What changed in this filing

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Item 1. Business

2026-02-27 compared with 2025-02-28 · 64 added, 96 removed, 533 unchanged (23% of the section changed)

9 unchanged sentences

We have a large and diverse customer base and maintain enduring relationships across the mortgage origination market, including with national banks, non-bank mortgage lenders, local mortgage bankers, community banks and credit unions.

In 2024, we provided new insurance coverage to over 1,600 customers.

In 2025, we provided new insurance coverage to approximately 1,600 customers.

For the full years ended December 31, 2025, 2024 and 2023 we generated new insurance written (“NIW”) of $51.5 billion, $51.0 billion and $53.1 billion, respectively.

12 unchanged sentences

EMICO is an approved insurer by the GSEs.

EMICO was renamed from Genworth Mortgage Insurance Corporation effective February 7, 2022.

We also offer mortgage-related insurance and reinsurance through our wholly owned Bermuda-based subsidiary, Enact Re Ltd.

("Enact Re").

We also offer mortgage and credit-related insurance and reinsurance through our other subsidiaries, including investing in new opportunities for Enact.

One of these subsidiaries, Enact Re Ltd.

("Enact Re"), our wholly owned Bermuda-based subsidiary, also reinsures EMICO’s new and existing insurance in-force under quota share reinsurance agreements.

We contributed $500 million into Enact Re in 2023.

As of December 31, 2024, Enact Re reinsured EMICO’s new and existing insurance in-force under quota share

reinsurance agreements and invests in new business opportunities for Enact, including assumption of excess of loss reinsurance relating to GSE risk share.

Our operations also include a run-off insurance block with reference properties in Mexico (“run-off business”), which is immaterial to our results.

19 unchanged sentences

The GSE charters generally require credit enhancement for Low Down Payment Loans to be eligible for purchase by the GSEs.

Such credit enhancement can be satisfied if a loan is insured by a GSE-qualified insurer, the mortgage seller retains at least a 10% participation in the loan, or the seller

agrees to repurchase or replace the loan in the event of a default.

Such credit enhancement can be satisfied if a loan is insured by a GSE-qualified insurer, the mortgage seller retains at least a 10% participation in the loan, or the seller agrees to repurchase or replace the loan in the event of a default.

Private mortgage insurance satisfies the GSEs’ credit enhancement requirement and, historically, has been the preferred method lenders have utilized to meet this GSE charter requirement.

As a result, the nature of the private mortgage insurance industry in the United States is driven in large part by the business practices and mortgage insurance requirements of the GSEs.

As a result, the nature of the private mortgage insurance

industry in the United States is driven in large part by the business practices and mortgage insurance requirements of the GSEs.

In furtherance of their respective charter requirements, each GSE maintains private mortgage insurer eligibility criteria, known as PMIERs, to establish when a mortgage insurer is qualified to issue coverage that will be acceptable to the GSEs for their portfolio.

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As a result, we believe borrowers with lower Fair Isaac Company (“FICO”) scores are more likely to secure mortgage loans with coverage by public agencies and borrowers with higher FICO scores are more likely to secure mortgage loans with coverage by private mortgage insurers.

Mortgage insurance policies from government agencies are also generally non-cancellable, meaning that borrowers are obligated to pay for coverage through the life of their loan,

whereas policies from private mortgage insurers are cancellable in certain circumstances as provided by the Homeowners Protection Act of 1998 (“HOPA”), and under GSE guidelines when the loan-to-value (“LTV”) ratio of an underlying mortgage falls below 80%.

Mortgage insurance policies from government agencies are also generally non-cancellable, meaning that borrowers are obligated to pay for coverage through the life of their loan, whereas policies from private mortgage insurers are cancellable in certain circumstances as provided by the Homeowners Protection Act of 1998 (“HOPA”), and under GSE guidelines when the loan-to-value

(“LTV”) ratio of an underlying mortgage falls below 80%.

