SFA Submits Response to NAIC on SVO’s Discretion Over NAIC Designations
On January 26, 2024, the Structured Finance Association (SFA) submitted a comment letter to the National Association of Insurance Commissioners (NAIC) in response to their exposure draft titled Amendment to the Purposes and Procedures Manual of the NAIC Investment Analysis Office (the “P&P Manual”) Authorizing the Procedures for the SVO’s Discretion Over NAIC Designations Assigned Through the Filing Exemption Process.
SFA’s comment letter requests that the NAIC do the following:
- Narrow the scope of the application of SVO discretion, including the characteristics of the securities which are likely to be the focus of rating reviews.
- Amend its discretion procedures to provide insurance company investors the option to engage directly with the Senior Credit Committee and VOSTF in the rating review process, allowing for a more productive, collaborative and cost-effective process.
- Answer questions about the discretion process, including the basis upon which the IAO will make a determination that the NAIC designation equivalent of a CRP rating is not a “reasonable assessment of risk for regulatory purposes,” and how the three-notch materiality threshold was derived, among others.
- Provide clarity on proposed “neutral third parties,” detailing about the responsibilities, and function of this role .
Related
SFCanada 2024
May 2024SFVegas 2025 Sponsorship Opportunities
May 2024SFA Responds to NAIC’s Written Comments on Holistic Framework on Insurers Investments
April 2024SFA Government Relations Webinar: A View from Capitol Hill: Policy/Political Catch All
April 2024SEC Exempts Structured Products from Final Climate Risk Disclosure Rule
April 2024