The regulatory price of a promise

When investment firms buy insurers · Article 6/8 · Documentary research current to 23 October 2026

An annuity still has to fund the same years of retirement, yet the resources required to support it depend on investment ratings, the reinsurance contract and the rules of the country where the liabilities are held. From the British proposal to new US risk factors, public documents trace how that treatment changes and the information needed to measure a capital saving.

Following the division of returns between policyholders, distributors and asset managers, this sixth investigation follows the prudential treatment of insurance promises.

On an insurer’s balance sheet, twenty years of payments to a retiree begin with an immediate question: what value of assets must the company hold today to meet those payments? The answer depends on when benefits fall due, the income expected from investments and the losses the business must be able to withstand. Some assets cover the value assigned to its obligations; own funds absorb adverse deviations. Together, they provide the financial backing for the promise. ¹

On 29 April 2026, the UK’s prudential regulator put striking figures on the importance of the calculation. It estimated that an average funded reinsurance transaction currently involves valuation and capital charges equivalent to 2–4% of the underlying annuity liabilities, compared with 11–15% for economically similar investments. Its proposal would bring the first measure to around 10%. Those figures combine a valuation adjustment, solvency capital and the risk margin. Treating them as three directly interchangeable capital rates would obscure the very mechanism the PRA wants to change. ^{2, 3}

That mechanism matters to groups combining asset management and insurance. Their organisation gives them influence over investment selection, financing and, where they also own a reinsurer, the entity carrying part of the risk. The BIS describes how these choices can combine better investment management with the effects of different reserving and capital rules. Establishing how much each contributes means following the calculation all the way through. ¹

An investment becomes a claim on a reinsurer

Funded reinsurance links a portfolio of assets to the payments the reinsurer undertakes to make while bearing the risks transferred to it. Depending on the arrangement, those assets may be transferred or remain with the insurer ceding the risks, as in funds-withheld structures. The insurer that contracted with the retiree retains its responsibility to that person. On its UK prudential balance sheet, it records a claim on the reinsurer representing the amounts it expects to recover. The investments still matter, but the exposure also takes the form of another company’s promise. ^{1, 2, 4}

The current treatment already includes a safeguard. The value of that claim is reduced to allow for expected losses if the reinsurer defaults. This is the counterparty default adjustment, or CDA. The PRA nevertheless considers its calibration too favourable compared with the treatment of similar direct investments. It proposes anchoring the adjustment to an existing reference: the fundamental spread for financial corporate bonds, selected according to credit quality and the timing of expected payments. ²

The immediate effect works through the asset’s value. When a claim is worth less on the balance sheet while liabilities remain unchanged, the excess of assets available as own funds shrinks. The solvency capital requirement (SCR) measures the capital needed to absorb a shock at a separate stage of the calculation. A rule can therefore make a transaction less attractive by reducing recognised own funds even while leaving the SCR rules in place. The British proposal follows this route; it would also affect how the CDA changes under stress. ^{2, 5}

Method and scope

PRA estimates published on 29 April 2026. l0g normalisation: percentages × £1 billion of annuity liabilities; neither an observed transaction nor an actuarial replication. The measure combines CDA, SCR and risk margin. Bands show the published estimated ranges; the orange point is an approximation for the average case under the proposal. The lower diagram shows the haircut channel with liabilities held constant.

This distinction helps make sense of the amounts. Simply scaling the PRA’s percentages to £1 billion of liabilities gives £20–40 million for funded reinsurance under the current treatment, £110–150 million for comparable investments and around £100 million under the proposal. These are the regulator’s estimates expressed on a common scale, with their original scope. Public data do not allow its actuarial model to be reproduced for an individual transaction. ²

The timetable also matters. The consultation closed on 31 July 2026. It envisages applying the changes to calculations from 1 July 2027, while excluding treaties under which all the covered risks had been fully transferred by 30 September 2026. Our checks as of 23 October identified no final decision on the proposal. The official SS5/24 register still lists the October 2025 edition as current. September therefore defines the proposed boundary between transactions; July 2027 remains a proposed implementation date. ^{2, 6}

Protection begins in the contract

To assign credit quality to the claim, the proposal starts with the reinsurer’s insurer financial strength rating, or IFS. This assesses its ability to meet insurance obligations, taking account of its balance sheet, diversification and regulatory environment, among other factors. It serves a different purpose from the rating of a loan held in the investment portfolio. The country of establishment therefore enters the assessment of the counterparty before the assets pledged as collateral are examined. ²

