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The Inflation Management Opportunities In The Insurance Industry Today

Inflation has become a major focus for insurance companies and many others interested in the industry. We've designed a new approach to exploiting the opportunities, combining new analytical tools with long-standing risk management principles for financial intermediaries.

The Authors
Bill Poutsiaka, Enterprise Driven Investing, LLC 
Michael Ashton, Enduring Investments 
Amnon Levy, Bridgeway Analytics   

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Bridgeway Analytics RBC-IRE-WG Comment Letter Re: Oliver Wyman Residual Tranche Report

The NAIC adopted interim 45% capital charges for residual interests of Asset-Backed Securities held by life companies; the charges previously aligned with the 30% equity charge assigned to operating companies. The adoption was a compromise with strong and differing views. The capital charges are interim in that they are expected to be overridden as the Academy progresses with a long-term solution for the treatment of structured assets. Oliver Wyman conducted an empirical assessment of the 45% interim ABS residual tranche C-1 capital charge on behalf of the Alternative Credit Council (“ACC”), the private credit affiliate of the Alternative Investment Management Association Ltd (“AIMA”), to which the Risk-Based Capital Investment Risk and Evaluation (E) Working Group (RBC-IRE-WG) requested comment.
Our comment letter to the Risk-Based Capital Investment Risk and Evaluation (E) Working Group on the Oliver Wyman Residual Tranche Report explores:

  • The Oliver Wyman study in the context of the C-1 framework. We focus entirely on the technical aspects of the approach. While we do not dismiss valuable lessons from the study, the methods depart from those used to estimate C-1 charges for bonds, equity, and other assets in several dimensions, including a lack of consideration for portfolio concentration and diversification effects. In addition, the study takes on the significant effort of assessing past experience and estimating baseline and stress loss scenarios across different markets, which is no easy task and requires a heavy dose of professional judgment. We conclude that differences in approaches can result in significant differences in risk assessments.

  • Our own analysis of data to differentiate the risks of CLO residuals and those of other asset classes. We draw two conclusions from our analysis:

    • Not all corporate equity or CLO residual interests exhibit the same risks, and ‘comparable attributes,’ defined by the American Academy of Actuaries in their Principles for Structured Securities RBC presentation in Attachment C, can help identify those risks.

    • The patterns are consistent across different lenses, suggesting differentiated tail risks of CLO residuals can be estimated for C-1.

In our opinion, a more thorough analysis is needed to assess an appropriate capital charge for residual interests of ABS.  

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Modernizing the NAIC’s Investment Risk Oversight Framework

Efforts to revise the NAIC investment risk oversight framework are moving forward on several fronts. The Financial Condition (E) Committee (E-Committee) formed a Drafting Group of regulators, which has mapped out a Workplan. The Workplan includes an assessment of a significant expansion of the NAIC’s analytical capabilities through centralized investment expertise (CIE). The effort acknowledges that the SVO currently limits its focus on credit risk, highlights regulators’ needed understanding of macroprudential and emerging risks, as well as needed guidance on policy design. In addition, the E-Committee is petitioning for the development of a request for proposal to engage a consultant who would help the NAIC develop a due diligence program over the ongoing use of agency ratings. 

This report reviews these developments and relates them to workstreams at the NAIC, which continue in parallel.

We hope you find this resource helpful It is consistent with our goal of bringing value to our community About the

Amnon Levy is the CEO of Bridgeway Analytics.
Brett Manning is a Senior Predictive Analytics Specialist at Bridgeway Analytics. 

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Investment vehicles: An update from the 2024 Spring National Meeting

In his Insurance Asset Risk article, Amnon explores possible changes to the treatment of direct investments in vehicles, with delineations determined by how the vehicle’s debt is classified under the principles based bond definition. A critical implication is the capital treatment that can either align with the 30% corporate equity charge if held by life insurers or be classified as residual interests of asset-backed securities and receive 45%. Aspects of classification that continue to be deliberated over include whether or not the vehicle is SEC-registered and the degree to which the vehicle is leveraged.

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Join Amnon Levy,'s Stewart Foley, and special guest Washington DC Associate Director of Insurance Philip Barlow to explore developments from the NAIC 2024 Spring National Meeting in a replay of their March 28, 2024 discussion:  

  • The classification of asset-backed securities and feeder funds

  • Overseeing the use of agency ratings: Extending NAIC staff discretion and the E-Committee Workplan

  • Designations and capital for CLOs and asset-backed securities

With $trillions of investments possibly impacted, the implications are broad for insurers and capital markets.

