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17 September 2026

The CLO Chronicles — NAIC’s New Life RBC Factors Cross The Finish Line (Podcast)

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The NAIC has spent four years overhauling capital requirements for life insurance companies' investments in collateralized loan obligations, introducing dramatic changes that will reshape how insurers allocate capital across their investment portfolios. These new rules, which account for credit spectrum positioning and tranche thickness for the first time, will force insurers to model significant impacts before year-end 2026 implementation.
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For the past four years, the NAIC has been rethinking how much capital life insurance companies should hold against their investments in collateralized loan obligations (CLOs) — essentially, packages of corporate loans that insurers have increasingly turned to for higher returns. In a new episode of Financial Services Focus, partners Lauren Pryor and Larry Hamilton walk through the biggest changes to hit insurance company investment portfolios in years, and explain why the ripple effects will reach well beyond CLOs.

As you move down the credit spectrum, charges rise sharply, in some cases more than doubling. For the first time, the rules account for "tranche thickness": thinner, lower-rated tranches now carry dramatically higher capital charges because they're more vulnerable to sudden losses. These new factors take effect for year-end 2026 calculations, meaning insurers need to be modeling the impact now. Perhaps the most consequential development discussed in this episode isn't a rate table at all. Listen to the newest episode now.

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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