From tracking the convergence of alternative asset management and insurance over the past several years, one structural transformation stands above all others in its implications for actuarial practice: the systematic entry of private equity firms into the life insurance and annuity business. What began as opportunistic purchases of discounted legacy blocks during the 2008–2009 financial crisis has evolved into a permanent feature of the industry's capital structure, one that is fundamentally reshaping how insurance liabilities are funded, how investment portfolios are constructed, and how regulators approach solvency oversight.

The scale is now difficult to overstate. According to the NAIC Capital Markets Bureau's year-end 2024 analysis, 137 private equity-owned U.S. insurers held $704.3 billion in total cash and invested assets, a 16% increase from $605.7 billion at year-end 2023, and a 50% increase from the 90 PE-owned insurers identified when the NAIC began tracking in 2018. These PE-owned entities now represent 7.8% of the entire U.S. insurance industry's nearly $9 trillion in invested assets. Life insurers comprise 96% of that total, reflecting the fundamental economic logic driving the convergence: long-duration insurance liabilities generate a massive, sticky "float" that private capital managers can invest to earn spread income at scale.

Apollo Global Management's Athene subsidiary alone held $430 billion in total assets as of September 2025, while Apollo's total assets under management reached $938 billion, approaching the firm's stated target of $1.5 trillion. KKR's Global Atlantic grew to $219 billion in AUM following KKR's move to 100% ownership in January 2024. Brookfield completed its $4.3 billion acquisition of American Equity Investment Life in May 2024, pushing its insurance assets past $100 billion. And the pipeline continues: PwC's insurance M&A outlook for 2026 reported $31.8 billion in announced deals across 207 transactions in just the six months from June to November 2025, with life and annuity platforms continuing to attract strong investor interest.

This article examines the economic mechanics driving the PE-insurance convergence, the investment strategies PE-owned insurers employ, the regulatory response now taking shape through the NAIC's 13 Considerations framework and Actuarial Guideline 55, the systemic risk concerns raised by the Bank for International Settlements, and what this structural shift means for practicing actuaries in 2026 and beyond.

The Economic Logic: Why Private Capital Wants Insurance Liabilities

The fundamental appeal of insurance to private equity is elegantly simple, even as the execution is extraordinarily complex. An insurance company collects premiums and agrees to make future payments, a time lag that can span decades for life and annuity products. During that period, the insurer invests the accumulated "float" and earns a return. If the float is invested skillfully and the underlying insurance risks are managed correctly, the insurer profits both from underwriting (collecting more in premiums than it pays in claims) and from the spread between investment returns and the rate credited to policyholders.

Private equity firms recognized that their core competency (sourcing, structuring, and managing complex credit investments) could be applied to insurance float at enormous scale. The post-2008 low interest rate environment was the catalyst: traditional insurers struggled to generate adequate returns from investment-grade bonds and public fixed income, creating an opening for alternative asset managers who could access higher-yielding private credit, structured securities, and direct lending opportunities.

The model that emerged, pioneered by Apollo with Athene beginning in 2009, works as a vertically integrated system. The insurance subsidiary originates liabilities (primarily fixed and fixed-indexed annuities) through distribution networks. Those liabilities generate investable assets. The affiliated asset manager deploys those assets into private credit, asset-backed securities, collateralized loan obligations, and other structured investments that yield more than traditional portfolios. The "spread" between investment returns and policyholder crediting rates generates spread-related earnings, while the asset manager collects management fees on the growing pool. The result is a self-reinforcing engine of capital accumulation.

Patterns we've observed across multiple quarterly earnings cycles show how dramatically this model has scaled. Apollo reported record 2025 results with adjusted net income of $8.38 per share, up from $7.43 in 2024, driven by the Athene platform. KKR's Global Atlantic contributed $1.1 billion in insurance operating earnings for 2025 and grew its AUM by 15% year-over-year. Brookfield Wealth Solutions (formerly Brookfield Reinsurance) reported $370 million in distributable operating earnings in a single quarter following the AEL acquisition. The economic returns are substantial: industry observers estimate PE firms typically achieve 20% to 30% returns on investment in insurance platforms, significantly exceeding most other available alternatives.

The Asset Allocation Shift: From Conservative Portfolios to Complex Structures

The most consequential aspect of PE ownership for actuaries is the transformation of investment portfolios. Traditional life insurers have historically maintained conservative allocations dominated by investment-grade corporate bonds and government securities. PE-owned insurers pursue fundamentally different strategies, allocating significantly more to structured securities, private credit, and alternative assets.

