $321 billion. Four schedules define the scope: D part 1 section 1, issuer credit obligations; D part 1 section 2, asset-backed securities; BA, other long-term investments; DA, short-term investments. About 28% represents credit exposure to an affiliate; the calculated 72% complement covers other affiliation relationships, including a securitization manager, a fund or another investment structure. Shares are rounded; no precise credit amount is inferred. Classification identifies the relationship to examine; risk depends on the borrower, underlying assets, instrument seniority and contractual terms.l0g / 0523.10.2026NAIC: the affiliatedinvestment reporting scopeUS life insurers · year-end 2025Book or adjusted carrying value$321bn affiliated · about 5%D · 1 · 1Issuer creditobligationsD · 1 · 2Asset-backedsecuritiesBAOther long-terminvestmentsDAShort-terminvestments~ 28% credit to an affiliate~ 72% other affiliationsManager, fund or structure:contract terms define the risk.Text: $321bn · table: $322bnSources:S22
FIG. 05 The affiliated universe extends beyond intragroup credit[S22]
Method and scope

NAIC, US life insurers, year-end 2025, book or adjusted carrying value: about $321bn across four reporting schedules in the text, versus $322bn in the published table. About 28% of the affiliated universe is reported as affiliate credit exposure. The arithmetic remainder of 72% retains other potential relationships and measures a separate reporting category. Global group aggregates use different boundaries.

Concentration also deserves attention. According to the NAIC, ten insurers with a “PE relationship” account for almost half of total affiliated investments. The report does not name those ten companies or provide a complete operational definition of that category. It therefore provides no basis for attributing the total to Apollo, Brookfield and KKR, or for directly comparing its $321 billion with the three groups’ global consolidated figures. The figures retain the difference between the text’s $321 billion and the table’s $322 billion, for which the publication supplies no reconciliation. 22

In its letter of 24 September 2026 to Senator Elizabeth Warren, the NAIC sets out the states’ supervisory tools: detailed reporting, group supervision and prior review of certain material transactions between affiliates. It also notes the potential benefits of less liquid investments for insurers able to hold them. This framework explains how an affiliated relationship can be permitted while remaining subject to supervision; it provides no individual endorsement of the price or risk of every asset. 15

Price is the decisive test

The strongest economic argument for these structures lies in bringing the businesses together. A team that sources borrowers, structures financing and understands insurance liabilities may be able to construct investments that are difficult to obtain in the conventional bond market. Maturities and cash flows may align more closely, while reduced liquidity may command additional compensation.

A working paper published by the Federal Reserve Bank of Chicago and revised on 27 April 2026 offers empirical support for part of that argument. Looking in particular at indexed annuities, it finds that major issuers use private and floating-rate investments whose shorter maturities can better match those of the products they sell. The authors also interpret their findings as evidence of better cash-flow matching. The results concern defined categories of products and portfolios; they do not certify every private loan or related-party transaction. 16

A working paper entitled Buying from the Family, in its September 2026 version, approaches the issue from the purchase price, comparing transactions in the same securities on the same dates. Among privately placed structured securities classified as primary-market purchases, the authors estimate an additional price premium of approximately 47 cents per $100 of face value for the combination of an insurer directly majority-owned by a private equity firm and a purchase of a security issued by an affiliate. Their ownership category distinguishes direct ownership by the private equity firm from ownership through one of its buyout funds. This is a purchase-price difference estimated by regression. Its interpretation depends on the sample and the classification of primary-market transactions, inferred using an algorithm. The coefficient describes the interaction between affiliation and direct ownership, measured per $100 of face value at purchase. 17

The two studies bring different evidence to the same question. One examines how a portfolio fits its liabilities; the other looks for a possible transfer of value when an asset is bought. Financing may have an appropriate maturity and still be overpriced. A related manager may also supply a good asset on competitive terms. Ownership links identify where to scrutinise the choices being made, while prices, contract terms and performance help establish their consequences.

