Locke Lord QuickStudy: NAIC Issues Draft White Paper on ‎Insurance Company Restructurings

Locke Lord LLP
October 22, 2021

Earlier today the NAIC Restructuring Mechanisms (E) Working Group of the Financial Condition (E) ‎Committee issued its draft NAIC White Paper on insurance company restructurings, namely ‎Insurance Business Transfers (IBT) and Corporate Divisions. Comments may be submitted by ‎November 22.‎

This White Paper is long-awaited and serves as the first step in the NAIC’s study of these ‎restructuring mechanisms with the objective of creating a framework for regulators to study and ‎hopefully implement appropriate regulatory standards. Although a few transactions have already ‎taken place — the Enstar and R&Q IBT transactions in Oklahoma and the AllState Division under ‎Illinois law, the market and regulators are still studying the results and the NAIC is still formulating its ‎advice.‎

The Working Group will continue its studies which will include taking advice from other NAIC ‎working groups on accounting and other regulatory issues.‎

A more detailed discussion of the White Paper will follow in coming days.‎

Our prior alerts on this subject include:‎