Sep 2026
The National Association of Insurance Commissioners (NAIC) held its 2026 Summer National Meeting in Columbus, Ohio, from 11-14 August, bringing together state insurance regulators, international counterparts, and industry leaders to address challenges facing consumers and insurance markets. Against the backdrop of a meeting focused on innovation and resilience, the Cayman Islands mounted a notable presence, including Conyers Partner Philippa Gilkes, and a high-level delegation led by Premier and Minister for Financial Services and Commerce, the Hon. André M. Ebanks MP. Critically, Premier Ebank’s presence supported the Cayman Islands’ long-awaited submission of a formal application to the NAIC for Qualified Jurisdiction Status (QJS), with the Premier and representatives from the Cayman Islands government and CIMA using the meeting to discuss the application directly with key government, policy, and financial services stakeholders. Premier Ebanks revealed that the application would proceed in two phases, beginning with property and casualty, where the regulatory framework is considered relatively settled. The submission of the QJS application by the Cayman Islands coincides with applications for QJS also being made by Guernsey and the Republic of Korea, to be considered in parallel by the NAIC Mutual Recognition of Jurisdictions (E) Working Group.
RBC Changes to Impact Offshore Insurance to Non-reciprocal Jurisdictions
The Summer Meeting produced significant regulatory activity relevant to the Cayman Islands insurance sector. Of greatest relevance, and concern, the NAIC’s Financial Condition (E) Committee approved a referral directing the Life Risk-Based Capital (E) Working Group to develop two changes to the life RBC formula: a new reinsurance recapture RBC factor for reserves ceded to reinsurers outside reciprocal jurisdictions, and a revised credit-risk methodology aligning the life RBC approach with the property and casualty framework. These proposals, targeted for year-end 2027 implementation, reflect regulators’ sustained focus on offshore life and annuity reinsurance. The E Committee also considered potential revisions to the Disclosure of Material Transactions Model Act (Model #285), which could expand the categories of transactions subject to regulatory reporting. For Cayman-based reinsurers, these developments are particularly consequential as the jurisdiction pursues QJS, since the new RBC factors would directly affect the capital treatment of business ceded to reinsurers outside reciprocal jurisdictions, with QJS alone not providing a safe harbour.
Stakeholders in the Cayman Islands insurance and reinsurance sector are encouraged to make submissions to the relevant NAIC Committees during the consultation process to respond to the proposed RBC changes and support the QJS application process as these developments unfold.
Private Credit Focus Continues
Private credit also featured prominently on the agenda. The Financial Stability (E) Task Force released a Macroprudential Risk Dashboard Summary report which acknowledged that private equity owned insurers continue to invest heavily in structured securities, private credit, and other non-traditional insurance assets and that private credit appears to be a significant risk for the insurance industry. The Financial Stability (E) Task Force also announced that it had held individual discussions with reinsurers in recent months which candidly uncovered that in all but the most severe stresses there would be no impact on the reinsurer’s rating. In the case of the most severe stresses (which is considered to be very unlikely) around 50% would experience moderate stress. Notwithstanding, Cayman-based reinsurers engaged in asset-intensive life and annuity business can expect heightened monitoring of private credit to continue both by the NAIC and the Cayman Islands Monetary Authority as best practices for managing risks associated with private credit exposure continue to be developed.
The NAIC Fall National Meeting will be held in Dallas, TX, from 14-17 November 2026, with another strong Cayman contingent expected as these developments impacting the jurisdiction continue to be advanced.