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This weekend, Pinpoint Executive Director Eric Ventimiglia published the following letter to the editor in The Wall Street Journal:
“The National Association of Insurance Commissioners has become a shadow regulator answerable to no one. The accountability problem runs deeper than the issue of transparency; it extends to NAIC’s active reach for powers Congress never granted it.” – Eric Ventimiglia, Executive Director, Pinpoint Policy Institute
Read the full letter to the editor below:
Eric Ventimiglia: America’s Unaccountable Insurance Regulator
The Wall Street Journal
Eric Ventimiglia
September 4, 2026
Patrick M. Brenner is right: The National Association of Insurance Commissioners has become a shadow regulator answerable to no one (“How Did a Nonprofit Become America’s Insurance Regulator?,” Cross Country, Aug. 29). The accountability problem runs deeper than the issue of transparency; it extends to NAIC’s active reach for powers Congress never granted it.
I recently testified before a working group at NAIC’s summer meeting in Columbus, Ohio. The group is developing a framework to evaluate credit-rating providers, which insurers rely on to determine regulatory capital requirements. The stated goal is reasonable: Make sure insurers aren’t hiding high-risk assets behind inflated grades.
In practice, however, the framework would allow NAIC to de-admit credit-rating providers or remove entire asset classes from regulatory use without defining its own triggering standards. Terms like “reasonable,” “material,” “equivalent” and “systematic disagreement” appear throughout the document with no definitions attached. A framework that fails to define standards yet carries severe consequences for violating them gives NAIC unchecked discretion.
There is also a glaring jurisdictional problem. Oversight of nationally recognized statistical rating organizations is a federal function reserved to the Securities and Exchange Commission under the Credit Rating Agency Reform Act of 2006. NAIC’s proposal would effectively evaluate rating methodologies, allowing the nonprofit to overstep its authority. Further, NAIC is demanding expansive new submissions of proprietary data, despite a recent cybersecurity breach of its own systems that exposed some 260,000 regulatory filings.
Mr. Brenner is right to question how a nonprofit became America’s insurance regulator. In Columbus, I saw firsthand how this private organization moves to absorb federal authority it was never given.
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