The PRA proposes up to three independent one-notch upgrades, depending on protections written into the treaty. To qualify for any of them, the insurer must first be able to obtain timely control of the collateral after a default, with identifiable, segregated assets protected from the competing claims specified in the rules. Securities issued by the reinsurer or its affiliates fail this eligibility condition: collateral whose value depends on the same business as the claim provides weak protection against that business failing. ^{2, 7}

The three tests make the value of a contract tangible. One concerns required collateral at least equal to the premium, with subsequent changes constrained. Another concerns matching payments in the same currency and asset eligibility under the cedant’s UK matching adjustment permissions. The third rewards collateral whose weighted average credit quality exceeds that of the reinsurer. These are conditional improvements in the credit quality used for the prudential calculation. ⁷

The decisive detail is the portfolio to which the latter two tests apply. Under the proposal, firms would consider the worst portfolio permitted by the contract, in terms of credit quality and cash-flow mismatches. The reinsurer may have rights to substitute assets. A snapshot of collateral deposited at inception can then tell less than the terms governing what may replace it. A right to recover collateral becomes much more useful when the treaty constrains its composition throughout the arrangement. ^{7, 5}

Method and scope

CP8/26 proposal and draft legal instrument, Annex B, rules 24A.1–24A.3. The three notches are independent, conditional on collateral protections and do not constitute a new agency-assigned rating. Tests 2 and 3 use the worst portfolio permitted by the contract. A+ → AA− illustrates one notch. SCR remains a separate calculation. Relationship diagram; no monetary proportions.

Existing supervisory expectations already address this exposure. SS5/24 asks firms to account for deterioration in the counterparty’s credit quality in the stressed CDA and to assess the consequences of recapturing liabilities. The 2026 debate concerns consistent valuation and incentives within a framework that already requires firms to model downgrades and recapture. ⁸

The rating meets the structure

In the United States, a document adopted during the summer of 2026 reveals another connection between ratings and capital. For year-end 2026, the NAIC introduced specific factors for the CLOs and related instruments covered by its table. CLOs pool loans and allocate their income and losses among tranches with different seniority. The protection afforded to a tranche depends on its position and the losses absorbed ahead of it. The published minutes record the Executive Committee and Plenary vote on 14 August 2026; the tracking page lists the change as adopted. ^{9, 10, 11}

In that table, designation 1.A, associated with AAA, carries a pre-tax factor of 0.158% for bonds other than CLOs/CBOs/CDOs, compared with 0.040% in the CLO/CBO/CDO column. At designation 3.B, associated with BB, the corresponding figures are 4.537% and 25.150%. Applied to a hypothetical book or adjusted carrying value of $100 million, these produce $158,000 and $40,000 in the first case, and $4.537 million and $25.150 million in the second. The arithmetic isolates an asset risk factor before the other stages of the US risk-based capital (RBC) calculation. ^{9, 12}

The revealing feature is that the differences point in opposite directions. The rule recognises the protection available to some senior tranches while requiring more for other parts of the structure. A claim that securitisation always reduces capital would miss this distinction. Understanding the factor requires the rating to be read alongside the claim’s seniority and the way losses reach it. ⁹

A second parameter makes the financial contract more tangible still: tranche thickness. For a BBB− tranche, designated 2.C, of a broadly syndicated loan CLO that meets the surcharge conditions, current thickness of no more than 4% of the underlying portfolio adds 11.77 percentage points to the 3.28% base factor. The result is 15.05%, or $15.05 million on our hypothetical $100 million holding. Thickness measures the slice of portfolio losses between the point where the tranche begins absorbing losses and the point where it is exhausted. It is distinct from the share of that tranche purchased by the insurer. ⁹

Method and scope

NAIC grid adopted for year-end 2026; base pre-tax C-1 factors. l0g amounts use a hypothetical US$100m book or adjusted carrying value, before portfolio adjustments and other RBC calculation stages. The tranche diagram assigns no numerical attachment point. The surcharge example is confined to a BBB−/2.C BSL CLO tranche with current thickness ≤ 4% of the pool. It does not measure a total capital requirement or a realised saving.