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What’s next for the rules that govern insurers’ investments:

Developments from the NAIC’s 2024 Spring National Meeting

Regulators continued their efforts to refine the rules to align with insurers’ shifting investment strategies more closely at the NAIC 2024 Spring National Meeting in Phoenix. At its core is an aspiration of achieving “equal capital for equal risk,” which is no easy task considering the interconnected components of the framework that governs insurers’ investments. There were significant developments on multiple fronts, including:

  • Changing the classification and valuation across categories of insurers’ investments whose risk characteristics can vary significantly. This includes the debt and residual interests of asset-backed securities (ABS).

  • Addressing concerns over ‘blind reliance’ on agency ratings in NAIC Designations, which help oversee hundreds of thousands of debt instruments worth $trillions of insurers' debt investments. Designations aspire to consistently rank order credit risk which is argued to be challenged by agencies using different methodologies and standards.

  • Differentiating capital for structured assets and residual interests of ABS, which include investment vehicles. While structured products are argued to provide attractive risk-adjusted returns, the products are complex, and establishing the appropriate capital requirements for such products requires a deep understanding of their nuanced risk-mitigating features and performance.

  • Moving forward with the Financial Condition (E) Committee’s long-term aspirations of modernizing the NAIC’s investment oversight framework.


This report reviews these recent developments, their potential implications for investment strategy, and what might happen next.

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Join Amnon Levy,'s Stewart Foley, and SSNC's Scott Kurland and Samuel Jones to explore tips for ensuring a smooth year-end filing process. The typical investment portfolio of an insurance carrier today is far more diverse and complex than it was ten years ago, and the need for data management and controls couldn't be more critical. This challenge is magnified by the significant changes to the NAIC's classification of debt, equity, and residual interests. The principles-based approach that will be rolled out in 2025 will, by its nature, take time for regulators in the industry to converge on how different types of assets will ultimately be classified and the sort of justification that is expected of insurers when they choose to classify an asset one way or another. With significant implications of classification on capital treatment, there could be broad implications for investment strategies and capital markets.

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In his latest Insurance Asset Risk article, Amnon Levy explores a fundamental challenge all capital market participants face with assessing risks across assets and the role rating agencies play in addressing those challenges.

In the context of U.S. insurers, agency ratings can be used in obtaining NAIC designations that feed into the regulatory oversight process, creating an inherent conflict of interest driven by rating agencies' commercial incentives and insurers' desire to, all else equal, minimize regulatory capital. The NAIC has long been concerned with relying on agency ratings and continues to refine the designation process to ensure greater consistency, uniformity, and appropriateness to achieve the NAIC's financial solvency objectives. The 2023 NAIC Fall Meeting brought several advancements to revise the designation process, including a proposal that would extend staff discretion over rating agency-based designations in an effort to move away from 'blind reliance' on agency ratings and an update on NAIC model based designations for CLO that will be effective in 2024. 

The report breaks down the fundamental challenges of overseeing credit risk that transcends agency ratings, which need to be deliberately considered when designing mechanisms for investment risk oversight, whether in the context of using agency ratings or NAIC model-based designations. The report also explores how other jurisdictions have approached overseeing agency ratings, along with other mechanisms outlined in another recent Bridgeway Analytics report, Overseeing Designations and the Prudent Use of Agency Ratings

2023 Nall National Meeting

Join Virginia Commissioner and NAIC Secretary-Treasurer Scott White, Bridgeway Analytics' Amnon Levy, and's Stewart Foley to explore the What's Next for the Rules that Govern Insurer's Investments: An Update from the 2023 NAIC Fall National Meeting. Significant developments to the landscape include modernizing the investment risk framework, designations and oversight of agency ratings, revisions to the treatment of structured assets and investment vehicles, and the treatment of asset concentration risk.

Register here for the live webinar on Friday, December 15, 2023 @ noon ET.

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This report reviews the 2023 NAIC Summer Meeting, which brought progress on several initiatives to revise guidelines with potentially far-reaching implications for insurers’ investment strategy and capital markets:

  • Classification of investment vehicles, including debt and residual interest of structured products.