The NAIC's year-end 2024 data quantifies the divergence. While bonds remained the largest asset class for PE-owned insurers at $431.3 billion, their composition differed materially from the broader industry. Asset-backed securities and other structured securities represented 29% of total bonds for PE-owned insurers, compared to just 12% for all U.S. insurers. Municipal bond exposure (typically considered among the safest fixed-income investments) was only 3% for PE-owned insurers versus 8% industry-wide. Mortgages increased to 20% of total PE-owned insurer investments, reflecting active origination of commercial and residential loans.

The concentration in affiliated investments is particularly notable. Affiliated Schedule BA investments represented 67% of PE-owned insurers' other long-term investments at year-end 2024, up from 64% in 2023. For the overall industry, affiliated investments were just 48% of the total. This pattern reflects the vertically integrated model: PE-owned insurers invest through their parent firms' origination platforms, which may create asset-backed securities, CLOs, or direct lending vehicles in which the insurance subsidiary then invests.

A Goldman Sachs Asset Management survey of 405 insurance CIOs and CFOs in early 2025 found that 58% planned to increase allocations to private credit over the next 12 months, and 62% intended to increase overall private markets allocation. The Chicago Federal Reserve documented that life insurers' private credit through private placements alone reached $407 billion by the third quarter of 2024, and the true total is substantially higher when including rated ABS ($699 billion industry-wide at year-end 2024), CLOs ($276.8 billion), and bank loans ($123.4 billion) that function as private credit but are reported on bond schedules rather than Schedule BA.

Morningstar's February 2026 analysis confirmed the trend is accelerating: less liquid assets now represent roughly 36% of U.S. life insurer investment portfolios, up from 32% in 2020, with ABS, CLOs, and other structured products increasing 12% year-over-year. PE-backed annuity writers hold especially high concentrations, with some firms allocating most of their invested assets to ABS and CLOs.

From an actuarial perspective, this asset reallocation raises fundamental questions about asset-liability management. Higher-yielding, less-liquid assets may improve spread income under normal conditions, but they introduce credit risk, liquidity risk, and valuation uncertainty that traditional ALM frameworks were not designed to address. The potential for forced selling in a stressed market (where illiquid assets cannot be readily converted to cash to meet policyholder surrender demands) represents a tail risk that actuaries must carefully model.

The Offshore Reinsurance Architecture: Sidecars, Bermuda, and Capital Efficiency

One of the most structurally significant, and controversial, aspects of the PE-insurance model is the extensive use of offshore reinsurance to manage capital requirements. The mechanism, sometimes described as the "Bermuda Triangle" strategy, involves ceding insurance liabilities to affiliated reinsurers domiciled in jurisdictions with different (often lower) reserve and capital requirements than the United States.

The scale of this activity has expanded dramatically. According to Fitch Ratings, U.S. life insurers nearly doubled their ceded reserves between 2019 and 2023, from $710 billion to $1.3 trillion. During the same period, reserves ceded to offshore jurisdictions nearly quadrupled, exceeding $450 billion. The Bank for International Settlements reported that PE-linked life insurers had ceded risk to affiliated reinsurers equivalent to almost half of their total assets (approximately $400 billion) by end-2023, compared to less than 10% for other U.S. life insurers. About two-thirds of the risks ceded by PE-linked insurers were assumed by offshore affiliates.

Reinsurance "sidecars" have emerged as a particularly prominent feature of this architecture. These special purpose vehicles allow outside investors to provide capital that shares in insurance risks and returns, freeing up the cedant's capital to underwrite new business. Reserves ceded to life and annuity sidecars nearly tripled between 2021 and 2023, reaching approximately $55 billion, according to AM Best. Apollo's ACRA co-investment vehicle raised over $3.2 billion in commitments, while KKR's Global Atlantic launched the Ivy sidecar as a $1 billion co-investment vehicle.

For actuaries, the offshore reinsurance structure creates complex analytical challenges. The post-reinsurance reserve position depends on the quality of assets held by the assuming entity, the collateral arrangements supporting the cession, and the counterparty's ability to honor its obligations under stress scenarios. When the assuming reinsurer is an affiliate of the PE sponsor, the potential for conflicts of interest (where the asset manager benefits from fee income while policyholders bear the investment risk) must be carefully assessed.

