$1 trillion in offshore liabilities, 7–9% social inflation hit, and a $2.85M bad-faith loss for an MGA. Plus, Evan Greenberg's hot take on the industry!


Reading scan time: 5 minutes
Listening time: 8 mins

Welcome to Your Pride's Friday Five

after reviewing 200+ insurance, legal, and cyber-risk articles this week, like we do each week..

Here's the news that caught our attention:

  • The NAIC's 2026 strategic priorities hit their first major milestones at the Spring National Meeting in San Diego. Three simultaneous shifts haven't moved at this scale since the post-financial-crisis solvency reforms.
  • Chubb CEO Evan Greenberg's 2025 letter to shareholders is one of the few industry documents worth reading every word. We break down what he said and what it means for regionals, mutuals, MGAs, and insurtechs.
  • A Texas federal court ruled a ransomware sublimit didn't say what the carrier needed it to say — and let bad-faith claims proceed to trial against both the carrier and the MGA.

Three events we think deserve a quick rundown…First, If you'd rather listen check out the audio version.

The NAIC Just Rewrote the Math on Carrier Balance Sheets

Summary

The three biggest changes to hit insurance carrier balance sheets in a decade are all happening this year. Most FI buyers have no idea.

The NAIC's 2026 strategic priorities — adopted in February and hitting their first major milestones at this week's Spring National Meeting in San Diego — move capital frameworks, investment oversight, and supervisory tools simultaneously at a scale not seen since the post-financial-crisis solvency reforms. For carriers managing large illiquid and offshore portfolios, the math is about to change. For FI insurance buyers evaluating carrier strength at renewal, the questions you need to ask just got more specific.

Three shifts. Starting with year-end 2026 statutory filings, the Structured Securities Group will financially model every CLO position held by insurers and assign capital designations based on stress scenarios, replacing reliance on credit-rating agencies. A 45% risk-based capital charge on residual tranches in structured securities already targets PE-backed insurer portfolios. And the AI Systems Evaluation Tool pilot launched March 2 in twelve states, with California joining March 10, giving regulators a structured framework for examining how carriers govern AI models in underwriting, pricing, and claims. Meanwhile, roughly $1 trillion in insurance liabilities have moved offshore to jurisdictions where U.S. regulators have limited visibility into the assets backing those obligations.

(source: LION Specialty analysis; NAIC 2026 Spring National Meeting proceedings)

So what?

If you're a regional or mutual carrier:

  • Your investment portfolio is getting re-scored. Know where you stand. Know where your reinsurers stand. The repricing flows downstream.
  • AI governance is now an exam item. No documentation means exam exposure, corrective action plans, and AM Best implications.
  • The availability crisis writes into your book. Homeowners, commercial property, force-placed in Florida, California, Colorado, Texas — the NAIC's new modeling working group will shape the regulatory expectations you operate under.

If you're an FI insurance buyer heading into renewal:

  • Capital adequacy. How does your carrier's surplus hold up under the new framework — not last year's?
  • AI governance, both sides of the policy. Does your carrier have a documented program? Do you? Carriers are now evaluating the insured's AI governance at underwriting.
  • Geographic concentration. Which of your portfolio geographies face further insurer withdrawal? When carriers exit, collateral values weaken, mortgage underwriting tightens, and force-placed coverage gets thinner.

The NAIC built the checklist. Most FI buyers still don't know it exists. We broke down all three shifts — and the diligence questions that go with each — in a separate analysis.

Monday morning action: Ask your CFO to request a portfolio-level impact estimate from your investment team under the new CLO stress-testing framework before your next board meeting.

Read FLIP's full piece here: The Three Biggest Changes to Hit Carrier Balance Sheets in a Decade!

Want to know how these moves could impact your next corporate liability renewal? We'd be happy to discuss how we're advising LION clients...Let's chat!

Evan Greenberg's Four Warnings and What They Mean for Your Capital, Pricing, and Operating Decisions

Summary

Evan Greenberg's annual letter to Chubb shareholders is one of the few industry documents that's actually worth reading every word. It's part scoreboard, part field manual, and part macro briefing on how capital, politics, and risk are really interacting beneath the surface. This year did not disappoint.

