On Dec. 9, North Dakota Insurance Commissioner and National Association of Insurance Commissioners (NAIC) President Jon Godfread delivered the keynote address at the NAIC 2025 Fall National Meeting.

As he prepares to conclude his year-long term as NAIC president, Commissioner Godfread highlighted regulatory progress under the NAIC’s 2025 “Securing Tomorrow: Advancing State-Based Regulation” roadmap and other advancements made in 2025.

He also noted the state-based model “that has protected Americans for more than 150 years” will continue leading through innovation in an evolving insurance landscape.

“State insurance regulators are not reacting to change,” said Commissioner Godfread. “We are driving it.”

You can find Commissioner Godfread’s remarks, as prepared for delivery, below:

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Let me begin by thanking Commissioner Yaworsky and [Chief Financial Officer] Ingoglia for welcoming us to this great state — a leader in resilience and an exceptional host for our Fall National Meeting. And truly… this is the perfect time of year to be in Florida. Sunshine, warm weather, palm trees—if you’re complaining, you’re doing it wrong.

I hope you’re enjoying the holiday season and getting at least a moment of rest—preferably after surviving this national meeting—before we move into what will be a very full 2026.

Now, before we go further…

Yes, I know exactly what you’re all thinking.

Will this meeting be disrupted?

Will someone storm the stage?

Should we all map the nearest exit or the nearest security guard?

At our last national meeting, I barely got through my warm-up remarks before a group of uninvited guests made their surprise debut.

It was not on the agenda. But in NAIC history, it certainly was memorable.

I’m proud of how quickly everyone responded. Security acted, the room regrouped, and we carried on. Rest assured, we’ve improved protocols. You may notice a few updates, but nothing too disruptive.

But in all seriousness, that moment revealed something important: People are paying attention.

For decades, activist groups barely knew that we existed. Now they show up with coordinated chants and matching t-shirts.

I’m not saying that’s how you know you’ve made it… but it’s definitely a sign.

More importantly, it underscores a truth that we all recognize: Our work is rising in visibility, urgency, and impact.

And that is because of you: your leadership, your expertise, your commitment to protecting consumers and strengthening markets. It’s why 2025 has been such a remarkable year for the NAIC.

Every day, state regulators shoulder the responsibility of ensuring affordability, stability, and trust in the insurance system. And you do it with integrity, expertise, and an unwavering commitment to service.

We are here today because of the strength of our people—and the strength of a state-based system that empowers those people to lead.

Earlier this year, we adopted our strategic roadmap, “Securing Tomorrow: Advancing State-Based Regulation,” to meet the moment boldly.

It wasn’t just a plan.

It was a promise. A promise to adapt, to prepare, and to grow.

We knew that securing tomorrow meant more than keeping pace with change. It meant shaping it.

As stewards of a system that has protected consumers for more than a century, our responsibility is to ensure that it remains strong for the next one.

This year underscored that mission powerfully.

We are at a flashpoint, where natural disasters, rapid technological advances, and global economic pressures are reshaping the insurance industry in real time.

Underwriting models are being tested, AI is transforming markets, capital frameworks are evolving, and affordability pressures are intensifying.

Yet within this complexity lies one of our greatest opportunities to make a meaningful difference.

And as my tenure as NAIC president draws to a close, I can say with pride that we have made tremendous progress—together.

When I look back on this year, I’m struck by how our toughest challenges brought out our strongest, most unified responses.

Less than a month into 2025, wildfires devastated Southern California. Many of us traveled to Pasadena to see the impact firsthand.

We walked neighborhoods still rebuilding and spoke with families determined to recover. It reminded us that our work cannot only react to disaster; it must help prevent the next one.

And the California fires were just the beginning.

Wildfires swept the West.

Tornadoes struck the South and Midwest.

Floods in Texas again devastated and displaced families.

These events reinforced why the NAIC adopted the “National Climate Resilience Strategy for Insurance.”

Faster, smarter mitigation is essential. And thanks to your leadership, states are delivering.