Private mortgage insurers also face limited competition from certain local and state housing finance agencies.

61 unchanged sentences

In 2021 and 2020, our portfolio was impacted by low persistency, a large origination market and commercial success in the market.

A period of higher persistency followed, leading to a more balanced concentration of IIF in recent years as the 2024, 2023 and 2022 book years represent 18%, 17% and 20%, respectively, of our primary IIF as of December 31, 2024.

A period of higher persistency followed, leading to a more balanced concentration of IIF in recent years.

Our primary exposures from legacy books originated prior to 2009 continue to resolve in an orderly fashion and represented 2% of both our primary IIF and primary RIF as of December 31, 2025.

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Generally, a higher LTV ratio has a higher likelihood of claim than a lower LTV loan, absent other mitigating loan characteristics, which we consider in our underwriting and pricing.

The weighted average LTV of our IIF as of December 31, 2024 was 93% and the weighted average LTV of our NIW was 93% in both 2024 and 2023.

The weighted average LTV of our IIF as of December 31, 2025 was 93% and the weighted average LTV of our NIW was 92% in 2025 and 93% in 2024.

The credit profile of our portfolio as represented by FICO score remains strong.

5 unchanged sentences

Our largest Metropolitan Statistical Area (“MSA”) or Metro Division (“MD”) is the Phoenix, AZ, MSA, which represents 3% of primary RIF.

Our long-standing industry presence has enabled us to build active customer relationships with over 1,600 mortgage lenders across the United States.

Our long-standing industry presence has enabled us to build active customer relationships with approximately 1,600 mortgage lenders across the United States.

Our customers are broadly diversified by size, type and geography and include large money center banks, non-bank lenders, national and local mortgage bankers, community banks and credit unions.

Our largest customer accounted for 20% of total NIW and 11% of our total revenues for the year ended December 31, 2024 and 19% of total NIW and 10% of our total revenues for the year ended December 31, 2023.

This customer also accounted for 18% of our total NIW during the year ended December 31, 2022.

Our largest customer accounted for 22% of total NIW and 12% of our total revenues for the year ended December 31, 2025, 20% of total NIW and 11% of our total revenues for the year ended December 31, 2024, and 19% of total NIW and 10% of our total revenues for the year ended December 31, 2023.

No other customer accounted for 10% or more of total revenues or NIW for the years ended December 31, 2025, 2024 or 2023.

No customer accounted for more than 10% of our total revenues in 2022 and no other customer accounted for more than 10% of NIW in 2022.

Our top five customers generated 33% of our NIW in 2025.

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We distribute our mortgage insurance products through a dedicated sales force located throughout the United States, our inside sales representatives and a digital marketing program designed to expand our reach beyond our sales force.

The breadth and depth of relationships across all areas of our customers’ operations serves as a differentiator for our mortgage insurance platform and

also enables us to form strategic partnerships with other mortgage service providers seeking to expand their distribution reach.

The breadth and depth of relationships across all areas of our customers’ operations serves as a differentiator for our mortgage insurance platform and also enables us to form strategic partnerships with other mortgage service providers seeking to expand their distribution reach.

We support our sales force and improve their effectiveness in acquiring new customers by raising our brand awareness through advertising and marketing campaigns, website enhancements, digital communication strategies and sponsorship of industry and educational events.

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Our risk management philosophy is designed to ensure all relevant risks are routinely identified, assessed, managed, monitored and addressed.

We rely upon a strong organizational risk culture and governance process, ensuring that the risks we take are transparent and quantifiable, and that we can monitor the changing nature of those risks over time.

We rely upon a strong organizational risk culture and governance process, supporting that the risks we take are transparent and quantifiable, and that we can monitor the changing nature of those risks over time.

We proactively work towards mitigating exposures outside of the risk appetite, limits and tolerances that we set and review annually.

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Credit Risk Transfer

sheet to highly rated counterparties or to investors through collateralized transactions.

