US insurance regulators are examining whether residential mortgage loans held indirectly through Delaware Statutory Trusts (DSTs) receive capital treatment and disclosure scrutiny that adequately reflect their underlying risks.
The National Association of Insurance Commissioners (NAIC) first flagged the issue in February 2026, and the question has stayed open through three national meetings since, with the next realistic decision point now set for November.
Now, there is a targeted NAIC proposal to redefine residential mortgage loans for risk-based capital purposes, which has been triggered by this regulatory concern over trust structures, and its public comment period closed on 2 October 2026.
The next step is working-group review, likely surfacing at November's Fall National Meeting, making early October the moment this moves from discussion towards a concrete capital rule.
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