Programs like My Safe Florida Home—and those in several other states that engaged in similar efforts—demonstrate measurable reductions in loss, improved availability, and stronger communities.

That is momentum.

That is progress.

And that is state leadership.

We also acted with urgency when the National Flood Insurance Program (NFIP) neared expiration. NAIC Members met at the White House and made it clear: Flood coverage is a lifeline, too vital to lapse.

Short-term reauthorization was secured, but uncertainty remains. Our advocacy must continue.

And beyond reauthorization, we are shaping the future of the NFIP through engagement with FEMA’s advisory committee.

These partnerships matter, because resilience is not theoretical. It protects homes, families, and futures.

But protecting the future also requires a regulatory system capable of meeting a rapidly changing marketplace.

Let me say this plainly: State insurance regulators are not reacting to change. We are driving it.

For more than a decade, we have modernized solvency oversight, strengthened models, and refined risk-based capital [RBC].

This work has been strategic, consistent, and forward-looking.

One of the clearest examples is the RBC Model Governance Task Force. Under the leadership of Commissioners Houdek and Ommen and Directors French and Wise, we improved transparency and accountability in one of the most consequential tools in global insurance.

Their work reinforces our principle: equal capital for equal risk—based on evidence.

Yet despite this progress, some commentary, mostly from outside U.S. markets, suggests state regulators are unprepared for evolving investment structures or for private credit growth.

Let me be unambiguous: That claim is wrong.

It overlooks years of refinement and misunderstands the architecture of U.S. solvency oversight. Just because evolving capital structures are new to observers does not mean they are new to us.

In 2024, we adopted the Holistic Review of Insurer Investments, a modernization plan to strengthen independence and reduce blind reliance on credit ratings.

On Jan. 1, 2026, the long-standing Valuation of Securities Task Force, more affectionately known as VOSTF, sunsets and is being replaced by the Invested Assets Task Force and new working groups that elevate our framework to its next level of maturity.

This is regulatory evolution.

This is leadership.

We welcome analysis, critique, and partnership.

But we also must defend what is true: The U.S. state-based regulatory system is robust, transparent, adaptive, and worthy of confidence.

If global counterparts want to better understand our work, our door is always open.

Attend our meetings.

Engage with our working groups.

Ask the hard questions.

Because we are proud of the system we have built—and the system we continue to modernize for tomorrow.

We are not just keeping up with the future.

We are securing it.

Our core responsibility is simple and enduring: Insurers must be able to keep their promises.

This year, NAIC Members strengthened that foundation with three coordinated actions across the life insurance sector.

Principle-based reserving [PBR] for non-variable annuities now gives regulators a clearer view of these rapidly growing products and promotes more disciplined risk management.

The new Generator of Economic Scenarios provides more realistic assumptions for both PBR and RBC, aligning our models with today’s interest-rate environment and tomorrow’s risks.

Actuarial Guideline 55 enhances disclosure when liabilities are transferred offshore or to third parties, ensuring that capital truly follows the risk.

Together, these measures materially strengthen solvency oversight across the life sector: modern, sophisticated, and responsive to emerging trends.

But solvency is only one part of a future-ready system. The way insurers assess risk, price products, and serve consumers is changing just as quickly—and nowhere faster than in the realm of artificial intelligence and use of data.

AI is transforming the insurance ecosystem: accelerating claims, improving underwriting, and enabling more tailored products.

But innovation without accountability is not progress.

When a proposed federal moratorium on AI regulation threatened to weaken protections and confuse consumers, we acted.

We removed that provision and reaffirmed that oversight belongs closest to the public. Now, that issue is resurfacing in Congress, and we stand ready to do so again.

Our H Committee and Big Data & AI Working Group continue to advance practical tools for evaluating fairness, transparency, and governance.

As AI becomes more deeply embedded, our priority is clear: Technology must enhance consumer trust, not erode it.

And the reason we can take on challenges like AI, solvency, and modernization with confidence is simple: We face them together.

None of this progress happened in isolation. Every success this year reflects the work of every department and every regulator across our 56 jurisdictions.