  • Potential revisions to the designation process, which determines capital for debt instruments.

  • Efforts to revise the capital framework to differentiate structured assets.

In addition, the Financial (E) Committee (E-Committee), whose working group’s mandate includes overseeing many of these initiatives, met to explore the Committee’s Framework for Regulation of Insurers Investments further. As a reminder, the Framework proposes a modernization of investment risk oversight, which is significant.

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Following the Global Financial Crisis (GFC), insurers faced a low-yield environment, prompting a significant shift towards higher-yielding alternative assets. This transition encompassed various strategies, such as private debt and equity placements, structured products, and cost-effective investment vehicles, including custom-designed, non-SEC registered funds tailored to their specific requirements. Up to the present, regulations have been tactically modified to evolving market dynamics. An August 2023 memo from the Financial Condition (E) Committee proposes a comprehensive reassessment of the regulatory framework for insurers' investments. This initiative acknowledges the imperative to modernize the existing structure to better align with contemporary needs. This report builds on the memo’s aspirational vision to modernize the NAIC’s oversight of investment risk and to use available resources cost-effectively, aiming to achieve the principle of “Equal Capital for Equal Risk.”Given the complexities involved with the needed depth and breadth of tools with considerations for the broad set of capital markets, statutory accounting, RBC, etc., this report introduces candidate core principles for investment risk oversight:

  1. Clarity–ensuring each component of the framework has a well-articulated objective and definition.

  2. Consistency–ensuring different types of investments are handled objectively and consistently across the framework.

  3. Governance–ensuring ongoing governance across the framework, including a model risk management framework with defined standards.

This report also introduced supervisory roles and responsibilities for insurers, NAIC staff, regulators, and external consultants, with deliberate considerations for potential conflicts of interest that tie back to the core principles. By deliberately leveraging resources efficiently and approaching the redesign to balance prudence and cost-efficiency while incorporating lessons learned from initiatives such as CCAR and Solvency II, we are confident that the U.S. insurance regulatory framework can be adapted to benefit policyholders and insurers

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The post-Global Financial Crisis (GFC) low-yield environment had insurers move more heavily toward higher-yielding alternative assets. These included strategies using private placements of debt and equity, structured products, and lower-cost, efficient investment vehicles, often bespoke private, non-SEC registered funds designed to address insurers’ unique needs. To date, the changes to investment guidelines have tactically responded to changing market conditions. The Financial Condition (E) Committee August 2023 memo outlines a holistic rethink of how insurers' investments are regulated, recognizing the need to modernize the framework.

This report addresses one aspect of the proposal by outlining candidate principles along with roles and responsibilities for overseeing designations, a mechanism that would allow for the prudent use of rating agencies – without mechanist reliance on such ratings or wholesale outsourcing of risk analysis to the NAIC. The mechanisms we propose to oversee designations deliberately consider the efficient use of resources, including NAIC staff, rating agencies, and other external solution providers. They also deliberately address challenges in credit risk measures and assessing their performance, including:

  • Measures of default risk, an inherently remote event, cannot be assessed robustly given the dearth of default data.

  • Level-setting risk across asset classes is challenging because different risk factors impact different credit segments (e.g., corporate vs. municipal).

  • Controlling for variation in methods and standards across Credit Assessment Providers whose methods necessarily involve subjectivity.

  • Avoiding conflicts of interest driven by rating agencies’ commercial incentives.

Statutory Accounting Principles are designed to provide transparency over solvency by separately reporting the value of reserves and surplus that are part of admitted assets. Reserves represent the value of assets required to support financial risks, benefits, and guarantees associated with the policies, with the remaining value of admitted assets reported as surplus, sometimes referred to as 'Capital and Surplus,' and used in to provide an adequate margin of safety. Life insurance policies and fixed-income assets are largely accounted for symmetrically at cost and insulated from interest rate fluctuations. Interest Maintenance Reserve (IMR) is an accounting construct designed to safeguard against the potential misrepresentation of surplus due to asset sales and keep the anticipated investment yield consistent with that needed to support the policies.