Several steps remain before arriving at the company’s own-funds requirement: portfolio adjustments, tax treatment, aggregation across risks and the regulatory intervention level. Multiplication by $100 million makes one factor legible. Measuring a capital raise, distributable funds or a realised saving requires the insurer’s full calculation. The adopted document sets the CLO portfolio adjustment factor at 1 for 2026, while providing for a review of the method for 2027 and subsequent years. ⁹

The quality of the rating remains crucial. In a working paper published on 1 September 2026, Alejandro Drexler and Andy Polacek examine private letter ratings, communicated privately, and their use following the US reform of capital categories. At comparable ratings, their sample contains more securities classified as NAIC6 among privately rated bonds. This category, covering ratings from CC to D, serves as their default proxy and also includes financial distress. They also find that some of the yield difference reflects lower liquidity. Their results call for a distinction between repayment capacity and the cost of selling an asset: yields compensate investors for both risks, which remain separate. The finding is a statistical relationship, rather than a determination that every privately rated security has been misrated. ¹³

In Bermuda, follow the payments through time

The country of establishment can change another part of the equation: the value assigned today to future benefits. In Bermuda, the scenario-based approach, or SBA, allows the asset requirement to be calculated, subject to conditions, by projecting how assets meet payments as they fall due. The rules examine matching, contractual options and currency risks; the method and material changes to it are subject to prudential oversight. Portfolio returns enter a detailed projection of cash flows. ^{14, 15}

The consolidated rules use nine interest-rate scenarios: a base path and eight shocks. Within each scenario, asset cash flows, including repayments, are set against benefit payments through time. A cash-flow shortfall leads to simulated asset sales at the conditions prevailing in that scenario; a surplus is reinvested under the applicable rules. The best estimate liability is the highest initial asset requirement across the scenarios. The risk margin and capital requirement remain further parts of the calculation. ¹⁵

Asset-liability management (ALM) seeks this alignment of payments. Better-matched cash flows can reduce the need to sell in unfavourable conditions. That is an economic benefit a method attentive to timing can recognise. Its measurement nevertheless depends on credit and reinvestment assumptions. The Bermudian handbook requires projected asset cash flows to be reduced for default and downgrade costs. For private or structured assets without a directly published calibration, the insurer’s assumptions are subject to credit floors; for a securitisation, the relevant floor applies to the tranche. ¹⁴

The regulatory transition illustrates how much the scope of a percentage matters. For business already in force on 31 December 2023, the credit downgrade cost included in these projections rises in stages: 20% of the ultimate cost in 2024, 40% in 2025, 60% in 2026, then 80% and 100% in 2027 and 2028. The insurer may also choose to apply the full cost immediately. Default costs apply in full, as do downgrade costs for new business after 2023. The 60% figure therefore concerns a loss assumption in the cash flows of an older stock of business. Translating it into a reduction in total capital would change the measure midway through the calculation. ¹⁴

A notice issued shortly before this article’s research cutoff provides a useful date check. In the notice dated 21 October 2026, the BMA states that its new consolidation of the rules restates existing standards without changing them. The download path carries a 20 October date; that publication difference does not turn the consolidation into a reform. ¹⁶

Nine valuations, and the comparisons still to build

Can the advantage of a jurisdiction be measured at a glance? The IAIS attempted an exercise more carefully controlled than a comparison of headline solvency ratios. Nine volunteer insurers and reinsurers in several jurisdictions were given hypothetical US dollar annuity cash flows to value as of 31 December 2023. They chose portfolios and certain assumptions within their own frameworks. In the report published in November 2025, technical provisions ranged from $52 million to $60 million, prescribed required assets from $53 million to $68 million, and target assets, including the additional buffer selected, from $54 million to $74 million. ¹⁷

Method and scope

IAIS exercise published in November 2025, valuations at 31 December 2023, nine volunteer participants and a shared hypothetical dollar cash-flow profile. Participants choose portfolios and some assumptions. Endpoints are not paired across measures; neither individual capital buffers nor jurisdictional rankings are inferred. The $15m range width is calculated as 68 − 53.

The dispersion shows the financial importance of the calculation. It also combines several causes: regulation, the returns on the assets selected, portfolio construction and modelling. The IAIS highlights differences between participants within the same jurisdiction, anonymises the results and rules out using them to rank countries by prudence. Nor can the published endpoints be used to subtract the lowest technical provisions from the lowest required assets and recover a company’s capital requirement. Those observations may come from different participants. ¹⁷

The same reasoning applies to the public reports of groups examined in this series. Athene’s 2025 Bermuda reports and Global Atlantic Re’s report describe their methods and disclose measures of provisions, eligible resources and required capital. They allow each entity’s balance sheet to be read on its own terms. The documents reviewed do not provide a counterfactual valuation of the same portfolio under another regime that would isolate the effect of domicile. A higher ratio, or a change in own funds, still leaves the underlying contributions unresolved. ^{18, 19}