Governance procedures therefore matter. At Athene, the functions of the former conflicts committee were transferred to the audit committee on 5 August 2025. Its policy reserves certain decisions for disinterested directors, while providing for pre-approvals and exemptions. The report also acknowledges that the committee may rely on information supplied by Apollo without independent verification. The investigation needs the decision that applied to a particular transaction, the comparables used and the insurer’s effective ability to choose another investment. 2

The contracts still missing from the map

The public record establishes a specific finding: some of the resources invested within these groups finance related companies, some pass through vehicles managed within the same corporate family, and securities also move through sales and capital contributions. For each route, a different document reveals the economic responsibilities: an investment mandate, a security, a loan agreement, the vehicle’s accounts or a conflicts policy. 1, 13, 14, 9, 10

The investigation identifies several of these connections and measures some of the balances. Detailed terms remain open for many financings: the full security package, the division of fees, contemporaneous valuations and the identity of every company holding the assets. This investigation relies on the cited publications. The groups’ positions are attributed to their authors; detailed contractual terms and independent price comparisons still to be obtained are identified in the text.

For a policyholder expecting payment in twenty years, the question becomes more concrete. Which income will support the company responsible for paying, what rights will it hold if a borrower runs into difficulty, and who will be able to decide on a restructuring? A useful map connects corporate relationships with obligations to pay, showing where interests meet and where they may diverge.

Further reading: the first investigation into AT&T pensions, the accounting boundary around Athora, and the guide to reading a life insurer’s financial strength.

Sources

The notes give each document’s date, scope and limitations. Company and regulatory communications are attributed to their authors.

  1. S01 · Athene Holding Ltd. / SEC EDGAR · 2026-08-10 · Accessed: 2026-10-23Athene Holding Ltd. : Form 10-Q, quarter ended June 30, 2026
    Passages and scope

    Balance sheet at 30 June 2026; first half of 2026; comparison at 31 December 2025.

    Printed pages 8 (balance sheet), 58–61 (Note 11; AHL receivable from AGM p.60 and reverse facility p.61), 70–71 (net-measure definition), 80–82 (three scopes and related-party categories), 95 (net portfolio) and 100 (overall investment reconciliation).

    Breaks $44,025m of related-party net invested assets into $24,778m, $8,468m, $7,061m and $3,718m. Distinguishes the $43,527m balance-sheet subtotal and $70,616m wider presentation. Identifies AHL’s unsecured $279m receivable from AGM, $500m capacity, rate, maturity and early-repayment right, as well as recognized management fees.

    Unaudited interim accounts at 30 June 2026. The non-GAAP net measure adjusts valuations, reinsurance, consolidated vehicles and third-party interests. The p100 overall bridge is not a detailed reconciliation from $70,616m to $44,025m. Generally unaffiliated borrowers are described relative to Athene. These notes do not trace the holding loan’s funding or provide individual transaction decisions. Q3 alternative-investment estimates issued on 5 October do not replace these accounts; Apollo Q3 results are scheduled for 3 November.

    Official copy consulted for this review

  2. S02 · Athene Holding Ltd. / SEC EDGAR · 2026-02-25 · Accessed: 2026-10-23Athene Holding Ltd. : Form 10-K, year ended December 31, 2025
    Passages and scope

    Year ended 31 December 2025; governance as described in the filing of 25 February 2026.

    Printed pages 45 (conflict risks), 179–182 (Note 15, related parties), 194 (transfer to the audit committee), 210–215 (fees, AAA and platforms; Atlas p.213, MidCap p.214, Wheels p.215), 218–220 (policy and exemptions).

    Confirms year-end 2025 MidCap positions, ABS/CLO exposure and potential origination fees. Dates the transfer of conflicts-committee responsibilities to the audit committee to 5 August 2025. Describes disinterested directors, pre-approvals and exemptions, and the risk of relying solely on Apollo information without independent verification.

