【德勤Deloitte】2025年美国保险业监管展望报告_34页_8mb

2025 Insurance Regulatory Outlook Summary

Core Content

The Deloitte Center for Regulatory Strategy provides a comprehensive outlook on the regulatory landscape for the insurance industry in 2025, emphasizing the need for agility, collaboration, and vigilance in the face of evolving challenges. The report outlines key areas where regulatory focus is expected to intensify, including data management, solvency oversight, customer-centric regulation, and climate change risk.

Main Points

• Increased Regulatory Scrutiny: State and federal regulators will maintain a heightened focus on insurance industry responses to domestic, geopolitical, and market challenges, especially in areas like cybersecurity, AI, and climate risk.
• Political Shifts: The new Trump administration may reduce federal regulatory enforcement and new rulemaking, but will likely continue to monitor issues such as homeowners insurance costs, cybersecurity, AI innovation, and national security concerns.
• State-Level Regulation: With the McCarran-Ferguson Act allowing state regulation, states are expected to assert their role in consumer protection, particularly in annuity sales, disclosures, and claims oversight. States like California, New York, Washington, Oregon, Connecticut, and Colorado are likely to lead regulatory innovation.
• AI Oversight: The NAIC is developing a framework for AI use in insurance, with a focus on consumer outcomes and third-party model governance. States may begin market conduct inquiries and enforce AI-related rules, with New York, Colorado, and Connecticut being more proactive.
• Cybersecurity: Cybersecurity remains a top priority, with New York enforcing stringent regulations under 23 NYCRR 500. The NAIC is also working on a cybersecurity event portal to improve notification processes and coordination.
• Solvency and Risk Management: The NAIC is focused on enhancing solvency oversight, particularly for complex investments like structured securities and private equity-owned insurers. A new actuarial guideline for asset adequacy testing is expected to be implemented by year-end 2025.
• International Standards: The Insurance Capital Standard (ICS) is set for implementation, with the US adopting the Aggregation Method (AM) as its preferred approach. This will require alignment with global standards and increased collaboration between US and international regulators.

Key Regulatory Areas

1. Managing Data Amid Innovation and Threats

• AI and Third-Party Models: The NAIC is developing a framework for AI use and third-party data governance. States may require testing for AI bias and establish robust governance structures.
• Enforcement Focus: Regulators will scrutinize AI outcomes and third-party model usage, with some states like Colorado extending deadlines for compliance.
• Regulatory Tools: The NAIC is working on new tools and guidance for evaluating AI systems and developing enforcement mechanisms.

2. Safeguarding and Improving Solvency

• Credit Risk and Investment Oversight: The NAIC is enhancing oversight of complex investments, including structured securities and private equity holdings. A new governance structure for due diligence and credit rating analysis is in development.
• Risk-Based Capital (RBC): Increased RBC charges for collateralized loan obligations (CLOs) are expected in 2025, with potential for more prescriptive rules by 2026.
• Offshore Reinsurance: Concerns over offshore reinsurance and reserve adequacy will continue, with states and the NAIC focusing on transparency and risk assessment.

3. Customer-Centric Regulation

• Consumer Protection: States will likely strengthen consumer protection measures, especially in areas like annuity sales and claims oversight.
• Populist Responses: Insurance costs and market disruption are expected to continue driving populist policy responses, particularly in states where insurance is a critical part of the economy.
• State Collaboration: The NAIC will continue to play a central role in shaping regulatory frameworks, incorporating state-level innovations and promoting a holistic solvency approach.

4. Climate Change Risk and Resilience

• Weather-Related Catastrophes: States will monitor the impact of extreme weather events on homeowners insurance markets, with the FIO and CISA working together to address catastrophic cyber risk.
• Regulatory Innovation: States may introduce new guidelines to address climate-related risks and improve market resilience, with New York and others leading the way in regulatory action.

Federal and State Collaboration

• Federal Agencies: The FIO and FSOC will continue to monitor financial stability and cybersecurity risks, particularly in the context of national security and market interconnectivity.
• NAIC's Role: The NAIC is central to shaping regulatory frameworks, with ongoing efforts to develop a unified solvency model and AI oversight guidelines.
• International Standards: The ICS will be implemented, with the US using the AM approach. This will require alignment with global standards and increased collaboration with international regulators.

Recommendations for Insurers

• Proactive Engagement: Insurers should engage with regulators, lawmakers, and industry groups to shape effective policies and avoid overbroad legislation.
• Compliance and Transparency: Insurers must demonstrate transparency in their AI and data governance practices, as well as in their investment and capital management strategies.
• Adaptation and Innovation: Continuous adaptation to regulatory changes, technological advancements, and market dynamics is essential for long-term stability and growth.
• Cybersecurity Preparedness: Firms should conduct thorough cybersecurity risk assessments and update their disaster response and business continuity plans, especially for New York and other states with stringent requirements.

Conclusion

The insurance industry faces a complex and evolving regulatory environment in 2025, marked by increased state-level oversight, federal interest in national security and market stability, and the implementation of international standards. Insurers must remain agile, engaged, and prepared to adapt to these changes while ensuring compliance, transparency, and consumer protection.