You modernized the models.

You strengthened the frameworks.

You supported communities.

You delivered for the consumers.

And nationally, people are noticing. Major outlets—Bloomberg, NPR, USA Today, The Washington Post, Fox Business, and others—have elevated the voices of state regulators on resilience, affordability, wildfires, and health insurance.

We are reminding the country, and the world, that state-based regulation is not only effective…

It is indispensable.

But even as we celebrate progress, we must face the pressures growing ahead:

Affordability.

Technological acceleration.

Shifting expectations.

Nowhere is the strain more visible than in health insurance.

Families across the country are opening renewal letters showing double or triple-digit premium increases. And with enhanced premium tax credits expiring in just weeks, the stakes are high.

If Congress does not act, this will not just be a headline; it will be a crisis.

But even if those subsidies are extended, we must confront the truth: Health insurance premiums rise because health care costs rise.

Not because insurers changed their business model.

Not because regulators fell asleep.

But because the cost of care—hospital systems, providers, pharmaceuticals—is growing faster than every other sector in the U.S. economy.

Blaming the insurance mechanism is not policy.

It is a distraction.

And consumers lose.

If we want affordability, we must ask the real questions:

Where is the money going?

Why is medical inflation so far outpacing the rest of the economy?

How do we control health care costs, not just premiums?

These questions are difficult, but they are necessary.

Affordability is not just economic—it is moral.

Families deserve meaningful, reliable, sustainable coverage.

This challenge also proves why the state-based system matters.

We see the pressures first.

We hear directly from consumers.

And we are prepared to bring truth, clarity, and leadership to the national conversation.

Moments like this remind us of something fundamental: Our strength comes from the model itself, a system built to stay close to consumers and responsive to reality.

The role of the NAIC is simple: to protect consumers, strengthen markets, and advance the state-based model.

Fifty-six jurisdictions, each with unique risks and perspectives, come together to build a stronger, more resilient system.

And when we collaborate, we don’t just coordinate; we elevate.

We scale what works. We fix what doesn’t and reinforce a model that has protected Americans for more than 150 years.

As the world continues to grow more complex and interconnected, that structure becomes even more essential.

Our 2025 roadmap is not an endpoint; it is the foundation for what comes next.

As we move into 2026, we are not resetting. We are advancing.

Commissioner White will guide this organization into its next chapter with a steady hand, and I am confident in his leadership and in the strength of this membership.

Together, we carry forward the momentum we built this year.

Much of the work we’ve discussed today—in property markets, solvency oversight, and technology—will continue to evolve.

We’ve laid a strong foundation, and the work ahead will build on it.

We have also made meaningful progress in our engagement with federal partners and international supervisors, strengthening the state-based perspective in national and global conversations.

That progress will continue as part of our broader commitment to a resilient and forward-looking regulatory system.

As we look ahead, one of our greatest opportunities lies in strengthening the capacity of our regulatory workforce.

In 2026, expanded training and professional development for examiners, actuaries, analysts, market conduct teams, and consumer services will deepen our expertise and reinforce the strength of our oversight.

A strong system relies on strong people, and our people remain our greatest competitive advantage.

As Commissioner White steps into his new role, I encourage each of you to support him with the same collaboration and commitment you have shown me throughout this year.

The challenges ahead are real, but so is the foundation we have built together. And with this membership, I have no doubt we are ready for what comes next.

We have accomplished a great deal this year.

Not because of any one leader or committee but because we share a mission. And we are committed to working together.

The challenges ahead will be significant.

They will be complex.

And they will be worth the effort.

We will continue proving that the state-based system is not only effective. It is essential.

It is resilient. It is strong. And it is ready for whatever comes next.

To the thousands of dedicated regulators across our 56 jurisdictions:

Thank you for your service.

Thank you for your partnership.

And thank you for your unwavering belief in this system—and in each other.

Let’s keep doing this work together.

Let’s keep leading with purpose.

Let’s keep securing tomorrow—together.

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