    Year-end 2025 snapshot, which must not be mixed with June 2026 GAAP amounts. Year-end 2025 Athora ownership percentages predate its 2026 financing. A published governance rule does not prove its application to every transaction or the fairness of an individual price.

  3. S03 · Apollo Global Management, Inc. / SEC EDGAR · 2026-08-10 · Accessed: 2026-10-23Apollo Global Management, Inc. : Form 10-Q, quarter ended June 30, 2026
    Passages and scope

    First half of 2026 and balance sheet at 30 June 2026.

    Printed pages 20 (Note 2, consolidation), 96–100 (Note 18, segments; intersegment fees p.98 and revenue reconciliation p.100).

    Cross-checks $785m of intersegment management fees recognized in the first half of 2026 and establishes elimination of intercompany accounts and transactions on consolidation. These disclosures distinguish segment revenue from consolidated revenue.

    Unaudited interim statements. Segment data, assets under management and Athene net invested assets have different scopes. Fee revenue is not the net profit earned from that service. Recognized fees do not establish identical cash settlements during the period.

    Official copy consulted for this review

  4. S04 · Apollo Global Management, Inc. / SEC EDGAR · 2026-02-25 · Accessed: 2026-10-23Apollo Global Management, Inc. : Form 10-K, year ended December 31, 2025
    Passages and scope

    Year ended 31 December 2025.

    Printed pages 15 (Athene AUM), 108–109 (net invested assets), 154 (consolidation policies), 257–261 (segments).

    Scope cross-check for Apollo consolidation and the distinction between managed assets, balance-sheet assets and net invested assets. The article’s core numerical evidence relies on S01–S03.

    Context and verification document; managed assets must not be treated as assets owned by Apollo, nor intersegment fees added without elimination.

  5. S05 · Athora Holding Ltd. · 2026-03-27 · Accessed: 2026-10-23Athora Group completes acquisition of Pension Insurance Corporation Group and announces plans to relocate headquarters to the UK
    Passages and scope

    Acquisition closed on 27 March 2026; cited financial metrics at 31 December 2025.

    Opening announcement; paragraphs retaining PIC as the UK business; footnote 1 for the date of financial metrics.

    Identifies PICG/PIC as the UK acquisition that Athene’s accounts say it helped finance in the first quarter of 2026.

    Buyer’s announcement; expected benefits and planned headquarters relocation remain company statements. This release does not establish the amount of any Athene payment.

  6. S06 · Brookfield Wealth Solutions / SEC · 2026-03-26 · Accessed: 2026-10-23Brookfield Wealth Solutions : Annual Report / Form 20-F 2025
    Passages and scope

    Financial year and position at 31 December 2025

    Note 26, F-81; Item 7.B, pp.109–112, especially p.111 on competing positions and passive strategy; Item 10.C, pp.134–135.

    Related-party investments of $13.4bn excluding equity-method investments, including $4.3bn of private loans to Brookfield subsidiaries. Describes conflicts, investment limits and management agreements.

    Consolidated BWS scope. General risk disclosures and procedures do not document the treatment of the specific BIP loan. The complete Form 20-F includes the governance sections; the separate annual financial report contains the accounts and MD&A. SEC filing dated 26 March 2026, accepted the previous evening.

  7. S07 · Brookfield Wealth Solutions / SEC · 2026-08-14 · Accessed: 2026-10-23Brookfield Wealth Solutions : Interim Report Q2 2026, Form 6-K exhibit 99.1
    Passages and scope

    Position at 30 June 2026; six months then ended

    Balance sheet p.1; note 8(c) p.18; note 26 p.46; note 27 pp.47–50.

    Related-party investments of $12.2bn excluding equity-method investments, including $4.1bn of private loans to Brookfield subsidiaries. Identifies the $450m BIP refinancing, shares received in capital transactions and real-estate/BBUC interests.