The BMA itself provides a method for establishing them. Its notice of 2 April 2025 asks for a reconciliation, for the relevant reinsurance blocks, between assets needed by the cedant and by the Bermudian reinsurer. This must distinguish the effects of book and market values, liability assumptions, discounting, the SBA and capital, with explicit target ratios. A change in asset allocation must appear separately. The reconciliation sets out the information needed to attribute relief to its cause; the public reports reviewed do not provide it transaction by transaction. ²⁰

Capital savings can support a real service

The counterargument deserves to be followed through. An insurer expecting regular payments far into the future can make productive use of assets that are difficult to sell, provided their cash flows arrive at the right time. A reinsurer can also bring diversification, additional capital and investment selection capabilities. The PRA recognises these potential benefits; the contractual protections it proposes to reward give them a place in its reform. ^{8, 21}

Research by Ralf Meisenzahl, Jackson Overpeck and Andy Polacek, revised on 27 April 2026 and published by the Chicago Fed, provides empirical support for that possibility. The authors link certain private investments to closer maturity and cash-flow matching for US indexed annuities, and to the growing market share of fund-owned insurers in that business. The finding applies to the products and data studied. It supports the existence of an economic service without measuring how the benefit is shared or establishing the strength of each reinsurance treaty. ²²

For an investigation into a particular group, the decisive document would therefore reconcile the same block before and after cession, identifying the investments, rights over collateral and valuation assumptions. It would help separate the contribution of better-matched payments, actual risk transfer and a change in prudential treatment. Public rules and tables show where those effects enter the calculation; attributing financial amounts to them requires transaction data. ^{20, 17}

For the retiree, the promise remains a stream of payments to be received. Its protection depends on the companies’ ability to fund them through adverse scenarios, and on the insurer’s rights when its partner stops fulfilling its part of the contract. The next stage of this investigation will follow those liabilities back: the assets recovered must then find their place in a balance sheet and a schedule of benefit payments. ⁸

Further reading: Jackson and Athene’s Bermuda reinsurance, affiliated investments within insurance groups, and the guide to reading a life insurer’s financial strength.

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Method. This documentary investigation draws on the regulatory texts, adopted tables, research papers and public reports cited below. Illustrative amounts apply percentages to explicitly hypothetical bases. The source notes set out the relevant passages, scopes and comparison limits; attributing a capital saving to a particular group would require its transaction data.

Sources

Each note identifies the document, period, relevant passage and limitations. Statements by companies and regulators are attributed to their authors.

1. S01 · Bank for International Settlements : Fabian Garavito, Ulf Lewrick, Tomas Stastny, Karamfil Todorov · Accessed: 2026-10-23Shifting landscapes: life insurance and financial stability
   Passages and scope

   September 2024 analysis; stylised balance-sheet example, not an observed transaction.

   Sections “Life insurers’ profitability and interest rates – a primer” and “Asset-intensive reinsurance – risk-sharing and other incentives”; Graphs 1 and 3.

   Explains the interaction of technical provisions, capital requirements and required assets, and potential gains for cedant and reinsurer in an example of regulatory differences.

   The example is theoretical. It quantifies neither a universal Bermuda advantage nor a realised group profit. Authors’ views are not a new regulatory standard.

2. S02 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23CP8/26 : Funded reinsurance
   Passages and scope

   Consultation close 31 July 2026; proposed application 1 July 2027; transaction cutoff 30 September 2026

   §§1.15–1.16, 3.5–3.24, 3.27–3.38, 4.6–4.13

   Consultation and cost-benefit analysis. Distinguishes valuation of the reinsurance recoverable, SCR and risk margin.

   Ratios are estimates and cases illustrative. The source does not allow full actuarial replication for an individual transaction. Proposals are not rules in force.

3. S03 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23PRA publishes plans to support resilience in the life insurance industry
   Passages and scope

   Announcement of CP8/26 proposals

   News release paragraphs 1–10 and Notes to editors

   Official communication of 2–4%, 11–15%, around 10% and roughly £40bn exposure.

   Uses simplified capital terminology; read with CP8/26 §4.11 to distinguish total valuation and capital charges from SCR alone.

4. S04 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-232025-10-L : RBC Asset Credit for Modco/Funds Withheld
   Passages and scope

   Adopted 30 June 2025, applicable at year-end 2025.

   PDF pp.1–2, LR045–LR048 Basis of Factors.

   Cedant C-1 relief is conditional on transfer of asset risk over the entire treaty; restriction on concurrent pledging for the cedant’s own benefit.

