PRT’s Why Courts Keep Ignoring the Dangers of Pension Risk Transfer Annuities—And Why These Cases Must Be Appealed

/ ChrisTobe

By Christopher B. Tobe, CFA

I. Introduction: Judges Are Not Seeing the Real Risk

Despite clear, quantifiable evidence that most Pension Risk Transfer (PRT) annuities violate ERISA’s prudence, loyalty, and prohibited-transaction rules, federal courts have repeatedly dismissed PRT complaints on superficial grounds.

Judges are not just wrong; they are missing the entire risk story.

The pattern is consistent:

  • They assume “annuities are safe” because insurers have not recently failed—ignoring Executive Life, Confederation Life, and AIG.
  • They defer to a captured Department of Labor (DOL) whose 2024–25 PRT reports downplay risk and were influenced heavily by insurer lobbying.
  • They treat PRT transactions as routine outsourcing, instead of the massive conflicted-party transactions they truly are.
  • They allow insurers to hide behind state regulation, ignoring offshore reinsurers, spread arbitrage, credit-default-swap pricing, and the lack of downgrade provisions.
  • They adopt a “no harm, no foul” approach that is wildly inconsistent with ERISA’s mandate that fiduciaries evaluate risk before harm occurs.

The question is no longer, “Are judges missing something?”
It is: “Why are judges refusing to even look?” See the recently added Appendix for new PRT Academic Research.

II. Structural Reasons Judges Currently Give Insurers a Free Pass

1. Lack of Financial Literacy on Insurance Risk

Federal judges rarely understand:

Offshore reinsurance and state-based regulatory arbitrage
 https://commonsense401kproject.com/2025/10/23/why-offshore-structures-and-weak-state-regulation-make-most-annuities-erisa-prohibited-transactions/

  •  

Judges often do not grasp that a PRT annuity is not a bond.
It is a credit-risk bet on a single insurer, whose solvency is priced daily in the CDS market and has no maturity.

2. Judicial Deference to a Captured DOL

My piece (DOL’s Pension Risk Transfer Flawed Report) shows how insurer lobbying shaped DOL’s stance. https://commonsense401kproject.com/2025/10/24/dols-pension-risk-transfer-flawed-report/   

Judges rely heavily on DOL guidance—even when it is outdated, superficial, or captured.
This is the same pattern we saw with:

  • the DOL’s deference to stable-value insurers in the 1990s,
  • the DOL’s failed crypto guidance,
  • and the DOL’s refusal to police prohibited transactions.

When the DOL says “PRT is fine,” judges stop asking questions.

3. Defense Lawyers Exploit Thole and the “No Harm” Mindset

Defense firms tell courts:

“No insurer has failed recently, so participants have no harm.”

But you’ve shown repeatedly (Annuity Risks & Hidden Fees, Dangerous to Ignore Damages):

  • ERISA requires evaluation of risk, not merely waiting for collapse.
  • Damages occur at the moment the imprudent decision is made, because participants lose PBGC protection and become exposed to credit-risk spreads.
  • Courts routinely get this wrong because plaintiffs have not yet framed the damages model correctly.

4. Lack of Transparent Discovery – Because Judges Block It

Many early PRT cases were dismissed before discovery, meaning plaintiffs:

  • never obtained internal insurer risk reports,
  • never obtained reinsurance structures (often offshore),
  • never obtained spread income data,
  • never obtained consultant conflicts,
  • never obtained the CDS or the downgrade analysis done internally,
  • never obtained evidence of lobbying or state-regulatory arbitrage.

Without discovery, judges compare “annuity vs. annuity,” when the real comparison is:

PRT annuity vs. PBGC-guaranteed DB plan vs. a downgrade-protected annuity.

This framing has never been properly argued.

5. Insurer Political Power

  • Athene (Apollo) has frightening political reach.
  • CALPERS trustees associated with Apollo suffered two high-profile deaths.
  • Blackstone, KKR, Apollo, and AIG have built deep relationships throughout federal and state governments.
  • Epstein–Apollo connections, however disturbing, illustrate the depth of informal networks surrounding these firms.

Judges do not operate in a vacuum.

III. Why PRT Cases MUST Be Appealed

Every dismissal so far rests on one or more reversible errors. The most common:

1. Courts Assume PRT Annuities Are Safe — Contrary to Market Evidence

Appellate arguments should highlight:

  • CDS spreads showing Prudential, Athene, and MetLife are priced at real default risk.
  • Offshore reinsurance (Bermuda, Cayman) materially increases counterparty risk.