    Unaudited consolidated BWS accounts, including ANGI. Notes 8 and 26 are not a complete inventory allowing every related exposure to be added automatically. SEC filing date is 14 August, following acceptance on the evening of 13 August.

  8. S08 · Brookfield Corporation / SEC · 2026-08-17 · Accessed: 2026-10-23Brookfield Corporation : Interim Report Q2 2026, Form 6-K exhibit 99.1
    Passages and scope

    Position at 30 June 2026 and structure described in the report

    Report introduction; Glossary p.58; note 3, including p.76, table footnote 6.

    BWS is a separate equity-accounted issuer; BN holds all Class C shares carrying the residual economic interest. The 73% BAM interest is on a combined BN + BWS basis. The 2025 transfer of 4% of BAM to BWS had a $3.5bn transaction value.

    June 2026 accounting structure. Class C ownership gives a residual interest, distinct from BAM’s management role. The report separately discusses the proposed BN–BWS combination, approved by shareholders in July and still expected to close during the year when published in August. SEC filing dated 17 August, accepted on the evening of 14 August.

  9. S09 · American National Group Inc. / SEC · 2026-08-13 · Accessed: 2026-10-23American National Group Inc. : Form 10-Q, quarter ended 30 June 2026
    Passages and scope

    Position at 30 June 2026 and first half of 2026

    Note 1 p.10; note 8 p.21; note 23 pp.43–44.

    ANGI is an indirect wholly owned BWS subsidiary. Reports $9.6bn of related-party investments excluding equity-method investments, including $3.8bn of private loans to Brookfield subsidiaries, and the $450m BIP refinancing.

    ANGI and subsidiaries: a consolidated insurance group, not a single policy-writing company. The passage does not name every legal lender. A subset of BWS, not an amount to add to BWS totals.

  10. S10 · Brookfield Infrastructure Partners / SEC · 2026-08-05 · Accessed: 2026-10-23Brookfield Infrastructure Partners : Interim Report Q2 2026, Form 6-K exhibit 99.1
    Passages and scope

    Loan refinanced on 7 May 2026; position at 30 June 2026

    Note 19, Related Party Transactions, p.40; repeated in MD&A.

    Corroborates the $450m refinancing: 6.33% fixed rate, anticipated repayment on 7 May 2031, final maturity on 7 May 2036; non-recourse to the BIP partnership. BIP describes market terms.

    The note omits the full contract, security, seniority, covenants and detailed signatories. Anticipated repayment differs from final maturity. The refinancing concerns $450m of existing debt, with net cash flows still to reconcile. The market-terms assessment belongs to BIP. SEC filing dated 5 August, accepted on the evening of 4 August.

  11. S11 · Brookfield Asset Management · 2026-08-05 · Accessed: 2026-10-23Brookfield Asset Management : Q2 2026 Supplemental Information
    Passages and scope

    Capital at 30 June 2026; fees for the quarter and trailing twelve months

    Page 24, Brookfield Wealth Solutions; chart checked visually.

    BWS capital managed: $150bn, 56% liquid credit, 38% non-fund private investment and 6% private funds. Stated IMA fees of 25bp plus additional fees on private funds. Also details undeployed commitments.

    Management presentation with rounding and fee-bearing capital measures. Categories do not measure the share of related-party borrowers. The $8.6bn committed is still in liquid credit; do not add it to balances as a separately deployed investment.

  12. S12 · Brookfield Asset Management / SEC · 2026-08-10 · Accessed: 2026-10-23Brookfield Asset Management : Form 10-Q, quarter ended 30 June 2026
    Passages and scope

    Position at 30 June 2026; first half of 2026

    Investments of Consolidated Funds, BSI II, p.25; MD&A Credit, Fee Revenues, note 2; Related Party Transactions.

    Confirms $150bn of BWS capital and $158m of H1 IMA revenues. BSI II sold part of its debt and equity interests in Spring Education to BWS for $129m in H1.