Regulatory Response: NAIC 13 Considerations and Actuarial Guideline 55

Regulators have responded to the PE-insurance convergence with increasing sophistication. The NAIC's Macroprudential (E) Working Group established its "13 Considerations" framework to monitor activities frequently associated with PE ownership that may affect the U.S. insurance industry. These considerations span affiliation and control structures, investment management agreements, complex and non-publicly traded assets, offshore reinsurance, sidecar arrangements, and asset adequacy testing.

As the Willkie Farr & Gallagher summary of NAIC developments noted, the 13th Consideration, addressing cross-border reinsurance, remains an area of continued focus and monitoring. The MWG reported in its August 2024 update that most considerations are now considered complete or have significantly progressed, with several resulting in enhanced Annual Statement disclosures, particularly in the investment schedules. These new disclosures provide greater transparency around PE firms' ownership of insurers and their affiliated investment managers' involvement with structured security origination.

The most significant regulatory development of 2025 was the NAIC's adoption of Actuarial Guideline 55 (AG 55) on August 13, 2025. AG 55, formally titled "Application of the Valuation Manual for Testing the Adequacy of Reserves Related to Certain Life Reinsurance Treaties," establishes requirements for ceding companies to perform asset adequacy testing for certain reinsurance transactions. It was developed by the Life Actuarial (A) Task Force specifically to address concerns that U.S. life insurers may be entering into reinsurance transactions that materially lower the total asset requirement (the sum of reserves and capital) and thereby facilitate capital releases that could prejudice policyholder interests.

AG 55 applies to life insurers with "Asset-Intensive Reinsurance Transactions" (generally defined as coinsurance arrangements involving life insurance products that transfer significant investment risk including credit quality, reinvestment, or disintermediation risk) ceded to entities that do not submit a VM-30 memorandum to U.S. state regulators. The guideline is effective for reserves reported in the 2025 annual statement, with first reports due April 1, 2026.

Critically, AG 55 was adopted on a "disclosure-only" basis for its initial implementation. It requires reporting of asset adequacy testing results but does not prescribe whether additional reserves must be held. That determination remains with the domestic regulator and the ceding company's appointed actuary. However, LATF has signaled its intention to reassess AG 55 after receiving the first year of data, potentially adding requirements beyond disclosure.

Additional regulatory actions are reshaping the investment landscape for PE-owned insurers. The NAIC increased the risk-based capital charge for ABS residual tranches (relevant for CLO equity and structured credit first-loss positions) from 30% to 45% for year-end 2024 reporting. The NAIC is also developing a comprehensive modeling methodology for CLOs, expected to be completed in 2026, which will require the Securities Valuation Office to model CLO tranches and assign NAIC designations rather than relying on external credit ratings alone. From January 1, 2026, the SVO gained authority to challenge credit ratings that differ from its own analysis by more than three notches, substituting its own assessment for capital purposes.

Systemic Risk Debate: BIS, IAIS, and the "Mark to Myth" Concern

The rapid growth of PE involvement in insurance has drawn attention from global financial stability authorities. In September 2024, the Bank for International Settlements published "Shifting Landscapes: Life Insurance and Financial Stability," a comprehensive analysis warning about systemic risks introduced by private capital's expanding role.

The BIS analysis documented several interconnected concerns. First, insurance risk is now backed by fewer liquid assets and more complex structures, making portfolios harder to value and potentially more volatile in stress scenarios. Second, cross-border risk-sharing arrangements among large reinsurance companies and their PE affiliates have made supervisory monitoring more complex. Third, the correlation risk inherent in asset-intensive reinsurance (where investment returns across multiple entities could decline simultaneously in a market downturn) differs fundamentally from traditional life reinsurance that diversifies mortality and longevity risk.

The BIS researchers modeled a stress scenario based on the 2008 financial crisis, in which the S&P 500 lost nearly 40%. Under that scenario, they estimated publicly held U.S. life insurers alone would face a capital shortfall of $150 billion. The concern is amplified by the fact that PE-linked insurers hold higher concentrations of structured and illiquid assets, which could experience deeper markdowns in a severe downturn.

The International Association of Insurance Supervisors published a complementary Issues Paper on structural shifts in the life insurance sector in late 2025, noting that PE firms' acquisitions had led to portfolio rebalancing toward higher-risk investments (including structured products, affiliated assets, and riskier mortgages) and more complex reinsurance structures.