State guaranty associations are grossly inadequate
https://commonsense401kproject.com/2025/06/24/state-guarantee-associations-behind-annuities-are-a-joke/

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Judges have made factual assumptions contradicted by market data.
That is a reversible error.

2. Courts Misapply ERISA’s Burden of Proof

https://commonsense401kproject.com/2024/12/17/pension-risk-transfer-annuities-should-be-prohibited-the-burden-of-proof-is-on-plan-sponsors-to-justify-that-they-are-prudent/ states it clearly:

Under ERISA, fiduciaries must prove prudence—not plaintiffs.

Many district courts flipped the burden, demanding plaintiffs prove:

  • the insurer will fail,
  • the guaranty association will be insufficient,
  • spread profits will impair benefits.

This is legally incorrect.

3. Courts Ignore Prohibited Transactions (the Strongest Claim)

PRT transactions trigger at least three independent §406 violations:

  1. §406(a)(1)(D): transfer of plan assets that benefits a party in interest
    (insurer earns spread income).
  2. §406(b)(1): fiduciary self-dealing through consultants tied to insurers
    (common in State Street, Mercer, etc.).
  3. §406(b)(3): kickbacks disguised as reinsurance or spread arrangements.

See my article https://commonsense401kproject.com/2025/11/01/annuities-are-a-prohibited-transaction-dol-exemptions-do-not-work/. Annuities are almost always ERISA Prohibited Transactions.   Insurers blatantly claim that these annuity contracts have a Prohibited Transaction Exemption (PTE)  but most flunk PTEs because they are one-sided contracts as documented by their failing of the Impartial Conduct Standards 1. Loyalty  2. Prudence 3. Reasonable Compensation 4. No misleading statements.  The DOL is totally ignorant of PTEs, and the industry knows this and has gotten away with this fraud for decades until recent litigation facilitated by Cunningham v. Cornel

 shows:

  • No insurer has ever proven compliance with PTE 95-60 or 84-24.
  • Courts have wrongfully treated these exemptions as if they automatically apply.

That is a reversible error.

4. Courts Wrongly Treat PBGC Loss as Irrelevant

Removing retirees from PBGC protection is an immediate, quantifiable harm:

  • Participants lose a federal backstop.
  • They lose downgrade protection.
  • They become unsecured creditors of a single private insurer.

Courts dismiss this as “speculative.”
Appeals should show it is a realized loss of a valuable guarantee, measurable by CDS spreads https://commonsense401kproject.com/2025/10/29/annuity-risk-measured-by-credit-default-swaps-cds/

5. Courts Ignore Offshore Private-Credit Exposures Inside Insurer Portfolios

My BIS-driven piece https://commonsense401kproject.com/2025/10/28/offshore-private-credit-creates-erisa-prohibited-transaction-risks-for-life-insurance-products-new-evidence-from-bis/

demonstrates:

  • Life insurers are stuffing general accounts with illiquid private credit.
  • These risks do not exist or are immaterial in PBGC-insured DB plans.
  • Courts fail to analyze this entirely.

That is a reversible error.

IV. Why the Bristol-Myers / State Street / Athene Case Should Win—or Settle for a Huge Amount

Big Win for Retirees as Pension Risk Transfer Case Against Bristol Myers, State Street, and Athene Proceeds

The Bristol case is unique because: 

  • Plaintiffs framed both prohibited-transaction and imprudence claims.
  • Athene’s offshore reinsurance is especially egregious.
  • State Street’s consultant conflicts create a classic §406(b) problem.
  • The plan could have chosen a downgrade-protected annuity, but did not.
  • The insurer (Athene) is associated with Apollo’s extreme private-credit and offshore strategies, making the risk objectively higher.

This is the perfect case for plaintiffs.

A settlement would be enormous because:

  • Damages = the present value of the increased risk premium (CDS spread difference) over the lifetime of the annuity obligations.
  • Plaintiffs can quantify damages using the Lambert–Tobe efficient-frontier model.
  • Discovery would expose Apollo/Athene’s offshore structures—something they will pay heavily to avoid.