Our risk management framework and analytics inform our CRT strategy, which is designed to reduce the loss volatility of our in-force portfolio during stress scenarios by transferring risk from our balance sheet to highly rated counterparties or to investors through collateralized transactions.

Our CRT program also provides capital relief under PMIERs and state insurance capital requirements.

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These efforts have traditionally involved loan modifications intended to enable qualified borrowers to make restructured loan payments or efforts to sell the property, thereby potentially reducing claim amounts.

With the COVID-19 pandemic, we experienced unprecedented use of forbearance plans nationwide to assist borrowers including the ability to extend forbearance beyond 12 months.

Historically, the use of forbearance plans was limited to 12 months and primarily used for a natural disaster that impacted a region of the country.

At the conclusion of the forbearance term, a borrower could either bring the loan current, defer any missed payments until the end of their loan, pay missed payments through a repayment plan or have one or more terms of the original note modified via a loan modification.

Given the relative success of COVID-19 related forbearance plans, the industry continues to use forbearance as a loss mitigation strategy.

In the years impacted by COVID 19, we experienced increased use of forbearance plans to assist borrowers.

Given the relative recent success, the industry continues to use forbearance as a loss mitigation strategy.

Our goal is to keep borrowers in their homes.

2 unchanged sentences

Various factors affect the frequency and severity of claims, including LTV at the time of foreclosure, size and coverage percentage of a loan, property values, employment levels and interest rates.

Any delays in foreclosure, including foreclosure moratoriums imposed by state and local governments and the GSEs, could cause our losses to increase as expenses accrue for longer periods or if the value of foreclosed homes decline during such foreclosure delays.

Any delays in foreclosure, including foreclosure moratoriums imposed by state and local governments and the GSEs, could cause our losses to increase as expenses

accrue for longer periods or if the value of foreclosed homes decline during such foreclosure delays.

For loans insured on or after October 1, 2014, our mortgage insurance policies limit the number of months of unpaid interest and associated expenses that are included in the mortgage insurance claim amount to a maximum of 36 months.

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We also periodically receive claim notices that request coverage for costs and expenses associated with items not covered under our policies, such as losses resulting from property damage to a covered home.

We actively review claim notices to ensure we pay only for covered expenses.

We actively review claim notices in an effort to ensure we pay only for covered expenses.

We deem a reduction in the claim amount paid relative to the amount requested in the claim notice to be a curtailment.

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Investment Portfolio

The investment portfolios of our insurance subsidiaries are directed by the Enact Investment Committee, a management-level committee, with Genworth serving as the investment manager.

the terms of our investment management agreement, the Company is charged an investment management fee by Genworth.

The total investment expenses paid to Genworth were $7.1 million and $5.7 million for the years ended December 31, 2024 and 2023, respectively.

The investment portfolios of our insurance subsidiaries are directed by the Enact Investment Committee, a management-level committee, with Genworth serving as the primary investment manager.

Under the terms of our investment management agreement, the Company is charged an investment management fee by Genworth.

See Note 11 to our audited consolidated financial statements for further information.

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In the future, we may choose to more broadly engage external asset managers.

Our senior management team, along with our board of directors, reviews investment performance and strategy on a periodic basis.

senior management team, along with our board of directors, reviews investment performance and strategy on a periodic basis.

As of December 31, 2025, the fair value of our investment portfolio was $6.1 billion of fixed maturity assets, of which 99% was rated as investment grade.

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As of December 31, 2025, we had 419 full-time employees, all of whom work in the United States.

Our employee population is made up of 52% women and 29% people of color.

Of our employees, 51% work in our Raleigh, North Carolina office and the remaining 49% are in the field, predominantly working in sales and underwriting.

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We routinely assess talent, engage in deep succession planning at all levels of the organization and provide feedback to our employees through a formal annual performance review process.

• Our employee-led council focused on our diverse employee population helps to build an inclusive culture through company-wide events and by educating our employees on the experiences and perspectives of others.