    The mandate is not a loan to BAM. Spring Education consideration is a transaction price, not a closing balance of a debt-only investment. SEC filing on 10 August, accepted on the evening of 7 August.

  13. S13 · Global Atlantic Limited (Delaware) · Accessed: 2026-10-23Global Atlantic Limited (Delaware) : Interim unaudited consolidated financial statements, Q2 2026
    Passages and scope

    Consolidated US GAAP accounts at 30 June 2026; first-half flows. Statements available to be issued on 10 August 2026 according to note 16; exact website publication date not confirmed.

    Note 14, printed pp. 69–71 / PDF pp. 70–72; note 16, printed p. 73 / PDF p. 74; balance sheet p. 2.

    Documents KKR mandates, $247m first-half 2026 in-kind capital contributions, historical prices for DCIF and KPPA interests and a $1bn credit agreement with an affiliate. The related-party table separates $10,479m carrying value from $114m accrued interest.

    Unaudited interim accounts for consolidated GALD. The passage does not name each holding insurance entity or the affiliate borrowing under the $1bn agreement, nor disclose the amount drawn. The historical fund-interest prices do not specify how consideration was settled. The $247m flow is an asset contribution, not a cash contribution.

  14. S14 · Global Atlantic Limited (Delaware) · Accessed: 2026-10-23Global Atlantic Limited (Delaware) : Audited consolidated financial statements, 2025
    Passages and scope

    Year ended 31 December 2025; includes the January 2024 purchase of fund interests. Audit report dated 2 March 2026; exact website publication date not confirmed.

    Note 18, printed pp. 96–99 / PDF pp. 97–100; DCIF/KPPA purchase printed p. 97 / PDF p. 98; audit report PDF pp. 3–4.

    Documents the purchase from KKR of minority limited-partner interests in DCIF for $555m and KPPA for $353m, a calculated total of $908m. Supports the distinction between securities purchases, capital contributions and management services.

    Consolidated US GAAP accounts, without the complete sale agreement or price comparables. The financial-statement audit is not an arm's-length opinion on every transaction. The 2024 price is neither a current valuation of the interests nor a fee.

  15. S15 · National Association of Insurance Commissioners · 2026-09-24 · Accessed: 2026-10-23NAIC Letter to Sen. Warren on Private Equity, Private Credit, and Affiliated Investment Issues
    Passages and scope

    Institutional response and status of reforms as of 24 September 2026

    pp.8–9, 12–14: related-party reporting, affiliated asset management, six codes and transaction oversight

    Distinguishes legal affiliation from broader related-party coding; discusses multiple layers of fees, manager authority over assets and mandate oversight.

    NAIC letter explaining and defending regulators’ framework; it is not an inspection of individual groups or approval of any specific transaction.

  16. S16 · Federal Reserve Bank of Chicago; Ralf R. Meisenzahl, Jackson Overpeck, Andy Polacek · 2026-04-27 · Accessed: 2026-10-23Life Insurers’ Private Credit Investments and Annuity Market Share Capture : WP 2025-09
    Passages and scope

    Revised 27 April 2026; primarily 2017–2024 data and purchases in 2020–2024

    Cover; printed pp. 13, 25–31 (PDF 15, 27–33); footnote 19; tables 6–8

    Documents access to private placements via affiliated issuers, improved maturity matching for indexed annuities, outside holdings of some affiliated issuance, and liquidity and default risks.

    Working paper; authors’ views. Aggregate econometric results with populations and measures distinct from NAIC 2025 and Huber et al. Promised spreads are not realized risk-adjusted profits.

  17. S17 · Amy W. Huber, Stefan Huber, Bella Shan and Christina Zhu; The Wharton School, University of Pennsylvania · 2026-09 · Accessed: 2026-10-23Buying from the Family: Private Equity-Owned Insurers and Their Affiliated Investments
    Passages and scope

    Version currently linked by the author, dated September 2026; 49 pages; holdings and transactions from 2009 to 2024.