V. Why Appeals Must Highlight the “Missing Evidence Problem”

The most compelling appellate argument is procedural:

Courts are dismissing cases without allowing discovery necessary to evaluate risk—thereby insulating insurers from any review.

This violates:

  • The pleading standards of Twombly and Iqbal (plausibility was established).
  • The fiduciary-monitoring requirements under Tibble v. Edison.
  • The prohibited-transaction rules under Harris Trust.

Appeals can force discovery where:

  • Credit-risk documents,
  • consultant conflicts,
  • downgrade analyses,
  • reinsurance structures,
  • spread profit calculations

will destroy the defense.

VI. Conclusion: These Cases Are “The New Tobacco”—And Courts Must Stop Looking Away

PRT annuities represent:

  • immense hidden risk,
  • massive undisclosed compensation to insurers,
  • offshore opacity,
  • downgrades without recourse,
  • loss of PBGC protection,
  • actuarial manipulation,
  • and a growing link to private credit that resembles 2008 all over again.

Judges have been asleep at the wheel.
Appeals are not just warranted—they are essential.

The Bristol-Myers case is the turning point.
If it proceeds through discovery, Athene and State Street will face unprecedented exposure.

If it settles, it will be one of the largest ERISA settlements in history.

But plaintiffs must push these cases to the appellate courts—because district judges have shown they are unwilling (or unable) to confront the insurance-industry machinery head-on.

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Appendix 1: What the New Corporate-Finance Literature Reveals About PRT Motives and Systemic Risks

A new academic study—Sven Klingler, Suresh Sundaresan, and Michael Moran (2022)—provides the most comprehensive empirical analysis to date of why corporations execute Pension Risk Transfers (PRTs) and what the consequences are for the pension system. Although written from a corporate-finance standpoint rather than a fiduciary or participant-protection perspective, its findings strongly reinforce the central warnings in this article: PRTs are most attractive to financially strong sponsors, increase systemic risk for the PBGC, and shift risk onto retirees without disclosure or safeguards. 22Paper

Below is a short summary of the findings most relevant to litigation, fiduciary duty, and the urgent need for appellate review.

1. Corporations use PRTs not because they are safer—but because the PBGC premium structure is distorted

The authors demonstrate that PRT decisions are driven primarily by:

  • High “flow-through costs”—the size of the plan relative to the company, which drives earnings volatility and credit-rating pressure.
  • A large “PBGC wedge”—the mismatch between high PBGC premiums and the low economic value of the “PBGC put” for financially strong companies.

Their regression evidence shows that a one-standard-deviation increase in either factor increases the probability of a PRT by 43–55%. 22Paper

This is critical for ERISA cases:
PRTs are not chosen because they reduce risk to retirees. They are chosen because PRTs allow corporations to escape PBGC premiums and balance-sheet volatility, regardless of the insurer’s credit risk. That is the opposite of a “best-interest-of-participants” standard.

2. Companies engaging in PRTs are the safest sponsors with the least risky pension portfolios

The paper finds:

  • PRT sponsors have lower default risk, measured via Expected Default Frequency (EDF).
  • PRT sponsors have 6.5 percentage points less equity risk in their pension portfolios.

These “safer sponsors” are precisely the ones that least need to offload risk—and whose retirees lose the PBGC guarantee as soon as the annuity contract is executed. 22Paper

Implication for my argument:
PRTs increase systemic risk because they remove the safest and most stable plans from the PBGC insurance pool, leaving PBGC with the weakest sponsors. Yet courts routinely ignore this actuarial and systemic fact when dismissing PRT-related fiduciary claims.

3. PRTs have already reduced PBGC’s insured participant base by more than 10%

The paper shows that from 2012–2021:

  • $150+ billion in obligations were transferred.
  • The number of PBGC-insured participants fell by ~10%.
  • PRTs reduced total DB plan assets by about 7%.

This contraction of the insured pool is accelerating. 22Paper

Litigation relevance:
When courts say “participants are not harmed,” they ignore evidence that PRTs structurally:

  • Weaken the PBGC’s solvency.
  • Reduce risk-pool diversification.
  • Increase the probability of future benefit losses for the remaining PBGC participants.

This is directly contrary to ERISA’s statutory design.