   Assets can remain on the cedant’s balance sheet. This does not by itself quantify total group or foreign reinsurer capital.

5. S05 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23CP8/26 Appendix 2 : Draft updates to SS5/24
   Passages and scope

   Draft for consultation, April 2026

   Printed pp.23–26 / PDF pp.24–27; chapter 5; §5.2, §5.5–5.11

   Proposed expectations for cash-flow matching, weighted average credit quality and rating governance.

   Marked Draft for consultation; tracked amendments are not current expectations.

6. S06 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23SS5/24 : Funded reinsurance: current-version landing page
   Passages and scope

   Current version published 23 October 2025, effective 27 October 2025; checked 23 October 2026

   Current version and Past versions sections

   The official page still identifies the October 2025 edition as current. Positive status check alongside searches for CP8/26 decisions.

   The page alone cannot prove the absence of all later communications; no final CP8/26 decision was identified in targeted searches as of 23 October 2026.

7. S07 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23CP8/26 Appendix 1 : PRA Rulebook: Funded Reinsurance Instrument [2026]
   Passages and scope

   Draft instrument, commencement date shown as [DATE]

   PDF pp.2–4; Annex A definitions; Annex B 24A.1–24A.5

   Exact draft language: financial corporate bond FS, IFS rating and three conditional one-notch upgrades, worst-case permitted collateral.

   Consultation draft; it creates neither a public guarantee nor an agency rating of the individual contract.

8. S08 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23SS5/24 : Funded reinsurance, October 2025
   Passages and scope

   Effective 27 October 2025; current at check date

   Printed pp.2–6, 10–16 / PDF pp.3–7, 11–17; §§1.5, 2.5–2.12, 3.6–3.15

   Current expectations: concentration limits, immediate recapture, default and downgrade, wrong-way risk, conditional recapture into an MA portfolio.

   A supervisory expectation is not a uniform factor applicable to every transaction; models and contracts differ.

9. S09 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-232026-12-IRE MOD : CLO RBC Factors
   Passages and scope

   Working-group adoption 23 June 2026; Capital Adequacy adoption 30 June 2026; applicable at year-end 2026.

   PDF pp.1–2 (adoption, scope, Chart 1); p.4 (thickness); p.6 (PAF); p.7 (LR002 factors).

   Pre-tax C-1 factors for CLO/CBO/CDO investments, 11.77-point surcharge for specified thin BSL CLO tranches, CLO PAF set to 1.

   Final rounded table differs from early proposals. Factors are inputs to RBC. The numerical example uses 2.C; application to NAIC6 is not inferred.

10. S10 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23Adopted Modifications to Risk-Based Capital Formulas
    Passages and scope

    Register last updated 1 July 2026, accessed 23 October 2026.

    Rows 2026-12-IRE MOD, 2025-22-IRE, 2025-10-L, 2024-24-L MOD.

    Adoption dates and first applicable year-end.

    Capital Adequacy tracker; subsequent Executive/Plenary vote is documented separately in S11.

11. S11 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23Executive (EX) Committee and Plenary : Minutes, August 14, 2026
    Passages and scope

    Vote held 14 August 2026; draft minutes dated 26 August.

    §11 printed p.6/PDF p.7; Attachment Four PDF p.58 (factors).

    Unanimous adoption of CLO factors applicable at year-end 2026.

    Minutes marked Draft Pending Adoption, distinct from the completed rule-adoption vote they record; cross-checked against the adopted text and register, S09 and S10.

12. S12 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23Purposes and Procedures Manual of the NAIC Investment Analysis Office : December 2025
    Passages and scope

    December 2025 edition: provisions effective at 31 December 2025, plus amendments scheduled for 2026.

    Printed pp.93–99/PDF 123–129 (challenges); p.121/PDF 151 (multiple ratings); pp.124–125/PDF 154–155 (PLRs); p.130/PDF 160 (rating equivalence matrix).

    Rating-to-designation mappings; challenge process with a three-notch materiality threshold; private-rating documentation.

    The edition predates 2026 changes. Its CLO modelling timetable does not establish actual implementation: see S30. NAIC designations are regulatory classifications, not investor credit ratings.

13. S13 · Federal Reserve Bank of Chicago : Alejandro Drexler, Andy Polacek · Accessed: 2026-10-23Market Knows Best: The Not So Hidden Risks of Private Ratings : WP 2026-17
    Passages and scope

    Reform announced in 2017 and implemented in 2021; recent purchases and defaults studied through 2025.

