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SFA Responds to NAIC’s Written Comments on Holistic Framework on Insurers Investments

Published on May 1, 2024

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On April 5, Structured Finance Association submitted a letter in response to the NAIC’s memo from February 14, 2024, titled “Response to Written Comments on Holistic Framework on Insurers Investments”. The NAIC’s proposed updates to the Holistic Framework include a due diligence framework to evaluate credit rating providers, through an independent consultant, under the SVO’s oversight.

SFA appreciates the progress made in developing the holistic framework but raises questions for the NAIC from membership regarding the due diligence framework for credit rating providers.

Key Points:

  • SFA seeks clarity on the consultant independence criteria and technical qualifications of the independent consultant, as well as the RFP structure.
  • SFA additionally seeks clarity on the change from “equal capital for equal risk” to “equal capital for equal tail risk” as well as this change in language’s potential implications.
  • SFA advocates for industry engagement and involvement in the methodology construction for the due diligence framework and selection of the independent consultant.

Read the Response Letter