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DISB urges quick adoption of Holding Company Systems amendments to meet NAIC accreditation
Summary
Philip Barlow of the District's Department of Insurance, Securities and Banking told the Committee the Holding Company Systems Amendment Act updates group capital calculations, requires liquidity stress testing and adds receivership authority to align with NAIC accreditation that becomes effective Jan. 1, 2026.
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Philip Barlow, Associate Commissioner for Insurance at the District’s Department of Insurance, Securities and Banking, told the Council’s Committee on Business and Economic Development that Bill 20-646 would incorporate recent NAIC accreditation requirements and give regulators new tools for group-wide supervision. "The group capital calculation provides U.S. solvency regulators with an additional analytical tool for conducting group wide supervision and assists regulators in understanding the financial condition of non insurance entities within a group," Barlow said. He also described a liquidity stress test and receivership provisions that would allow the Commissioner to oversee essential affiliate services if an insurer is placed into receivership.
Committee members pressed DISB on whether the District had diverged from the NAIC model. Barlow said the bill is "substantially consistent" with actions other states have taken and noted the District currently has no domestic insurers doing business in the U.K. or E.U., so some cross‑border risks are not immediate. He told the Committee the Department has identified implementation steps and does not believe emergency legislation is required if there is visible legislative movement before the accreditation deadline.