    Introduction, printed pp.1–3 / PDF pp.3–5; section 3 and conclusion, printed pp.24–26 / PDF pp.26–28.

    The authors study private letter ratings and distinguish default risk from liquidity. Their method uses NAIC6 classification as its default proxy and also attributes part of the spread difference to illiquidity.

    Working paper, not a regulatory decision. NAIC6 includes CC through D, so the proxy extends beyond observed payment defaults (section 2.2, PDF p.12). Footnote 19 gives a different equivalence, which is not used. Findings do not establish misconduct by a named insurer or agency. The conclusion specifies 2020–2024 purchases; the introduction describes 2020–2025 observations. No numerical estimate is generalised.

14. S14 · Bermuda Monetary Authority · Accessed: 2026-10-232025 Year-end Long-Term Instructions Handbook
    Passages and scope

    Year-end 2025 handbook; 2024–2028 transition and SBA conditions

    C30.1f–g p.151; E4 p.272; E9 p.284; E10 pp.285–288; especially E10.8–11 p.286 and E10.16–17 p.287

    Default and downgrade costs reduce projected asset cash flows. For business in force at year-end 2023, the downgrade component applies at 20/40/60/80/100% in 2024–2028; default costs and new-business costs apply in full. Private and structured assets use own assumptions with floors.

    Transition percentages apply only to a downgrade cost in liability valuation, never to total required capital. Early adoption is possible. Eight stresses plus the base scenario make nine in the rules.

15. S15 · Bermuda Monetary Authority · Accessed: 2026-10-23Insurance (Prudential Standards) (Class C, Class D and Class E Solvency Requirement) Rules 2011 : consolidated October 2026
    Passages and scope

    Consolidated version published 20 October 2026; unchanged rules per 21 October notice

    Schedule XXVI paragraphs 27–28 printed pp.349–351/PDF 350–352; paragraph 29 printed pp.366–367/PDF 367–368; paragraph 30 printed p.367/PDF 368; Class C version later

    The standard approach uses a risk-free curve with an appropriate illiquidity adjustment. SBA requires matched portfolios and matched or hedged currencies, nine interest-rate scenarios, modelled sales and reinvestment, and BEL set to the highest asset requirement. Fungibility between blocks requires proof and approval.

    Long document repeating provisions by class. These locators refer to Schedule XXVI for Classes D/E. The October 20 consolidation does not change the rules. SBA does not imply a uniform capital discount.

16. S16 · Bermuda Monetary Authority · Accessed: 2026-10-23Notice: Consolidated Prudential Standard Rules
    Passages and scope

    Notice dated 21 October 2026; file/index dated 20 October 2026

    Single page, final two paragraphs

    BMA explicitly says the publication consolidates existing prudential standards without changing them.

    One-day discrepancy between file/index and printed date. This is not a new substantive reform.

17. S17 · International Association of Insurance Supervisors (IAIS) · Accessed: 2026-10-23Issues Paper on structural shifts in the life insurance sector
    Passages and scope

    Valuation exercise as at 31 December 2023; discussions in 2023–2024; published November 2025.

    Section 3.5.6; section 4.2.5, Box 4 and Table A, PDF pp.56–57; section 4.2.6, PDF pp.57–58.

    Nine volunteer insurers and reinsurers value hypothetical US-dollar annuity cash flows. Published ranges: technical provisions $52–60m, prescribed total assets $53–68m, target total assets $54–74m.

    Participants choose portfolios, yields and some assumptions; unusually long duration for some. Jurisdictions and participants anonymised. Endpoints across the three measures are not paired. No statistical significance or ranking of regimes; dated exercise, not a 2026 tariff. Individual data are not published in the table.

18. S18 · Athene Bermuda Sub-Group · Accessed: 2026-10-23Athene Bermuda Sub-Group Financial Condition Report 2025
    Passages and scope

    Position at 31 December 2025; April 2026 report

    Section 7(b) p.39; section 8(a)(vii) p.43; section 8(b)(i) and notes pp.44–45

    Describes primary use of SBA; reports several capital measures for AARe, ALRe and ALReI, MSM/ECR requirements and transitions.

    Company disclosure. Consolidation creates overlap across the three entities; do not add them. GAAP/SFS/EBS differences do not isolate the effect of SBA or domicile. Exact publication date not identified; PDF says April 2026.

