Comment Letter: NAIC CLO Reporting Proposal 2025-22-IRE

LSTA and the Alternative Credit Counsel (ACC) submitted comments to the NAIC's RBC IRE Working Group supporting adding a separate CLO column to Form LR002, the risk-based capital filing life insurers use to report long-term bond holdings, but argue the new treatment should apply only to BSL CLOs. They ask that middle market (MM) CLOs remain under existing corporate bond C-1 factors until the Academy develops a MM CLO model.​​​​​​​​​​​​​​​​