• Our employee-led council focused on our employee population helps to build an inclusive culture through company-wide events and by educating our employees on the experiences and perspectives of others.

• We champion civic engagement through paid volunteer time for employees, event sponsorship programs, employee-directed charitable gifts with a 100% company match, the Enact Foundation, and through our commitment to environmental sustainability.

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• We celebrate our talent by showcasing employee achievements and expertise in industry and local publications, at events and conferences, and through our online presence.

Enact was recognized as an award winner by external organizations on five occasions throughout 2024.

Enact was recognized as an award winner by external organizations on four occasions throughout 2025.

Our insurance operations are generally subject to extensive oversight and a wide variety of laws and regulations.

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For example, state insurance laws and regulations typically govern the financial condition of insurers, including standards for solvency, types and concentrations of permissible investments, establishment and maintenance of reserves, credit for reinsurance, requirements for capital adequacy, and the business conduct of insurers, including marketing, sales practices and claims handling.

State insurance laws and regulations also usually require the licensing of

insurers and agents, and the approval of policy forms and rates.

State insurance laws and regulations also usually require the licensing of insurers and agents, and the approval of policy forms and rates.

In addition, states may require actuarial justification of rates on the basis of the insurer’s loss experience, expenses and future projections.

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Mortgage guaranty insurance premium rates and policy forms are subject to regulation in every jurisdiction in which our insurance subsidiaries are licensed to transact business in order to protect policyholders against the adverse effects of excessive, inadequate or unfairly discriminatory rates.

In most jurisdictions, premium rates and policy forms must be filed prior to their use.

jurisdictions, premium rates and policy forms must be filed prior to their use.

In some states, such rates and forms must also be approved prior to use.

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In considering an application to acquire control of an insurer, the insurance commissioner generally considers factors such as the experience, competence and financial strength of the applicant, the integrity of the applicant’s board of directors and executive officers, the acquirer’s plans for the management and operation of the insurer, and any anti-competitive results that may arise from the acquisition.

Most jurisdictions also require a person seeking to acquire control of an insurer licensed but not domiciled in that jurisdiction to make a filing prior to completing an acquisition if the acquirer and its affiliates and the target insurer and its affiliates have

specified market shares in the same lines of insurance in that jurisdiction.

These provisions may not require acquisition approval but can lead to imposition of conditions on an acquisition that could delay or prevent its consummation.

In certain situations, state insurance laws and regulations also require that a controlling person of an insurer submit prior notice to the insurer’s domiciliary insurance regulator of a divestiture of control.

Similarly, with respect to our contract underwriting entity, Enact Financial Services, Inc., prior approval from state banking commissioners is required in some jurisdictions prior to acquiring control of our contract underwriting entity, which is licensed or has an approved license exemption in most states.

Similarly, with respect to our contract underwriting entity, Enact Financial Services, Inc., prior approval from state banking commissioners is required in some jurisdictions prior to acquiring

control of our contract underwriting entity, which is licensed or has an approved license exemption in most states.

domiciled insurance subsidiaries’ payment of dividends or other distributions to our holding company is regulated by the state insurance laws and regulations of their respective domiciliary states.

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and provide a confidential high-level report annually to the lead state commissioner.

We comply by participating in Genworth’s ORSA reporting.

State insurance laws and regulations govern the marketplace for U.S.

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State insurance regulators developed SAP as a basis of accounting used to monitor and regulate the solvency of insurers.

Since insurance regulators are primarily concerned with ensuring an insurer’s ability to pay its current and future obligations to policyholders, statutory accounting conservatively values the assets and liabilities of insurers, generally in accordance with standards specified by such insurer’s domiciliary jurisdiction.

Since insurance regulators are primarily concerned with ensuring an insurer’s ability

to pay its current and future obligations to policyholders, statutory accounting conservatively values the assets and liabilities of insurers, generally in accordance with standards specified by such insurer’s domiciliary jurisdiction.