    Printed pp. 8–12, 17–20 and 40 (PDF 9–13, 18–21, 41); table 5, col. 2; stress pp. 25–28 and table A3, p. 46

    For privately placed structured securities classified as primary-market trades, Table 5, column 2, estimates the affiliation × direct PE-ownership interaction at 0.465 price points per 100 of par (3,549 transactions). The benchmark is the same security on the same day, bought by independent insurers on an unaffiliated basis.

    Working paper and aggregate regression result. Private primary-market status is inferred using a classifier and a 30-day window. The coefficient measures a purchase-price difference whose interpretation depends on the model and sample. The author-page abstract still contains figures different from the linked PDF; the older $27m annual and 8.9-point figures are excluded. The stress calculation extrapolates beyond CLOs and scales losses to the fixed-income portfolio.

  18. S18 · NAIC Capital Markets Bureau; Jennifer Johnson, Jean-Baptiste Carelus, George Lee · 2025-08 · Accessed: 2026-10-23Private Equity-Owned U.S. Insurer Investments Increased at Year-End 2024
    Passages and scope

    Year-end 2024 holdings; count updated June 2025

    pp. 1–3; footnote 1 on nonpublic company list; tables 1–2

    137 insurers identified at year-end 2024, $704.3bn cash and invested assets, 7.8% of all-lines total; 96% of those assets held by life insurers. Manual identification method explained.

    Evolving count, identified using Schedule Y plus supplementary sources; names nonpublic. Neither denominator nor definition should be equated with “PE relationships” in the 2025 report.

  19. S19 · Federal Reserve Bank of Chicago · 2026-04-27 · Accessed: 2026-10-23Life Insurers’ Private Credit Investments and Annuity Market Share Capture : publication page
    Passages and scope

    Page giving June 2025 and Revised April 27, 2026

    Title, byline, date, abstract and Download link

    Confirms authors, WP 2025-09 status and the 27 April 2026 revision.

    Landing-page summary; detailed findings verified in PDF S16.

  20. S20 · Amy W. Huber · Accessed: 2026-10-23Amy W. Huber : Working Papers: Buying from the Family
    Passages and scope

    Author page accessed on 23 October 2026; paper marked “Updated (Sep 2026)”.

    Working Papers; first paper and Paper link

    Provides the currently linked PDF and working-paper status; lists a presentation at NBER Summer Institute Corporate Finance.

    Its abstract still gives 60.8%, 1.7%, $27m/year and 8.9 points, differing from the current PDF. These figures are not used in the analysis; retain as provenance/version evidence.

  21. S21 · National Association of Insurance Commissioners · Accessed: 2026-10-23Affiliated Investments : Insurance Topics
    Passages and scope

    Current page accessed 23 October 2026

    Background; Related Content

    Explains conditionally permitted affiliated investments, conflicts, concentration and valuation oversight, and broader related-party investments.

    General institutional overview, not state-specific legal advice or an empirical finding about an insurer.

  22. S22 · NAIC Capital Markets Bureau; Jennifer Vento and Michele Wong · 2026-09-24 · Accessed: 2026-10-23U.S. Life Insurers’ Affiliated Investments at Year-End 2025
    Passages and scope

    Year-end 2025 holdings at book/adjusted carrying value; published 24 September 2026 according to Capital Markets Bureau index

    Pages 1–3; Table 1 on page 2; following paragraph for the 28% share; page 3 for concentration among insurers with PE relationships.

    The text reports $321bn of affiliated holdings at year-end 2025, about 5% of life insurers’ cash and invested assets. About 28% of affiliated holdings across four schedules are reported as affiliate credit exposure. Ten insurers with PE relationships account for almost half of all life insurers’ affiliated holdings.

