Pinpoint Submits Comment Letter Urging NAIC to Withdraw Flawed Credit Rating Framework

This week, Pinpoint Policy Institute submitted a formal comment letter (available here) to the National Association of Insurance Commissioners (NAIC) Credit Rating Provider (E) Working Group urging the deferral and redesign of its proposed CRP Due Diligence Framework, a proposal that raises serious legal, procedural, and data security concerns.

The Framework, as currently drafted, suffers from three independent defects:

• Illegal overreach: The Framework assumes regulatory authority over credit rating methodologies that Congress expressly withheld from even the SEC under Section 15E(c)(2) of the Exchange Act. Calling it “due diligence” doesn’t change what it is.
• No accountability, no due process: The NAIC is a private, tax-exempt organization not subject to APA procedures, cost-benefit requirements, or judicial review, yet this Framework would give it unchecked power to de-admit credit rating providers and strip asset classes of filing-exempt status behind closed doors.
• Wrong time to expand data collection: The NAIC suffered a cybersecurity breach on June 11, 2026 and failed to disclose it for six days, despite imposing a 72-hour notification standard on the very insurers it regulates. Expanding confidential data transfers now is not prudent policy.

As Pinpoint’s letter states:

“Our comments focus on the substance of the Credit Rating Provider (“CRP”) Due Diligence Framework Whitepaper (“Framework Whitepaper,” “Framework,” or “Whitepaper”) and on several underexamined consequences for the insurance marketplace, capital formation and capital markets, and the broader financial system. Our concern, as outlined in this letter, is that the proposed Framework appears to move beyond oversight of rating use in the NAIC designation process and toward de facto oversight of CRPs and rating methodologies, security-level rating judgments, and other NAIC actions that could materially affect insurance companies and policyholders.”

Pinpoint urges the Working Group to pause, conduct proper legal and economic analysis, and re-expose a revised Framework for public comment.

Read the full comment letter here.

More from Pinpoint:

• Is NAIC a Leaking Ship?
• ICYMI: NAIC Regulators Field Complaints About Transparency, Closed Meetings
• What You Need to Know About the NAIC
• Holding the NAIC Accountable
• A Regulatory Trojan Horse
• The NAIC is Eager to Boost Federal Incentives While Dismissing Economic Stability