Uniform statutory accounting practices are established by the NAIC and are generally adopted by regulators in the various state jurisdictions.

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We believe our insurance subsidiaries’ investments are in compliance with these state insurance laws and regulations or are subject to any applicable waivers.

Enact Re’s investments are in compliance with Bermudian law.

Enact Re’s investments are governed by, and in compliance with, Bermudian law.

Capital and Surplus Requirements

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or (iv) any changes to our operations that may be necessary to comply, any of which could have a material adverse effect on our business, results of operations and financial condition.

We also cannot predict whether other regulatory initiatives will be adopted and what

impact, if any, such initiatives, if adopted as laws, may have on our business, results of operations and financial condition.

We also cannot predict whether other regulatory initiatives will be adopted and what impact, if any, such initiatives, if adopted as laws, may have on our business, results of operations and financial condition.

Group Capital Requirements .

The NAIC has developed a group capital calculation (“GCC”) tool using an RBC aggregation methodology for all entities within the insurance holding company system, including non-U.S.

The NAIC has developed and implemented a group capital calculation (“GCC”) tool using an RBC aggregation methodology for all entities within the insurance holding company system, including non-U.S.

The GCC provides regulators with an additional tool for conducting group-wide supervision and enhances transparency into how capital is allocated.

In December 2020, the NAIC adopted a Group Capital Calculation Template and Instructions, and it amended the Holding Company System Model Act and Regulation to implement an annual GCC filing requirement.

The amendments were adopted by Virginia, Genworth’s insurance holding company group’s lead state, in 2022.

We submit the required GCC filing annually to Virginia, our insurance holding company group’s lead state.

It is unclear how the development of group capital measures by the NAIC will interact with existing capital requirements for U.S.

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As the largest purchasers of conventional mortgage loans, and therefore, the main beneficiaries of private mortgage insurance, the GSEs impose eligibility requirements that private mortgage insurers must satisfy in order to be approved to insure loans purchased by the GSEs.

Effective December 31, 2015,

each GSE adopted the original PMIERs, which set forth operational and financial requirements that mortgage insurers must meet in order to remain eligible.

On September 27, 2018, the GSEs issued revisions to PMIERs, which became effective March 31, 2019.

PMIERs aims to ensure that approved insurers possess the financial and operational capacity to serve as strong counterparties to the GSEs throughout various market conditions.

PMIERs is comprehensive, covering virtually all aspects of the business and operations of a private mortgage insurer of GSE loans, including internal risk management and quality controls, underwriting, claim processing and loss mitigation, among others.

Initially effective December 31, 2015, each GSE adopted the original PMIERs, which set forth operational and financial requirements that mortgage insurers must meet in order to remain eligible.

PMIERs, which has had multiple subsequent updates, aims to ensure that approved insurers possess the financial and operational capacity to serve as strong counterparties to the GSEs throughout various market conditions.

PMIERs is comprehensive, covering virtually all aspects of the business and operations of a private mortgage insurer of GSE loans,

including internal risk management and quality controls, underwriting, claim processing and loss mitigation, among others.

In addition, PMIERs require private mortgage insurers to obtain the prior consent of the GSEs before taking certain actions, which may include entering into various intercompany agreements and commuting or reinsuring risk, among others.

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They include quality control requirements that are designed to ensure that approved insurers have a strong internal risk management infrastructure and senior management oversight.

During 2020 and 2021, the GSEs issued several amendments to PMIERs.

Many of the provisions are no longer applicable but for loans that became non-performing due to a COVID-19 hardship, PMIERs was temporarily amended with respect to each non-performing loan that (i) had an initial missed monthly payment occurring on or after March 1, 2020 and prior to April 1, 2021 or (ii) is subject to a forbearance plan granted in response to a financial hardship related to COVID-19, the terms of which are materially consistent with terms of forbearance plans offered by the GSEs.