Stripped of the Chubb self-congratulation, the 2025 letter is a commentary on four bigger issues: a mixed-but-fragile macro backdrop, a softening commercial insurance cycle, AI as an enterprise-wide operating disruptor, and U.S. litigation as a structural inflation driver. Chubb reported record P&C underwriting income of $6.5 billion on a combined ratio of 85.7%, with net premiums of $54.8 billion. Those are the numbers. The useful part is his worldview, not the company scorecard.

(source: 2025 Chubb Letter to Shareholders)

The LION Lens

What happened — The CEO of the largest commercial P&C insurer used his annual letter to warn that the macro, cycle, AI, and litigation forces converging right now are structural, not cyclical (2025 Chubb Letter to Shareholders).

Why it matters — He called MGA support "a bad bet in the majority of cases," signaled significant workforce reductions from AI, and described the pricing environment as already softening in key lines. That's not commentary. That's a capital allocation signal.

Practical implications — The four warnings map directly to decisions you're making right now on pricing, reserves, technology investment, and program structure.

So what?

What LION is seeing in FI lines right now. D&O pricing is competitive and soft although showing signs of flattening out. Many carriers are still chasing market share, contrary to the discipline Mr. Greenberg says his Chubb is operating under. Cyber is stabilizing, but terms and sublimit structures are tightening — the CiCi case below is a direct illustration of where that tightening breaks down. E&O/ICPL remains firm for insurers and MGAs with claims activity. Fiduciary liability is seeing renewed underwriter attention as regulatory scrutiny of retirement plan governance increases. This is not a uniform soft market.

On macro: plan for sticky severity and funding risk. Greenberg sees strong 2026 growth but immediately lists the forces keeping inflationary pressure alive: deficit spending near 6% of GDP, lagged tariff impacts, rising electricity demand, immigration-related labor shortages, and money-supply growth. His warning is blunt — deficits near $2 trillion during strong growth are "a self-inflicted problem. A reckoning is coming." Embed structurally higher loss-trend assumptions into pricing and capital plans, particularly on long-tail liability. If your actuaries booked trends at 5% and the real number is running 7–9%, the reserve conversation is now — not at next year's renewal.

On the cycle: beware following undisciplined capital. The commercial P&C pricing environment is "textured and nuanced" — firm in U.S. casualty, soft in large-account property (admitted and E&S), and competitive in financial lines where carriers are reaching for margin. Greenberg is blunt about over-intermediation: risk passing through four or five layers of commission-earning intermediaries before reaching the ultimate risk taker is a "volume-based incentive system" where the losers are risk takers and policyholders. Regionals and mutuals should treat rapid competitor rate-cutting as a warning signal, not a benchmark. MGAs and insurtechs need profitability gates hard-wired into bind authorities to avoid being pulled into the volume game.

On AI: pick workflows and do the hard yards. Greenberg frames AI as a full-scale operating rebuild, not a side project — "iterative, gritty work" done "business by business, at a deeply granular level." Chubb hired 1,500 engineers last year and signaled significant workforce reductions as automation scales. The question for your organization is not "Do we use AI?" but "Where are we actually redesigning work?" Pick 2–3 high-volume workflows — FNOL, small commercial endorsements, low-severity claims triage — and run multi-year programs with clear metrics on cycle time, leakage, and expense.

On litigation: design for a permanent tax. Greenberg pegs liability insurance costs rising 7–9% a year — multiples of inflation — and recasts it as a political problem, not just an actuarial one. Litigation finance has turned courtroom payouts into a speculative asset class. Tort reform in Georgia, South Carolina, Florida, and Louisiana is helping, but modestly. For regionals and mutuals, this is license to be explicit with boards and regulators: rising liability rates are tracking a political and legal environment, not carrier behavior. Operationally, that means sharper jurisdiction modeling, tighter attachment points, and disciplined pruning of classes where litigation dynamics turn claims into speculative assets.

The LION POV

Here's how we're advising clients:

Your loss-trend assumptions are the first thing to pressure-test. Not against CPI. Against Greenberg's actual inflation checklist: deficit spending, tariffs, power demand, labor tightness, money-supply growth. If there's a gap between what your actuaries booked and where those forces are pushing severity, that's a board conversation this quarter, not next year.

Ask the MGA question about your own program. Not as a headline reaction to Greenberg — as a mirror. How many layers sit between the underwriting decision and the balance sheet that absorbs the loss? The answer shapes claims outcomes. CiCi proves it.

