The Point
Pinpoint Submits Comment Letters to NAIC on Capital Rules, Rating Agencies, and Process
Pinpoint's three new comment letters ask NAIC groups weighing capital rules, rating agency oversight, and asset-backed securities to show the evidence first.
Pinpoint Policy Institute recently submitted three public comment letters to working groups and committees of the National Association of Insurance Commissioners (NAIC), which play key roles in shaping insurance regulation. Each one makes the general ask: show the evidence, follow a fair process, and hold regulators accountable prior to changing the rules.
Risk-Based Capital Model Governance (EX) Task Force
The Task Force is considering a new commissioner-level body to set the agenda for insurer capital rules. Pinpoint urged it to hold off until the proposal includes binding evidence requirements, open meetings, and conflict-of-interest safeguards, including for its outside consultant.
Credit Rating Provider (E) Working Group
The due diligence framework would let the NAIC scrutinize rating agency methodologies. Pinpoint argued this raises federal law concerns and risks the NAIC picking winners and losers among rating agencies. We asked for an independent legal analysis and a cost-benefit review before adoption.Risk-Based Capital Investment Risk and Evaluation (E) Working Group
The Working Group is weighing which asset-backed securities to review for higher capital charges, but the staff summary measures size, not risk. Pinpoint asked it to select no category until it shows that current charges fall short and that capital rules are the right tool.