September 2026

A rating is not the finish line for insurance-oriented private credit structures. Increasingly, it is the beginning.

In FFP’s latest perspective, Managing Director and Co-Founder Richard Wheelahan III examines two developments from the NAIC’s 2026 Summer National Meeting that private credit managers should be watching: the evolving RBC governance framework and a proposal addressing embedded asset-liability management risk within the principles-based bond definition.

Together, they reinforce a broader point: insurance investors do not evaluate rated note funds in isolation. They evaluate them within the context of their own capital, accounting, asset-liability management, liquidity, ratings and regulatory constraints.

For managers seeking scalable, durable insurance capital, the analysis therefore needs to go beyond achieving a rating and calculating the current RBC charge. It also means understanding how a structure performs as collateral, ratings methodologies, regulatory treatment and investor-specific constraints evolve.

The article explores why scenario analysis, structural flexibility and a deeper understanding of insurer-specific balance sheet considerations are becoming increasingly important for managers accessing insurance capital.

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