Stop talking about AI strategy. Show the receipts. If you can't name the specific workflows where AI is measurably changing cycle time, expense, or accuracy today, you're not transforming. You're presenting.

The market rewards carriers and MGAs that understand the difference between growing and compounding. Greenberg has been making that distinction for 20 years. It's worth listening to.

Monday morning action: Pull your current loss-trend assumptions and compare them against Greenberg's 7–9% liability inflation benchmark. If there's a gap, put it on the actuarial committee agenda this month.

A $250K Sublimit That Didn't Say What It Meant and the Bad-Faith Case That Followed

Summary

CiCi Enterprises, the operator of the Cicis Pizza chain, suffered a ransomware attack in May 2022. A threat actor encrypted its systems and threatened to publish exfiltrated data. CiCi paid a $400,000 ransom and incurred total losses exceeding $1.2 million. The cyber policy, issued by HSB Specialty Insurance Company and underwritten through its MGA At-Bay Insurance Services, carried a $3 million aggregate limit.

HSB acknowledged coverage under four insuring agreements: Information Privacy, Network Security, Business Interruption, and Cyber Extortion. Then it invoked a Ransomware Event Sublimit Endorsement to cap the payout at $250,000. On February 24, 2026, the Northern District of Texas ruled the sublimit did not apply to the Cyber Extortion claim — and allowed CiCi's Chapter 541 bad-faith claims to proceed to trial, naming both HSB and At-Bay as the source of alleged misrepresentations and failures to disclose information critical to the coverage CiCi sought.

(sources: CiCi Enterprises LP v. HSB Specialty Ins. Co., N.D. Tex. Case No. 3:2023-cv-02155; Anderson Kill analysis)

So what?

This is Greenberg's MGA warning in real time.

The root cause isn't sloppy drafting — it's delegated binding authority without carrier-level form review. The MGA drafted the form. The carrier defended it in litigation. Neither could make the endorsement say what they needed it to say. HSB's own coverage letter acknowledged all four insuring agreements triggered, then asserted the sublimit — creating the internal inconsistency the court found devastating.

The bad-faith claims surviving summary judgment mean CiCi now has discovery into HSB and At-Bay's internal communications, underwriting files, and claims protocols. With treble damages available under Chapter 541, total exposure could approach $2.85 million on a $1.2 million loss.

A contrasting decision weeks later — Perry v. Cowbell — upheld a nearly identical $250,000 sublimit. The difference: Cowbell's endorsement explicitly stated it capped liability regardless of the number of claims or incidents. Same amount. Opposite outcome. Drafting precision.

Audit your sublimit endorsements against the insuring agreements they claim to modify. Require carrier-level review of coverage position letters before issuance. Cross-reference your defined terms. And note: CiCi was decided under Texas's strict "four corners" rule — endorsement-interpretation standards vary by state, which reinforces the need to audit against governing law in every state where your program operates.

Monday morning action: Hand this article to your coverage counsel. Ask them to confirm that every sublimit in your cyber and professional liability tower expressly references the insuring agreements it modifies — before renewal, not after a claim.

The Bottom Line

The NAIC is rescoring the capital strategies. Greenberg is naming the cycle and intermediation dynamics. A Texas court is showing what the breakdown looks like on a live claim. The question for every board heading into renewal season: where does the distance between underwriting and risk retention live in your program — and who is closing it?

In Case You Missed It!

Our last Wednesday Intelligence was our most read Brief ever. Worth checking out if you haven't already. It told the story of a southeastern regional insurer we took over from a mega-broker.

The title says it all: "Our Process Wasn't Complicated. That's the Point. And Why We Won."

A D&O claim exposed every gap in the generalist team's process. Our alternative: Our process we run for all LION clients. Senior team, 150-day timeline, direct client-to-carrier communication. The fix wasn't proprietary. It was disciplined. If you missed it, it's worth the four-minute read or listen.

[Listen here / Read here]

Thank you for reading today's edition!

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Stay Covered Out There Y'all,

TASH & FLIP

Co-Founders and Managing Partners

LION Specialty

P.S. Nothing in this briefing constitutes legal advice. These are the opinions of the founders. It's market intelligence designed to help you ask better questions of your advisors and make sharper decisions at your next insurance renewal.

LION Specialty

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