4. PRTs are part of a broader corporate de-risking strategy that often includes plan freezes, lump-sum buyouts, and terminations

The study documents that companies doing PRTs are dramatically more likely to:

  • Offer lump-sum windows
  • Freeze the DB plan
  • Terminate the plan entirely

This aligns with my argument that PRTs are not a one-off insurance procurement but a structural dismantling of the DB system—done without participant consent and without meaningful regulatory scrutiny. 22Paper

5. The paper inadvertently supports plaintiffs: PRTs produce a “one-time cost spike” and require full funding—meaning they are expensive unless the sponsor is highly motivated to escape risk

The authors find:

  • PRTs cause a major spike in pension expenses in the transfer year.
  • Sponsors must fully fund the liabilities and pay insurer markups.

This again refutes the idea that PRTs are participant-oriented prudence decisions.

A rational sponsor would only accept these costs if it perceives a private corporate benefit—not because the annuity is prudently selected for retirees.

**Conclusion:

Even in corporate-friendly academic research, PRTs are shown to raise systemic risk, weaken the PBGC, and be driven by corporate incentives—not participant protection**

The Klingler–Sundaresan–Moran paper is valuable because it:

  • Confirms that corporate incentives dominate, not ERISA prudence.
  • Demonstrates that PRTs increase systemic and pool risk.
  • Shows that safe sponsors offload liabilities to insurers of varying credit quality.
  • Documents that PRTs meaningfully shrink PBGC coverage.

For appellate judges, this should be a wake-up call: the economics profession itself views PRTs as risk-shifting devices that degrade system-wide protection, not as benign or “equivalent” replacements for DB pensions.

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Appendix 2: The New O’Brien–Walters PBGC Analysis—Why Courts Are Wrong About PBGC Guarantees After PRTs

Our legal argument—that courts are ignoring material credit-risk evidence, CDS spreads, downgrade risks, and the absence of downgrade-trigger clauses—is strongly reinforced by these findings.

Source: “The Forgotten Promise: Why PBGC Retirement Benefit Guarantees Should Continue After Pension Risk Transfer Transactions,” Kevin O’Brien & Spencer Walters, Ivins, Phillips & Barker, Nov. 2025  https://www.ipbtax.com/PRT-PBGC-Guarantees

I. Overview and Relevance to PRT Litigation

A newly released white paper by nationally recognized ERISA attorneys Kevin P. O’Brien and Spencer F. Walters (Ivins, Phillips & Barker) provides the strongest statutory and historical argument to date that PBGC guarantees legally continue even after a pension plan executes a Pension Risk Transfer (PRT).

Their central conclusion is simple and explosive:

PBGC’s current position that its guarantees cease after a PRT is unsupported by statute, contradicted by PBGC’s own earlier interpretations, and inconsistent with both legislative history and IRS/ERISA regulatory structure.

This analysis directly undermines decades of judicial assumptions that PRT annuitants “lose PBGC protection,” and it creates new grounds for appeal in cases such as Konya v. Lockheed Martin, Doherty v. Bristol-Myers, and others.

Ironically, the O’Brien–Walters paper shows that both plaintiffs and defendants have been litigating on a false premise—that PBGC’s 1991 reversal is legally valid. The authors show it is not.

II. PBGC’s Original Rule (1981): PBGC Guarantees Continue After an Annuity Is Purchased

O’Brien and Walters highlight that PBGC’s original 1981 regulation and preamble explicitly promised that PBGC would guarantee annuity payments if an insurer failed:

“In the unlikely event that an insurance company should fail… the PBGC would provide the necessary benefits.”
— PBGC Final Rule, 46 Fed. Reg. 9532 (Jan. 28, 1981)

IPB OBrien-Walters 2025 White P…

This destroys modern arguments claiming PBGC never intended to insure post-PRT annuity recipients.

The PBGC reversed itself only in 1991, with no statutory change and no Congressional authorization.

III. Statutory Text: ERISA §4022 Requires PBGC Guarantees to Continue

The authors make a powerful statutory argument:

  • ERISA §4022 guarantees “all nonforfeitable benefits… under a single-employer plan which terminates.”
  • A benefit paid through an annuity contract remains a benefit “under the plan,” because:
    • The annuity is pursuant to and arises out of the plan.
    • Treasury regulations for 415, 417, 401(a)(9), 411(d)(6), 402, 401(h) all treat annuity-contract payments as plan benefits.
    • PBGC itself argued in Lami v. PBGC (1989) that annuity payments are plan benefits for §4044 purposes.

