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The National Association of Insurance Commissioners (“NAIC”) recently set off a firestorm among life insurance companies that invest in credit tenant loans (“CTLs”) and other so-called “loan-backed and structured securities” by adopting regulations that change the NAIC designation of debt securities (other than those already designated NAIC-1), which trade in the secondary market at either a discount from face value or at a premium (or are carried on the books of an insurance company at either a premium or discount
