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Pinpoint Policy Institute submits comment letter on the Financial Condition (E) Committee’s 2027 Proposed Charges calls for an evidentiary standard, enforcement review, and process safeguards.
This week, Pinpoint Policy Institute submitted a comment letter (available here) to the National Association of Insurance Commissioners (NAIC) Financial Condition (E) Committee on its 2027 Proposed Charges, urging the Committee to require evidence, enforcement, and accountability before new capital and investment workstreams proceed.
The Charges set the agenda for the groups that determine insurer capital requirements and how private credit and affiliated investments are treated. As drafted, they would extend a multi-year expansion of regulation without requiring the NAIC to identify a documented problem, show that existing authority is inadequate, or measure what new rules cost policyholders.
“Pinpoint is not asking the Committee to stop regulating,” said Eric Ventimiglia, Executive Director of Pinpoint Policy Institute. “Each new requirement that NAIC proposes in the 2027 Charges should be supported by evidence, enforced before it is expanded, and be worth the cost to the people who ultimately pay for it.”
Pinpoint’s letter recommends ten amendments, including published problem statements, a public cost-benefit analysis, aggregate reporting on permitted practices, published results from existing tools, and written responses to public comments.
Read the full comment letter here.
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