The risk-based required asset amount factor for the non-performing loan is the greater of (a) the applicable risk-based required asset amount factor for a performing loan were it not delinquent, and (b) the product of a 0.30 multiplier and the applicable risk-based required asset amount factor for a non-performing loan.

In the case of (i) above, absent the loan being subject to a forbearance plan described in (ii) above, the 0.30 multiplier is applicable for no longer than three calendar months beginning with the month in which the loan became a non-performing loan due to having missed two monthly payments.

Loans subject to a forbearance plan described in (ii) above include those that are either in a repayment plan or loan modification trial period following the forbearance plan unless reported to the approved insurer that the loan is no longer in such forbearance plan, repayment plan, or loan modification trial period.

In addition, the PMIERs Amendment made permanent revisions to the risk-based required asset amount factor for non-performing loans for properties located in future Federal Emergency Management Agency (“FEMA”) Declared Major Disaster Areas eligible for individual assistance.

Under PMIERs, we are subject to these operational and financial requirements.

1 unchanged sentence

In their respective letters approving credit for reinsurance against PMIERs financial requirements, the GSEs require our mortgage insurance subsidiary not to exceed a maximum statutory RTC ratio of 18:1 or they reserve the right to reevaluate the amount of PMIERs credit for reinsurance and other CRT transactions available under PMIERs indicated in their approval letters.

Freddie Mac has also imposed

additional requirements on our option to commute these reinsurance agreements.

Freddie Mac has also imposed additional requirements on our option to commute these reinsurance agreements.

Both GSEs reserved the right to periodically review the reinsurance transactions for treatment under PMIERs.

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In addition, our PMIERs required assets as of December 31, 2024, benefited from the application of a 0.30 multiplier applied to the risk-based required asset amount factor for certain non-performing loans.

Per guidance released by the GSEs in the third quarter of 2024, use of the multiplier will be discontinued effective March 31, 2025.

Per guidance released by the GSEs, use of the multiplier was discontinued effective March 31, 2025.

On August 21, 2024, the GSEs and the FHFA released updated PMIERs requirements phasing in a revision to the available assets standards between March 31, 2025 and September 30, 2026.

The updated standards differentiate between bonds based on credit quality and liquidity.

The updates also establish limits for assets backed by residential mortgages or commercial real estate to mitigate the impact if such assets lose value during periods of housing stress.

We expect to hold capital sufficiency well in excess of these requirements and do not expect the impact of these updates to be material.

The ultimate impact of the PMIERs changes will be influenced by investment portfolio maturities, dispositions, reinvestments, and overall business and economic performance between today and the phase-in dates.

The updates also established limits for assets backed by residential mortgages or commercial real estate to mitigate the impact if such assets lose value during periods of housing stress.

We expect to hold capital sufficiency well in excess of these requirements and do not expect the impact of these updates to be material to our sufficiency.

The ultimate impact of the PMIERs changes will be influenced by investment portfolio maturities, dispositions, reinvestments, and overall business and economic performance through the phase-in dates.

Other Federal Regulation

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Although many states prohibit mortgage insurers from giving rebates, RESPA has been interpreted to cover many non-fee services as well.

Mortgage insurers and their customers are subject to the potential sanctions of this

law, which may be enforced by the CFPB, state insurance departments, state attorneys general and other enforcement authorities.

Mortgage insurers and their customers are subject to the potential sanctions of this law, which may be enforced by the CFPB, state insurance departments, state attorneys general and other enforcement authorities.

HOPA provides for the automatic termination, or cancellation upon a borrower’s request, of the borrower’s obligation to pay for private mortgage insurance upon satisfaction of certain conditions.

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FCRA imposes restrictions on the permissible use of credit report information and requires mortgage insurance companies to provide “adverse action” notices to consumers in the event an application for mortgage insurance is declined or offered at less than the best available rate for the loan program applied for due to information contained in a consumer’s credit report.

There has been class action litigation over these FCRA adverse action notices involving the mortgage insurance industry, including court-approved settlements.

