FSA 2025 - Regulatory Update
By Stuart Klugman
General Insurance Insights, December 2024
One of the features of the new FSA pathway is the ability to have options regarding education on local regulatory issues. In the last edition of this newsletter, I described the four GI courses:
- GI 101 – Ratemaking and Reserving
- GI 201 – Financial, Regulatory, and Legal
- GI 301 – Further Topics in General Insurance
- GI 302 – General Insurance in the United States
To earn a fellowship, candidates must choose a 101-201 sequence in a specific practice area. After GI candidates complete GI 101 and GI 201, they may choose their remaining two courses from any in the SOA catalog. The first three courses are mostly generic (GI 201 will contain some U.S.-specific material), while GI 302 focuses exclusively on U.S. regulations.
International and Canadian candidates may benefit from GI 301, but are unlikely to elect GI 302 unless practicing in the U.S. is a likely future outcome. Those with an interest in Canadian regulation can substitute CAS Exam 6C for GI 201.
In earlier communications, we indicated that to meet the education requirements of the U.S. Qualification Standards for signing the NAIC Annual Statement, candidates would need all four GI courses plus a regulatory certificate. Since the last newsletter, an SOA/American Academy of Actuaries joint task force concluded that the four courses are sufficient, and no additional certificate is needed.
We have now put this recommendation in front of the NAIC’s Casualty Actuarial and Statistical Task Force (CASTF). In mid-November, CASTF put forth a plan to verify that the four courses cover the knowledge needed to be an appointed (signing) actuary. This is straightforward as the NAIC had previously developed a set of Knowledge Statements that we must cover. Our current GI exams currently do this, and we have designed the four courses to ensure this continues. Should the NAIC request specific changes, we will make them in time for the Fall 2025 exams.
A final element relates to candidates in transition who complete some exams from the current system and some courses from the new system. We will be asking the NAIC to approve specific combinations that cover the vast majority of the Knowledge Statements. It may be possible to earn the FSA (which always conveys practice rights) but not meet the requirements to be an appointed actuary. In particular, assuming the current GIA and FERL modules are completed, candidates will likely need either GI ADV or GI 301 along with either GI INT or GI 302.
Our goal is to have all NAIC decisions made well in advance of registration for the Fall 2025 exams so candidates may make choices based on their personal and professional interests.
As a reminder, information about the 2025 FSA changes is available here.
Statements of fact and opinions expressed herein are those of the individual authors and are not necessarily those of the Society of Actuaries, the newsletter editors, or the respective authors’ employers.
Stuart Klugman, FSA, CERA, is a senior staff fellow at the Society of Actuaries. Stuart can be contacted at sklugman@soa.org.