Thus PBGC cannot claim that annuity payments are “under the plan” when reducing their own liability (as in Lami), but not “under the plan” when guaranteeing benefits.

This is the most devastating contradiction.

IV. Legislative History: Congress Refused PBGC’s Request to End Guarantees

In the mid-1980s, PBGC, worried about Executive Life and steel/airline failures, explicitly asked Congress to amend ERISA to remove PBGC responsibility for insurer insolvency.

Congress rejected that request.

  • 1983 PBGC proposal: rejected
  • 1985 Reagan Administration bill (H.R. 2995): rejected
  • 1986 SEPPA amendments: Congress affirmed PBGC obligations continue after standard termination.

The paper cites the House Education & Labor Committee:

“A certification of close-out does not affect the PBGC’s obligations under Section 4022.”

Congress was crystal clear.

V. PBGC’s 1991 Reversal Was Purely an Administrative Power Grab

The PBGC had financial problems in the early 1990s and unilaterally reversed its position through regulatory reinterpretation.

It did so:

  • Without statutory authority
  • Without revising §4022
  • Ignoring its own 1981 rule
  • Ignoring Lami v. PBGC
  • Citing only a change in its “mission interpretation”

O’Brien & Walters note PBGC even admitted it had no internal legal analysis supporting the reversal.

In 2025, under Loper Bright, the PBGC’s 1991 policy receives zero Chevron deference and must be judged under Skidmore, where it fails every factor.

VI. Policy Argument: PBGC Should Be the Backstop, Not State Guaranty Associations

The paper argues that reversing PBGC coverage contradicts ERISA’s purpose:

  • PBGC was created as a federal guarantee program, not insurers.
  • State guaranty funds are:
    • inconsistent across states,
    • capped at extremely low levels,
    • funded only after insurer insolvency,
    • not designed for large plan failures.

Under the PBGC’s original model:

  1. State insurance guaranty pays first
  2. PBGC covers any shortfall

This layered approach was the explicit PBGC understanding in 1981.

VII. Implications for PRT Litigation

This analysis provides new ammunition for plaintiffs—and new exposure for defendants.

A. Standing

Courts in Konya and Doherty held that loss of PBGC protection = concrete injury.
But if PBGC protection never legally disappears, then:

  • PRTs do not eliminate federal protection
  • Courts must recognize the PBGC guarantee as still in force
  • Claims of “no injury” or “mootness” by defendants collapse

B. Fiduciary Breach

Plan fiduciaries who rely on PBGC’s 1991 informal interpretation may be:

  • violating the statute,
  • ignoring legislative history,
  • failing to secure PBGC protections that legally exist.

C. Prohibited Transactions

If PBGC protections remain:

  • Fiduciaries cannot argue that PRT annuities are “safe substitutes”
  • Private insurers bear full credit risk—and PBGC’s guarantee is the only federal backstop
  • Offshore reinsurance, private credit exposures, and lack of downgrade clauses become more alarming

D. Appeals

Appellate courts now have:

  • statutory basis
  • regulatory history
  • unsuccessful Congressional repeal attempt
  • PBGC’s own contradictory positions
  • Loper Bright and Skidmore deference rules

This appendix strengthens every pending appeal.

VIII. How This Appendix Strengthens Our Thesis

Our original article argued that courts are ignoring:

  • insurer risk (CDS spreads)
  • offshore reinsurance exposure
  • lack of downgrade clauses
  • conflicts of interest
  • state guaranty inadequacy

The O’Brien–Walters paper adds an entirely new dimension:

PRTs may not actually divest PBGC protection at all.
Courts have been relying on a legally wrong assumption.

This transforms PRT litigation.

IX. Conclusion: PBGC Guarantees Likely Still Apply—Courts Must Correct the Record

The O’Brien–Walters paper demonstrates:

  • PBGC’s 1991 reversal was unauthorized and inconsistent
  • ERISA’s statutory text supports ongoing PBGC protection
  • Legislative history confirms Congressional intent
  • Judicial dicta (e.g., Beck v. PACE) is not binding
  • Modern courts are applying an incorrect understanding of PBGC’s obligations

This appendix gives plaintiffs a powerful new argument in appeals and may shift the landscape of PRT litigation nationwide.