The Fair Housing Act generally prohibits discrimination in the terms, conditions or privileges in residential real estate-related transactions on the basis of race, color, religion, sex, familial status or national origin.

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In addition, both the Department of Justice (the “DOJ”) and the CFPB have pursued claims under the Fair Housing Act on a disparate impact theory as well.

There has been litigation over the Fair Housing Act involving other mortgage insurers, resulting in some cases in court-approved settlements.

Mortgage Servicing Rules

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Since 2014, the CFPB has clarified those rules through subsequent rule makings and provided guidance on how servicers must apply them in certain circumstances.

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was signed into law.

On April 3, 2020, the CFPB, the National Credit Union Administration, the Federal Banking Agencies and the Conference of State Bank Supervisors issued a joint statement to clarify existing flexibility in the mortgage servicing rules that services can use to help consumers during the COVID-19 emergency, including those applicable to mortgage forbearance options under the CARES Act.

The joint statement addressed flexibility around required notices from servicers and the existing requirements related to continuity of contact and reasonable diligence steps required when the forbearance ends.

This guidance could reduce claims and mitigate losses but may also contribute to delays in foreclosure and have an adverse impact on resolution of claims with respect to the servicing of mortgage loans covered by our insurance policies.

The CARES Act provided financial assistance for businesses and individuals and targeted regulatory relief for financial institutions.

Among many other things, for up to 120 days after the termination date of the national emergency concerning COVID-19 declared by the Trump Administration on March 13, 2020 under the National Emergencies Act, the CARES Act required mortgage servicers to provide up to 180 days of forbearance for borrowers with a federally backed mortgage loan who asserted they had experienced a financial hardship related to COVID-19.

The forbearance could be extended for an additional 180 days, up to a year in total, or shortened at the request of the borrower.

In addition, on February 25, 2021, the FHFA announced that borrowers with a mortgage backed by the GSEs who were

in an active COVID-19 forbearance plan as of February 28, 2021, could request up to two additional forbearance extensions for a maximum of 18 months of total forbearance relief.

In addition, the CARES Act provided that furnishers of credit reporting information, including servicers, should report a loan as current to credit reporting agencies if the loan is subject to a payment accommodation, such as forbearance, so long as the borrower abided by the terms of the accommodation.

Many servicers updated and improved their reporting to private mortgage insurers for when a loan is covered by forbearance.

The Biden Administration ended the national emergency for COVID-19 in April 2023, so the deadline for requesting a COVID-19 related forbearance under the CARES Act ended in August of 2023.

Regulation of Mortgage Origination

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More recently, in July of 2023, the Federal Reserve, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency proposed for comment the Basel III Endgame rule.

Under the proposed rule, commercial banks with total assets greater than $100 billion would no longer receive the 50% capital relief for high loan-to-value portfolio loans with mortgage insurance.

If adopted as proposed, this rule could decrease the demand for mortgage insurance.

The federal banking regulators are currently in the review process, and with the change in Administration on January 20, 2025, the outcome, content and timing of the final rule are unclear.

As originally proposed, the rule would have eliminated the 50% risk‑based capital benefit for high‑LTV portfolio mortgages with private mortgage insurance for banking organizations with $100 billion or more in total assets, which, if adopted, could reduce demand for mortgage insurance.

Since the Basel III Endgame proposal was issued, U.S.

banking regulators have since withdrawn that proposal and indicated that the standard will be re-proposed with significant revisions.

As a result, the timing, substance, and ultimate impact of the Basel III Endgame on financial institutions, and the mortgage insurance market, remains uncertain.

Privacy of Consumer Information and Cybersecurity

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Furthermore, the issues surrounding data security and the safeguarding of consumers’ protected information are under increasing regulatory scrutiny by state and federal regulators, particularly in light of the number and severity of recent United States companies’ data breaches.

The Federal Trade Commission, the DOJ, the New York State Department of Financial Services (“NYDFS”), the SEC and the NAIC have undertaken various studies, reports and actions regarding privacy and data security for entities under their respective supervision.