19. S19 · Global Atlantic Re Limited · Accessed: 2026-10-23Global Atlantic Re Limited Financial Condition Report 2025
    Passages and scope

    Position at 31 December 2025; subsequent events assessed through 24 April 2026

    Section IV pp.24–25; Section V pp.26–28; Section VI p.29 (PDF + 2)

    Describes SBA through assets needed to fund cash flows and the most demanding scenario; net BEL of $56,328m, risk margin of $375m, technical provisions of $56,703m, eligible capital of $4,710m and ECR of $2,301m.

    Company disclosure. The GAAP/statutory bridge p.27 labels amounts as thousands inconsistently with prose and scale: do not use it without clarification. Gross BEL minus recoverables has rounding differences. No isolated jurisdiction effect. Exact upload date unknown.

20. S20 · Bermuda Monetary Authority · Accessed: 2026-10-23Notice: Prior Approval of New Long-Term Block Reinsurance Transactions
    Passages and scope

    Process operating since January 2023; scope and TAR reconciliation clarified April 2025

    pp.1–3; appendix item 13 and nine attribution steps, pp.4–6

    BMA requires prior approval for new blocks and modifications; compares technical provisions plus required capital at disclosed target solvency ratios and requires a detailed cross-jurisdiction attribution.

    Individual submission is not public. No transaction-level capital saving is disclosed and the notice does not establish that every Bermuda cession lowers required assets.

21. S21 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23Innovation and Resilience in the BPA Sector : speech by Gareth Truran
    Passages and scope

    Year-end 2024 MA portfolio data; 2025 funded reinsurance premiums; April 2026 proposal

    Sections Trends in investments and Funded reinsurance

    PRA recognises diversification and asset-access benefits; explains public/internal ratings, CDA and the alternative of unbundling transactions.

    Regulatory speech, aggregate analysis and institutional views. £6.5bn is 2025 premiums, not an exposure stock.

22. S22 · Federal Reserve Bank of Chicago : Ralf R. Meisenzahl, Jackson Overpeck, Andy Polacek · Accessed: 2026-10-23Life Insurers’ Private Credit Investments and Annuity Market Share Capture : WP 2025-09
    Passages and scope

    June 2025 working paper, revised 27 April 2026; observations including 2017–2024.

    Section 4.3, printed pp.21–24 / PDF pp.23–26; section 4.4.1, printed pp.25–27 / PDF pp.27–29; abstract.

    The authors link certain private placements to better maturity and cash-flow matching for indexed annuities and market-share growth among PE-owned insurers.

    Sample-based findings concentrated in US indexed annuities. No capital saving on an individual reinsurance treaty is measured here. Authors’ views, not an official Federal Reserve position; working paper. Spread estimates discussed in article 5 are not reused.

23. S23 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23Life Insurance Stress Test: 2025 Results
    Passages and scope

    Balance sheets at 31 December 2024; 2025 stress-test exercise

    Annex 2, Exploratory scenario findings : FundedRe recapture; notes 4 and 7

    Recapture scenario: £12.3bn liabilities, SCR coverage 154% to 144%, SCR +6%, eligible own funds −1%.

    Exploratory scenario without a target probability; subset with material exposure, one counterparty per firm, no currency stress and most collateral MA-eligible.

24. S24 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-232021-11-L Life Bond Factors (ACLI)
    Passages and scope

    2021 proposal, labelled Adopted on the current tracking page; factors confirmed in the adopted 2026 schedule.

    PDF p.2, LR002; presentation p.36.

    Historical 20-category bond C-1 factors.

    The archived form retains the Exposed box; the current NAIC tracker labels it Adopted, and the factors are cross-checked against S09/S11.

25. S25 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23Reinsurance Recapture Charge : Financial Condition (E) Committee Referral
    Passages and scope

    Directive dated 27 July 2026; implementation methods exposed in August–September 2026; target year-end 2027.

    PDF p.1 (implementation options); pp.2–3 (signed directive, jurisdictions and timetable).

    Planned recapture charge outside reciprocal jurisdictions and improved treatment of reinsurer financial strength.

    Development directive, not a finalized calibration. Bermuda is expressly identified as reciprocal; the first measure therefore does not target every Bermuda transaction.

26. S26 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23NAIC Letter to Senator Warren on Private Equity, Private Credit, and Affiliated Investment Issues
    Passages and scope

    Letter dated 24 September 2026.

    pp.4–6 (bond definition and ratings); pp.7–8 (capital); pp.14–17 (PLRs and challenges).

    Official update on reforms and their purposes; three-notch threshold and final state-regulator decision.

    An institutional NAIC account; the effectiveness of every measure or absence of risk is not established by a response letter.

