Highlights:
The National Association of Insurance Commissioners (NAIC) generated $91.8 million in revenue last year through a single affiliate alone. Most Americans have never heard of it.
The NAIC presents itself as a cooperative of state insurance regulators – a behind-the-scenes body that helps states share best practices and harmonize rules. But as Pinpoint has documented, that description hasn’t been accurate for decades. What the NAIC actually is today is a Delaware-chartered corporation with no public accountability, no congressional oversight, and no obligation to file basic financial disclosures required of virtually every other tax-exempt organization in America.
NAIC runs this as a business. It owns a set of proprietary platforms that collect tens of millions of dollars in mandatory fees, all from the industry it regulates. State law often requires insurers and producers to use these platforms to do business. That turns state insurance commissioners into a captive sales force for a private corporation’s products.
Here is what’s inside the machine.
The crown jewel of the NAIC’s commercial empire is the National Insurance Producer Registry (NIPR). Nominally structured as an independent 501(c)(6) organization, NIPR provides the credentialing and licensing infrastructure for insurance professionals.
A 2025 audit of the NIPR revealed a staggering $91.8 million in total revenue. But NIPR is far from independent. The NAIC’s own CEO sits on its board, combining with NAIC members to form a majority, and the NAIC is NIPR’s sole member.
Because NAIC member regulators mandate NIPR’s use, everyone from large insurers to individual agents and “mom and pop” small businesses are forced to pay transaction fees into the system. The NAIC then takes a massive 38% cut of NIPR’s gross revenue, over $30 million a year, as a highly questionable “license fee” for data that arguably doesn’t even belong to the NAIC in the first place. When NIPR board members previously attempted to question this arrangement, they were reportedly muscled by the NAIC into not only keeping the fee but substantially increasing the percentage in subsequent contracts. In total, NIPR funneled $34.7 million back to the NAIC in 2025 in related-party transactions.
Worse, because states force businesses to use the platform, oversight is incredibly lax. A New Hampshire state audit discovered that NIPR had “inappropriately collected” roughly $151,000 from over 6,000 transactions that were rejected or failed to process, part of a massive $378,000 reconciliation discrepancy the state hadn’t even noticed.
While NIPR handles producers, the System for Electronic Rates & Forms Filing (SERFF) handles the products. Built and completely controlled by the NAIC, SERFF is the platform insurers use to submit rates and forms to state regulators.
SERFF operates less like a service and more like a mandatory toll booth. 35 states currently require insurers to use SERFF for their filings, often by regulatory fiat or bulletin rather than actual legislative statute. The industry has no choice but to use the NAIC’s proprietary system, and pay the NAIC for the privilege.
Because it operates a captive market, the NAIC sets fees entirely by its own discretion. In 2001, SERFF transactions cost $7. By 2026, the NAIC pushed through an increase to $21 per transaction. When industry members on the SERFF board (including former Amica General Counsel Bob Suglia) attempted to exercise actual governance and oversight over the system in 2013, the NAIC simply disbanded the board and replaced it with a toothless advisory committee.
This reliance comes with severe risks. In June 2026, the NAIC experienced a massive ransomware attack that reached their systems, compromised sensitive data across multiple platforms – including SERFF.
NAIC also operates State Based Systems (SBS), a back-office regulatory software platform, and OPTins, a platform for premium taxes. Together, they generated over $8 million in transaction fees in 2024.
The procurement of these systems by state governments is riddled with red flags. SBS secures no-bid contracts from states, raising serious concerns regarding state gift ban laws. Even more concerning, the NAIC claims its executive committee members owe a fiduciary duty to the NAIC. When a state commissioner who serves on that committee signs a state contract for SBS, they owe a fiduciary duty to both sides of the transaction. It is perhaps unsurprising that SBS was previously sued by private commercial vendor Aithent for predatory practices.
Moreover, independent state audits reveal this technology often simply doesn’t work:
Individually, each platform may have been developed as ordinary software solutions, with good intentions. But together, they have become a business model for a private company, paid by everyone else.
But states are not powerless to change this. Since 1998, Michigan has stood alone in requiring the NAIC to report directly to its legislature. And model legislation exists to provide a ready-made legislative roadmap for other states to force the NAIC to open its books and answer to elected lawmakers.
The industry and consumers who ultimately bear the cost of these fees deserve to know exactly where their money is going, and why an unelected NGO is allowed to operate a multi-million-dollar toll booth on the American economy with zero oversight.
The NAIC maintained the deference of a government regulator and the freedom of a private monopoly – but faces no level of accountability that either should have.
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