Regulatory Update: National Association of Insurance Commissioners Fall 2025 National Meeting

The National Association of Insurance Commissioners (NAIC) held its Fall 2025 National Meeting (Fall Meeting) December 8–11, 2025. This blog summarizes the highlights from this meeting in addition to interim meetings held in lieu of taking place during the Fall Meeting. Highlights include evaluation of insurers’ use of funding-agreement-backed note (FABN) and funding-agreement-backed securities (FABS) programs, adoption of guidance regarding the risk transfer analysis for combination reinsurance contracts, discussion of a new committee structure for NAIC investment monitoring activities, and consideration of additional regulatory frameworks to address insurers’ use of artificial intelligence (AI).