27. S27 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23Life Risk-Based Capital (E) Working Group
    Passages and scope

    Page accessed 23 October 2026; recapture comment period ended 23 September; next meeting announced for 28 October.

    Exposure Drafts; Additional Life RBC Guidance.

    Public project tracking and status.

    Live page; a meeting announced after the cutoff is not treated as completed.

28. S28 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-232024-24-L MOD : Principles-based Bond Project (Life RBC)
    Passages and scope

    Adopted 15 May 2025 for year-end 2025; accounting bond definition effective 1 January 2025.

    PDF p.1 and bond/non-bond classification tables.

    RBC implementation of the principles-based bond definition.

    There is no universal factor for all private credit: classification, collateral and structure matter.

29. S29 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23How Insurance Regulators Ensure Insurers Have Enough Money to Pay Claims: Leveraging Credit Ratings for Regulatory Use
    Passages and scope

    NAIC brief dated March 2026.

    PDF pp.1–2.

    Concise explanation of SVO discretion, scope and safeguards.

    Explanatory brief rather than the manual; later status is cross-checked in S26 and S30.

30. S30 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23Invested Assets (E) Task Force : Minutes, August 13, 2026
    Passages and scope

    Meeting held 13 August 2026; draft minutes dated 17 August, pending adoption.

    Attachment One, PDF pp.12–14: CLO filing exemption and SVO discretion.

    Change of direction on CLO modelling; designation-challenge process reported operational.

    Draft minutes. Reporting that the process is operational does not establish a published number of actual reclassifications.

31. S31 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23RBC Investment Risk and Evaluation (E) Working Group : Agenda and Materials, October 5, 2026
    Passages and scope

    Materials for the 5 October 2026 meeting.

    Agenda; September ACLI comments; structured-assets work plan.

    Check of further work after CLO factor adoption.

    Includes research and industry requests; not a decision changing the factors. Charts from earlier proposals are not used.

32. S32 · National Association of Insurance Commissioners (NAIC) · Accessed: 2026-10-23Investment Designation Analysis (E) Working Group
    Passages and scope

    Page accessed 23 October 2026; next meeting announced for 28 October.

    Adopted Interim Changes; meeting agenda.

    Check of recent P&P Manual changes and timetable.

    The page alone is not a complete decision archive; cross-checked with S30/12.

33. S33 · Bermuda Monetary Authority · Accessed: 2026-10-23Guidance Notes for Commercial Insurers and Insurance Groups’ Statutory Reporting Regime
    Passages and scope

    EBS and commercial reporting framework from 31 March 2024

    Paragraphs 1–9, printed pp.6–7/PDF 5–6; paragraph 50 printed p.18/PDF 17

    The EBS underpins ECR calculations. Statutory and economic statements use distinct valuation bases. EBS treatment of modco should be similar to GAAP, provided a fair-value approach is adopted.

    Read with consolidated rules and the 2025 handbook; some wording retains historical proposal language.

34. S34 · Bermuda Monetary Authority · Accessed: 2026-10-23Insights and Reflections on Asset Intensive Reinsurance in Bermuda
    Passages and scope

    Regulator analysis and position, March 2025

    pp.7–9, Regulatory Enhancements and Regulatory differences

    BMA describes private capital as a capacity provider and explains transaction review, collateral and reconciliation of total asset requirements.

    The jurisdiction’s own regulator defending its market; attribute its assessment. A high solvency ratio alone does not establish the absence of regulatory arbitrage.

35. S35 · Bermuda Monetary Authority · Accessed: 2026-10-23Lapse, Liquidity and Scenario-Based Approach Return : 2025 Completion Instructions
    Passages and scope

    Reporting instructions for year-end 2025

    Paragraphs 1–4 p.3; SBA tables and BEL movement analysis pp.29–35

    Confirms prudential amendments effective 31 March 2024; collects detailed assets, cash flows, lapse risk, liquidity and SBA model information.

    Reporting instructions, not disclosure of individual results.

36. S36 · Global Atlantic Assurance Limited · Accessed: 2026-10-23Global Atlantic Assurance Limited Financial Condition Report 2025
    Passages and scope

    Position at 31 December 2025; subsequent events assessed through 24 April 2026

    Section V pp.24–26; Section VI p.27 (PDF + 2)

    Reports eligible capital of $1,571m, ECR of $190m, and qualitative differences between statutory and economic capital.

    Company disclosure; no like-for-like counterfactual or SBA saving. A separate entity from GARe; not selected for the core article.