A separate concern centers on asset valuation. Because many PE-originated investments are private, illiquid, and not traded on public markets, their reported values depend on internal models and assumptions. Academics have described this as "mark to myth" accounting, arguing that there can be wide variation in how managers value identical private assets. For actuaries performing asset adequacy testing, the reliability of reported asset values is a foundational assumption, one that becomes harder to verify when a large portion of the portfolio consists of affiliated, illiquid, privately originated securities.

Defenders of the PE-insurance model emphasize several countervailing points. PE-owned insurers maintained 96% of their bond investments in NAIC 1 and NAIC 2 designations at year-end 2024, the same credit quality profile as the prior year and consistent with the broader industry. Athene maintains $34 billion in regulatory capital and argues that its policyholder protection is robust. And the convergence model has demonstrably expanded consumer access to competitive annuity products during a period of strong demand for retirement income solutions.

The Competitive Landscape: Who's Playing and How the Model Is Evolving

The PE-insurance convergence is no longer limited to a handful of pioneers. The competitive landscape has expanded substantially, with multiple alternative asset managers now operating insurance platforms at scale.

Apollo/Athene remains the dominant player, with $430 billion in total assets and a stated ambition to reach $1.5 trillion in AUM. The firm's "One Apollo" model treats Athene as a permanent capital engine that funds Apollo's credit and origination platforms, creating what the firm describes as a "closed-loop system of growth."

KKR acquired Global Atlantic initially in 2021, taking it to 100% ownership in January 2024. Global Atlantic's AUM reached $219 billion by year-end 2025, with annual asset originations growing from $17 billion to $36 billion since the partnership began. KKR's co-CEOs have signaled willingness to pursue further acquisitions to scale the insurance platform.

Brookfield completed its acquisition of American Equity Investment Life in May 2024 for $4.3 billion, pushing insurance assets past $100 billion and establishing a major presence in the fixed annuity market. Brookfield has since pivoted toward a multiline strategy, entering P&C insurance through its acquisition of Argo Group.

Blackstone's approach has been more partnership-oriented. In August 2024, Blackstone and Resolution Life announced a strategic partnership involving $3 billion in new equity capital commitments, with Blackstone serving as investment manager. This positions Resolution Life for accelerated acquisition of closed blocks of life and annuity business globally.

The Carlyle Group operates Fortitude Group Holdings as its insurance platform, while Sixth Street Partners manages Talcott Financial Group. Bain Capital formed a strategic partnership with Lincoln Financial in June 2025, and Janus Henderson announced a partnership with Guardian Life in April 2025 to manage its investment-grade public fixed-income assets.

PwC's 2026 M&A outlook identified several billion-dollar-plus insurance transactions in the second half of 2025 alone, including Acquarian's $4.1 billion acquisition of Brighthouse Financial and Sompo Holdings' $3.5 billion purchase of Aspen Insurance from Apollo. The trend shows no signs of slowing: McKinsey's Global Private Markets Report 2026 noted that approximately 70% of 300 surveyed limited partners plan to maintain or increase private equity allocations in 2026, with insurance-backed permanent capital vehicles among the fastest-growing segments.

What This Means for Actuaries: ALM, Reserving, and Career Implications

The PE-insurance convergence has profound implications for actuarial practice across multiple domains.

Asset-Liability Management. The shift toward private credit, structured securities, and illiquid assets fundamentally challenges traditional ALM frameworks. Actuaries must model cash flow projections for assets with uncertain prepayment characteristics, limited historical performance data, and restricted secondary market liquidity. The duration-matching exercise becomes more complex when a significant portion of the asset portfolio consists of private placements, direct lending, and affiliated structured vehicles whose behavior in stress scenarios is difficult to predict from public data alone.

Asset Adequacy Testing. AG 55's adoption makes asset adequacy testing for reinsurance transactions one of the most consequential actuarial responsibilities in the current environment. Appointed actuaries at ceding companies must evaluate whether post-reinsurance reserves, considering the assets held by both the ceding and assuming entities, are sufficient under moderately adverse conditions. This requires understanding the assuming reinsurer's investment strategy, collateral arrangements, and the credit quality of assets supporting ceded reserves. With AG 55 reports due April 1, 2026, the first reporting cycle will establish important precedents.

Reserve Valuation. The growing proportion of affiliated, illiquid assets introduces valuation uncertainty into the reserve adequacy framework. When the NAIC completes its CLO modeling methodology and the SVO exercises its new authority to challenge external ratings, the capital implications for PE-owned insurers could shift materially. Actuaries must stay current with these evolving regulatory standards and incorporate them into their valuation analyses.