Appendix 3: The Hong v. Credit Suisse/UBS Case—A Fiduciary Test of Pension Risk Transfer Governance

The November 2025 correspondence from attorney Edward Stone on behalf of former Credit Suisse employee Victor Hong provides a detailed example of the fiduciary and transparency failures embedded in recent corporate Pension Risk Transfer (PRT) transactions HongUBSPrt.

1. False and Misleading Participant Communications

Mr. Hong’s December 2024 “Notice of Annuity Contract” claimed that the transfer of the Credit Suisse Employees’ Pension Plan to Nationwide Life Insurance Company would “not affect the value of his pension benefit.” As Stone’s letter notes, this representation was materially false because the transaction eliminated ERISA coverage and PBGC insurance protection, exposing participants to the sole credit risk of Nationwide and removing uniform fiduciary and reporting standards.

This pattern mirrors industry-wide conduct in which sponsors and insurers present PRTs as “neutral” conversions, when in fact participants lose statutory rights and transparency.

2. Loss of Diversification and Fiduciary Oversight

Before the PRT, Hong’s pension was backed by a diversified, ERISA-regulated portfolio subject to minimum-funding, reporting, and fiduciary standards. After the transfer, his claim rests entirely on Nationwide’s general-account credit. He no longer receives annual statements or protections tied to diversified trust assets—a risk shift analogous to replacing a diversified fund with a single corporate bond.

3. Key Due-Diligence Questions Ignored

Stone’s letter enumerates specific fiduciary-process inquiries that the plan administrators refused to answer:

  • Which insurers were solicited to bid?
  • What were the relative bid prices and credit-quality differentials?
  • Who served as the independent fiduciary charged with identifying the “safest available annuity” as required by ERISA 95-1?
  • Were credit-default-swap spreads or insurer solvency metrics evaluated?
  • What criteria and methodology were used to select Nationwide?

The absence of responses to these fundamental questions demonstrates a failure of prudence and loyalty. No evidence was provided that any independent fiduciary evaluated downgrade risk or insurer solvency.

4. UBS Response and Denial of Disclosure Obligations

UBS’s January 30, 2025 response explicitly declined to furnish nearly all requested information, asserting that ERISA §1024(b)(4) did not require disclosure beyond the basic plan document and an amendment authorizing the PRT. UBS refused to produce the annuity-provider bids, independent-fiduciary reports, or the executed contract—claiming the latter “has not yet been finalized.” This response highlights a regulatory blind spot: once a PRT is announced, participants are stripped of standing to demand fiduciary documentation, even though the transaction permanently alters their benefit security.

5. Legal and Systemic Implications

The Hong correspondence illustrates the same systemic issues identified in academic and policy analysis:

  • Material misrepresentation of “no change” in benefit value conceals the loss of federal insurance and oversight.
  • Opaque fiduciary selection processes prevent scrutiny of insurer risk or conflicts of interest.
  • Regulatory gap: once obligations are transferred, participants fall outside ERISA Title I enforcement and into fragmented state insurance regimes.

Together, these factors confirm that current judicial deference to PRTs ignores both factual and structural evidence of participant harm.

Expert Opinion Summary

The Hong case provides direct, documentary evidence that major financial institutions—now under UBS ownership—executed a PRT that (a) misrepresented participant protections, (b) failed to demonstrate independent fiduciary diligence, and (c) relied on narrow disclosure interpretations to avoid transparency. These practices substantiate the expert conclusion that PRTs violate ERISA’s fiduciary and anti-misrepresentation standards and exemplify why appellate courts must revisit lower-court assumptions that such transfers are risk-neutral.

Annuities Are a Prohibited Transaction — DOL Exemptions Do Not Work
Why Offshore Structures and Weak State Regulation Make Most Annuities ERISA “Prohibited Transactions”
Annuity Risks and Hidden Fees: Dangerous to Ignore, Difficult to Measure Damages
Weak Standards Make Annuities Prohibited Transactions in ERISA Plans
How Insurers Are Making Their Own Annuities More Likely to Be Prohibited Transactions
State Guarantee Associations behind Annuities are a Joke
Offshore Private Credit creates ERISA Prohibited Transaction Risks for Life Insurance Products: New Evidence from BIS

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FED says in  November 2025 Life Insurers continue to hold a significant share of illiquid assets on their balance sheets and have increased leverage

www.federalreserve.gov/publications/files/financial-stability-report-20251107.pdf

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