NAIC Heads Back to the Lab on Annuity Suitability

After the National Association of Insurance Commissioners’ (NAIC) Annuity Suitability (A) Working Group published its 2025 technical report, aimed at insurers, on “Annuity Best Interest Regulatory Guidance and Considerations,” the working group immediately went back into the lab to embark on a new phase of work. The report evaluated insurers’ obligations when they delegate the NAIC suitability model regulation’s supervision requirements to third parties. For 2026, however, the group will focus its work on developing materials that are primarily for regulator use, as summarized below.

Training

The working group will develop training on the Suitability in Annuity Transactions Model Regulation (Model #275) in coordination with the NAIC’s education and training team, geared toward insurance regulatory agency attorneys, investigators, and examiners. In doing so, the group is seeking input from regulators with annuity suitability examination experience to assist in developing the training materials. Commissioner Doug Ommen, chair of the Life Insurance and Annuities (A) Committee, explained that the working group will collaborate with the new Market Conduct Regulation Modernization (D) Working Group on training issues.

Resource Document

The working group will examine insurers’ suitability practices to identify methodologies and practices that insurers have implemented to effectively meet their supervisory obligations under Model #275. Because Model #275 is principlesbased and provides flexibility, the group believes that state insurance regulators, insurers, and interested parties could benefit from compiling a document outlining common best practices insurers use to comply with the model. To develop this resource document, the group exposed a “Framework of Resource Document” and is seeking “specific ‘best’ practices or procedures insurers have implemented to satisfy the supervisory obligations of Model #275.” The working group seeks to identify three categories of such practices or procedures:

• Training
• Supervision systems
• Required disclosures and conflicts of interest

The working group also requested data on insurers’ compliance challenges or confusion. The deadline for responses is May 11, 2026.

Database of Administrative Law Decisions

As a data resource for insurance regulators, the working group seeks to compile administrative decisions in a searchable format.

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