By Amanda Barry-Moilanen
Policy Project Manager, Life
The Academy’s Life Practice Council (LPC) has identified 2026 public policy priorities that capture pressing and actionable policy trends and issues impacting life actuaries in the United States. Those priorities span a wide range of elements in their work, ranging from valuation to investments and products, and specific regulatory considerations across them. The LPC will be leading work on:
- Investments, complex assets, and risk-based capital developments.
- The VM-22 principle-based reserving (PBR) framework and C3P1 Capital for Non-Variable Annuities.
- Actuarial Guideline (AG) 55 asset adequacy testing for cross-border reinsurance.
- Underwriting and risk selection.
- Economic scenario generators and the National Association of Insurance Commissioners’ Generator of Economic Scenarios (GOES) project.
- Illustrations.
In 2026, the LPC will continue to monitor and provide input on developments related to complex assets, and the C1 Subcommittee will continue its work on the collateralized loan obligation (CLO) comparable attribute research project. This project was created in response to a request from the NAIC’s Risk-Based Capital Investment Risk and Evaluation (E) Working Group in 2023. Over the last couple of years, the LPC had ramped up its engagement on issues surrounding modeling complex assets, both by educating practicing actuaries about them and by responding to regulatory initiatives attempting to provide structure to life insurance investing. A great example of this is the work around AG 53, which deals with the incorporation of complex assets in asset adequacy testing.
It is clear that complex assets and other investment-related topics remain a hot topic in 2026, and will be among the leading topics at the Academy’s second annual Insurance Investment Summit that our Life Investment Analysis Subcommittee has planned for May 12-13. Registration is open for this event that offers insights and interaction with leading voices from the actuarial, regulatory, and insurance world across the life, health, and property/casualty lines of business. New to the event this year are optional pre-summit sessions that focus on key issues in asset management.
The LPC continues to engage with the NAIC on non-variable annuities, on the reserving side, on the implementation of VM-22 and capital side, and in terms of C3 Phase 1 alignment. With VM-22—the section of the valuation manual that deals with non-variable annuities—effective as of Jan. 1, the LPC’s Annuity Reserve and Capital Subcommittee will continue to offer education to regulators and practitioners, as well as monitor additional policy issues that arise after implementation.
Another key priority in the new year is monitoring the implementation of AG 55, which attempts to improve reserve adequacy requirements for life insurance companies entering cross-border reinsurance transactions. The AG was effective for year-end 2025 and the LPC plans to release a policy paper for practitioners to help with the transition. The LPC will also continue to monitor and comment on other cross-border reinsurance issues as they arise.
The LPC continues to prioritize underwriting and risk selection in 2026. Specifically, the Life Underwriting and Risk Classification Subcommittee will continue to respond to developing regulations related to the potential for algorithmic bias and unfair discrimination in data and predictive models used for underwriting and risk selection by life actuaries. The subcommittee hosted a webinar on its Governance Checklist, Related to Testing Life Insurance Underwriting for Unfairly Discriminatory Practices on Jan. 13, discussing governance considerations for practitioners focused on underwriting. Similarly, the LPC continues to prioritize the NAIC’s Life Actuarial (A) Task Force’s (LATF) implementation of GOES. The new generator also became effective Jan. 1, so the Economic Scenario Generator Subcommittee intends to offer education to practitioners by way of several webinars while continuing to monitor any “day two issues” (e.g., governance, validation).
Lastly, toward the end of 2025, there was some activity from LATF and the NAIC Life and Annuity Illustration (A) Subgroup on AG 49-A, which deals with illustrations for indexed universal life (IUL) products. The LPC anticipates additional activity related to potential changes to requirements around life and annuity illustrations in 2026, and the Life Illustrations Subcommittee is well-positioned to respond to any further developments.
Ultimately, the LPC has a robust list of priorities for the coming year that will leverage the expansive expertise housed within the practice council. The LPC is well-positioned to respond to regulatory initiatives in any of the policy areas listed and continues to prioritize providing sound educational resources to practitioners. If you are interested in learning more, or to volunteer with one of the LPC’s committees, please reach out to us for more information!