SS&C flags new CLO capital requirements for insurers taking effect at year-end 2026
SSNC•Insurers face new collateralized loan obligation capital requirements and expanded private placement disclosures at year-end 2026 under NAIC reforms, including an 11.77% surcharge for certain CLO tranches.
1. Insurance rule changes
Under NAIC reforms taking effect at year-end 2026, an 11.77% surcharge applies to broadly syndicated loan CLO tranches rated NAIC 2.C or below with tranche thickness of at most 4%. Private placement disclosures must identify SEC registration status, and expanded notes must cover valuations, deferred and payment-in-kind interest, and private letter ratings. From January 1, 2027, residential mortgage loans in qualifying statutory trusts receive directly owned mortgage treatment, with early adoption permitted.