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In a declining interest rate environment, an insurer could sell fixed-income assets, recognize gains, and increase surplus. In reality, the sale and reinvestment would be in lower-yield assets with insufficient interest payments to support policies. This shortfall highlights the ongoing need for the gains to support the policy block rather than, say, be paid off as a dividend. To align the balance sheet with the economic reality, IMR defers interest rate-related gains from fixed-income asset sales and requires them to be amortized through income over their remaining life. Without the IMR offset (i.e., through the deferral of the gains), the surplus would inappropriately portray a false representation of financial strength.

Similarly, fixed-income portfolio sales in rising interest rate environments could result in a misleading reduction of surplus. The economics mirror those above, with the company reinvesting in higher-yielding assets with interest payments that exceed those needed to support policies that directionally offset the realized loss. The NAIC only recently adopted admittance of negative IMR as an asset in surplus and capital, with qualifications on an interim basis; amortized negative IMR had already been incorporated into earnings. Prior to allowing for admittance of IMR offset (i.e., through the deferral of the losses), the surplus was inappropriately showing decreased financial strength, which was increasingly constrained in the context of the recent dramatic rise in interest rates. The perverse incentives had insurers focus on managing statutory financial outcomes, limiting fixed-income transactions, and deviating from long-standing investment practices, including prudent asset-liability management (ALM) and risk management behaviors related to portfolio rebalancing. This seemingly obscure piece of accounting is impacting a broad set of investment strategies and business models, including the likes of pension risk transfer (PRT).

Life insurers' balance sheets in the United States are robust, and solvency is not under question, with insurance policies experiencing directionally equivalent movements in valuation as fixed-income assets. Nevertheless, the stakes are high, with life insurers facing close to an estimated $700 billion of unrealized losses on fixed-income investments reported on Schedule D alone, coupled with our empirical analysis of insurers’ fixed-income trading activity that suggests qualifications for admittance possibility resulting in life insurers facing continued constraints with managing their fixed income portfolios prudently.  Acknowledging the need for a more thoughtful long-term solution, an ad hoc group is likely to be formed to explore long-term solutions reflecting the 2025 sunset of the temporary guidelines.

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The rate of change to the regulatory landscape governing US insurance investments is only accelerating, with broad implications for investment strategy. This report explores developments from the National Association of Insurance Commissioners (NAIC) 2023 Summer National Meeting with possible changes to the treatment of investments. Several initiatives have the potential to result in far-reaching implications for insurers’ investment strategies and capital markets:
• Classification of investment vehicles, including bonds and residual interest of structured products.
• Revisions to the definition and oversight of ratings-based designations.
• Revisions to the capital framework to potentially differentiate Collateral Loan Obligations (CLOs) and structured assets more broadly.
In addition, the investment community closely watched the Financial (E) Committee (E-Committee) meeting to deliberate on its memo that proposes a holistic framework for investment guidelines. The memo could lead to significant implications for the path and outcome of how investment guidelines will be revised. While potential long-term implications are noteworthy, the E-Committee Chair clarified that they "do plan to hear from all interested parties as we finalize this document, but we do not plan to stop any of the work that is currently ongoing," citing three current initiatives (i.e., those related to CLO model-based designations, differentiation of C-1 capital for structured assets, and SVO discretion over designations). However, it was noted that these are deliberative processes that will continue with no commitment to adoption in their current form.
This report reviews recent developments with efforts to revise NAIC investment guidelines, their potential implications for investment strategy, and what might happen next.


What’s next for the rules that govern insurers’ investments: An update from the 2023 NAIC Summer National Meeting


The NAIC Summer National Meeting is having the investment community focused on the announcement by regulators for an evaluation of the overall framework that governs insurers’ investments. Noticeable shifts in the investment strategies toward private assets, along with structured and complex assets, had the NAIC embark on significant multi-year updates to the RBC and STAT frameworks ranging from asset classification (i.e., proposed definitions for bonds and residual interests), designations (e.g., proposed definition), cashflow testing (AG 53) to capital assignment (e.g., CLOs and ABS).  Join Chair of the Valuation of Securities (E) Task Force and Iowa's Chief Investment Specialist Carrie Mears and Bridgeway Analytics' Amnon Levy on Stewart Foley's August 23 live webinar (register here). The three will unpack developments from the 2023 NAIC Summer National Meeting and provide insights into potential implications of the changing landscape that governs insurers’ investments, including: 