Risk-Based Capital. The NAIC's increase of C-1 charges for ABS residual tranches from 30% to 45%, and the ongoing expansion from 6 to 20 rating categories for RBC purposes, will directly affect capital requirements for insurers with large structured security portfolios. Actuaries involved in capital planning must model the impact of these changes on their companies' RBC ratios and strategic asset allocation decisions.

Career Opportunities. The convergence has created substantial demand for actuaries with expertise spanning insurance liabilities and alternative investments. PE-owned insurers need actuaries who understand structured credit, private placements, and complex reinsurance structures, skills that bridge traditional actuarial training with capital markets knowledge. Roles in asset-liability management, enterprise risk management, and regulatory compliance at PE-backed insurers offer competitive compensation and exposure to sophisticated financial engineering.

For candidates pursuing the SOA's FSA pathway, the PE-insurance convergence provides rich context for understanding why the Investment track and the new Predictive Analytics focus are increasingly relevant. The NAIC's RBC reforms, AG 55 requirements, and evolving structured security treatment create a rapidly changing regulatory landscape that demands actuaries who can navigate both technical actuarial standards and financial market complexity.

Outlook: Permanent Capital, Expanding Scope, and Regulatory Evolution

The convergence of private capital and insurance appears structural rather than cyclical. Deloitte's 2026 global insurance outlook projects continued convergence as carriers allocate growing portfolio shares to alternative asset classes and increasingly partner with or are acquired by alternative asset managers. The retirement savings gap, driven by aging demographics worldwide, creates sustained demand for annuity products, which in turn generates the long-duration liabilities that make insurance platforms so attractive to private capital.

The geographic scope is expanding. KKR has formed partnerships with Japan Post Insurance and Manulife Japan, while Blackstone's Resolution Life partnership targets global life and annuity consolidation. Apollo-backed Athora acquired Pension Insurance Corporation in the UK for $7.8 billion in 2025, extending the model into European pension markets.

Regulatory evolution will be a defining feature of the next several years. AG 55's first reporting cycle will provide regulators with unprecedented visibility into the asset adequacy of offshore reinsurance transactions. The NAIC's 2026 charges for the Macroprudential Working Group include reviewing sidecar use in the life insurance sector, creating a reinsurance dashboard, and examining retrocession and reinsurance recapture provisions. The completed CLO modeling methodology, expected in 2026, could materially change capital charges for structured credit-heavy portfolios.

The central tension remains unresolved: PE-owned insurers argue they deliver higher returns to policyholders, expand product availability, and maintain robust capital. Critics (including researchers at the BIS, the Federal Reserve, and advocacy groups) contend the model introduces systemic risk through illiquid asset concentrations, offshore opacity, and potential conflicts of interest. For actuaries, this is not merely an academic debate. It shapes the analytical frameworks we use, the regulatory standards we follow, and the professional responsibilities we carry as stewards of policyholder promises.

The PE-insurance convergence is not a temporary phenomenon. It is redefining the structure of the industry and with it, the practice of actuarial science. Actuaries who understand this transformation, and who can navigate its complexities with both technical rigor and professional judgment, will be among the most valuable professionals in the field.

Sources

  • NAIC Capital Markets Bureau, "Private Equity-Owned U.S. Insurer Investments Increased at Year-End 2024," 2025 - naic.org
  • NAIC, "Insurance Topics: Private Equity," updated 2025 - naic.org
  • NAIC Capital Markets Bureau, "U.S. Insurance Industry Total Cash and Invested Assets: Asset Mix at Year-End 2024," May 2025 - naic.org
  • Bank for International Settlements, "Shifting Landscapes: Life Insurance and Financial Stability," BIS Papers No. 161, September 2024 - bis.org
  • Deloitte, "2026 Global Insurance Outlook," December 2025 - deloitte.com
  • McKinsey & Company, "Global Private Markets Report 2026: Private Equity - Clearer View, Tougher Terrain," February 2026 - mckinsey.com
  • PwC, "Insurance M&A: US Deals 2026 Outlook," 2026 - pwc.com
  • Athene Holding, Investor Relations, Q3 2025 - ir.athene.com
  • KKR, "From Safeguard to Catalyst: The Evolution of Insurance as an Asset Class," October 2025 - kkr.com