    Four schedules: D, Part 1, Sections 1 and 2; BA; DA. The table gives $322bn versus $321bn in the text, without a published reconciliation. The 28% extends beyond direct loans; the 72% remainder is a reporting-category residual. The detailed 28% calculation, names of the ten insurers and full operational definition of a PE relationship remain unspecified.

  23. S23 · NAIC Blanks(E) Working Group · 2022-05-25 · Accessed: 2026-10-232021-22BWG Modified : Investment schedules: related parties
    Passages and scope

    Adopted 25 May 2022; effective for annual 2022 reporting

    pp. 1–2; Schedule BA, Part 1, column 27; Schedule D, Part 1, p. 5, column 35

    Six electronic codes distinguish direct lending, vehicles with mostly related collateral, vehicles with minority or zero related collateral, substantive related arrangements, other links and no link.

    2022 adoption text; column numbers may have changed with schedule redesign. NAIC 2026 letter confirms the framework. Code 3 includes 0% and all exposures below 50%.

  24. S24 · National Association of Insurance Commissioners · 2026-03 · Accessed: 2026-10-23Accounting Practices and Procedures Manual : as of March 2026
    Passages and scope

    March 2026 manual, 2,117 pages.

    SSAP 25, paragraphs 2, 5–12 and 15–23, pages 25-1 to 25-9 (PDF 174–182); Appendix A-440, paragraphs 1, 2 and 9 (PDF 1100–1101).

    Defines affiliates, related parties and the 10% control presumption; addresses intermediaries, parent loans, service fees, economic transactions and parent-level gains.

    NAIC statutory accounting standards; application depends on state law and circumstances. Do not conflate control presumption, economic ownership and delegated asset management.

  25. S25 · NAIC Blanks(E) Working Group · 2026-08-27 · Accessed: 2026-10-23Adopted Modifications to Financial Statements and Instructions
    Passages and scope

    Index updated 27 August 2026; adoption and implementation dates

    Index: 2021-22BWG Modified, adopted on 25 May 2022 for annual 2022 reporting; 2025-22BWG Modified, adopted on 5 March 2026 for annual 2026 reporting.

    Confirms 25 May 2022 adoption of related-party reporting and annual 2022 implementation; new public/144/private classification effective for annual 2026 reporting.

    Adoption index; details require the text of each amendment.

  26. S26 · Prudential Regulation Authority / Bank of England · 2026-04-29 · Accessed: 2026-10-23CP8/26 : Funded reinsurance
    Passages and scope

    Consultation published on 29 April 2026 and closed on 31 July 2026; status checked on 23 October 2026.

    Paragraphs 1.2–1.8, 1.15–1.16; chapter 3

    Proposes aligning funded-reinsurance capital treatment more closely with economically similar assets by changing the counterparty default adjustment.

    UK proposal targeting implementation on 1 July 2027. In official sources inspected on 23 October, the page retains consultation status. The proposals apply under Solvency UK and have a separate scope from the US transactions examined.

  27. S27 · NAIC Capital Markets Bureau; Jennifer Vento and Michele Wong · 2026-09-01 · Accessed: 2026-10-23Increase Continues for U.S. Insurers’ Outsourcing Investment Management in 2025
    Passages and scope

    Annual 2025 reporting; management outsourced to nonaffiliates

    pp. 1–2, 4–6

    Explains that outsourcing reporting uses 10%/50% thresholds of assets managed and does not necessarily disclose the BACV amount under mandate; about 54% of insurers report nonaffiliated management.

    All-lines insurer counts, not share of sector assets; 10% mandate threshold differs from voting-control presumption. Context source, not quantified comparison of groups.

This analysis is not investment advice.

// cite this analysis

l0g, “The insurer’s money, the group’s business”, l0g.fr, published October 23, 2026, updated October 23, 2026, https://l0g.fr/en/analysis/insurers-affiliated-investments-apollo-brookfield-kkr/


$ cd ../analysis