  • Designations, and the use of rating agencies

  • Revisions to the treatment of structured assets and investment vehicles

  • Potential implications from a proposed revision to modernize investment governance

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The changing rules governing US insurers’ investments: Capital requirements and the role of agency ratings


In response to shifting investment strategies, insurance regulators and the National Association of Insurance Commissioners (NAIC) have embarked on a multi-pronged revision to investment guidelines that will better align with the new landscape, including the following: 

  • Classification of assets, with principles-based approaches which will impact the likes of debt issued by investment vehicles and structured assets, as well as their equity and residual interests

  • Designation process which relies on agency ratings, with NAIC staff and regulators vocalizing concerns of rating agencies lacking consistent standards, notably private ratings that, by their private nature, are not subject to market oversight

  • Capital allocation across assets, with an initial focus on addressing potential capital arbitrage for structured assets and investment vehicles, and broader aspirations of aligning capital requirements across investments with their economic risks to avoid perverse incentives


With trillions of dollars in insurers' investments likely impacted, the multi-year effort will have broad implications.

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Trends in the Ownership Structure of US Insurers and the Evolving Regulatory Landscape, Q2 2023 Insurance AUM Journal 


The United States insurance regulatory landscape is experiencing broad changes in reaction to noticeable shifts in ownership structure that have resulted in changing conditions in investment markets and the financial services industry. This report explores insurance industry trends and evolving NAIC guidelines designed to support the new landscape. The report includes a review of how the new rules help address possible concerns with conflicts of interest associated with forms of ownership and control. 

About the Authors

Amnon Levy founded Bridgeway Analytics which supports the investment and regulatory community in navigating complex capital markets. Amnon has led the development of award-winning quantitative solutions actively used by 200+ financial institutions and their regulators, including 2021 redesigned NAIC C1 bond factors.


Bill Poutsiaka is a senior financial services executive with considerable experience and accomplishments, including successful strategic and operational transformation as CEO, Chief Investment Officer, and board member for global insurance and asset management businesses.


Scott White is the Virginia Commissioner of Insurance and Secretary-Treasurer of the National Association of Insurance Commissioners (NAIC).  He is also a member of the International Association of Insurance Supervisors (IAIS) Macroprudential Committee. He served as Chair of the NAIC’s Financial Condition (E) Committee from 2020-2022.

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Efforts to Reform NAIC Investment Guidelines: Lessons Learned from History

Shifts in insurers’ investment strategy over the last decade have motivated state regulators to embark on broad reforms to govern the new landscape better. Given the scope of change, possible unintended consequences are top of mind. Our latest report explores the lessons learned from past revisions to guidelines and unintended consequences for investment strategy and capital markets more broadly. Importantly, we relate those lessons to current efforts to revise guidelines, including:

  • Proposals related to designations and limiting the use of agency ratings

  • The proposed interim increase in capital to 45% for residual tranches of structured assets


We do this through two case studies:

  • The 2009 Mortgage-Backed Securities (MBS) reform introduced model-based designations to replace agency ratings. The change was partly to provide capital relief for insurers holding MBS tranches that were downgraded due to deteriorated real estate values that came with the Great Financial Crisis (GFC). However, the change also incentivized insurers to hold on to and invest in new sub-investment grade MBS. In their study, Regulatory Forbearance in the U.S. Insurance Industry: The Effects of Removing Capital Requirements for an Asset Class, Becker, Opp and Saidi, show that by 2015, insurers’ sub-investment grade MBS comprised over one-third of their overall MBS holdings, dwarfing the 5% observed for other asset classes (figure 1 from their study reproduced)

  • The so-called C1 bond factor cliff associated with the punitive pre-2021 NAIC 3 designation, is roughly equivalent to the S&P BB credit rating. In a separate study, Regulatory Pressure and Fire Sales in the Corporate Bond Market, Ellul, Jotikasthira, and Lundblad explore patterns related to insurers selling bonds when downgraded below investment grade. With insurers being the most significant single bond market participant, often holding one-third of all outstanding investment-grade corporate bonds, the collective divesting of downgraded issues resulted in a ‘fire sale’ with transaction prices deviating from fundamental values by a substantial median of 11%. Unfortunately, insurance companies that faced capital structure constraints were more likely to sell downgraded bonds, putting further strain on their solvency.

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