Several states have recently enacted new privacy and information security requirements and new insurance laws that require certain regulated entities to implement and maintain comprehensive information security programs to safeguard the personal information of insureds and enrollees.

Several states have enacted privacy and information security requirements and insurance laws that require certain regulated entities to implement and maintain comprehensive information security programs to safeguard the personal information of insureds and enrollees.

The GLB Act and the FCRA impose privacy and information security requirements on financial institutions, including obligations to protect and safeguard consumers’ nonpublic personal information and creditworthiness information, respectively, and limitations on the use and sharing of such information.

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Many states have enacted privacy and data security laws that impose compliance obligations beyond those imposed by the GLB Act, including obligations to protect sensitive personal information.

All fifty states also require entities to provide notification to affected state residents and, in certain instances, state regulators, such as state attorneys general or state insurance commissions, in the event of certain security breaches affecting personal information, though some of these laws include exemptions for entities regulated by the GLB Act.

The California Consumer Privacy Act of 2018 (the “CCPA”) was amended significantly by the California Privacy Rights Act of 2020 (“CPRA”).

The CCPA, as amended by the CPRA, grants California residents the right to know what information a business has collected about them and the sourcing and sharing of that information, as well as the right to access and correct their personal information, and (subject to certain exemptions) the right to have a business delete their personal information.

All fifty states also require entities to provide notification to affected state residents and, in certain instances,

state regulators, such as state attorneys general or state insurance commissions, in the event of certain security breaches affecting personal information, though some of these laws include exemptions for entities regulated by the GLB Act.

The California Consumer Privacy Act of 2018 (the “CCPA”) was amended significantly by the California Privacy Rights Act of 2020 (“CPRA”) and again amended in 2025 by the California Privacy Protection Agency (CalPrivacy).

The CCPA and its amendments grant California residents the right to know what information a business has collected about them and the sourcing and sharing of that information, as well as the right to access and correct their personal information, and (subject to certain exemptions) the right to have a business delete their personal information.

The CPRA created the California Privacy Protection Agency to enforce the CCPA and to promulgate regulations thereunder, imposed additional obligations regarding the privacy notice and service provider contracts, created new requirements around the protection of sensitive personal information and eliminated certain exemptions for personal information collected in employment or business-to-business contexts.

The majority of the CPRA provisions went into effect on January 1, 2023.

Failure to comply with the CCPA risks regulatory fines, and the law grants a private right of action for any unauthorized disclosure of certain personal information not subject to an exemption as a result of failure to maintain reasonable security procedures and practices.

Virginia, Colorado, Connecticut, and Utah enacted comprehensive data privacy laws that went into effect in 2023.

These laws generally impose similar requirements as the CCPA but do not apply to employee or contractor data or business-to-business information.

Each of these laws has entity-wide exemptions for financial institutions subject to the GLB Act.

Additionally, other states have enacted privacy laws that will become effective in 2024 and beyond.

Many states have enacted comprehensive data privacy laws in the past few years.

These laws generally impose similar requirements as the CCPA but most do not apply to employee or contractor data or business-to-business information.

Each of these laws has either entity-wide or data-specific exemptions for financial institutions subject to the GLB Act.

Adapting our data privacy practices to forthcoming applicable laws and regulations may increase our compliance costs and increase the risk of noncompliance.

Cybersecurity continues to be an area of significant and increasing focus of legislatures and regulators.

The NYDFS amended its cybersecurity regulation effective November 1, 2023, which, along with subsequent guidance, requires all banks, insurance companies, and other financial services institutions and licensees regulated by the NYDFS, including several of our subsidiaries, to establish a cybersecurity program.

The New York Department of Financial Services (“NYDFS”) amended its cybersecurity regulation which, along with subsequent guidance, requires all banks, insurance companies, and other financial services institutions and licensees regulated by the NYDFS, including several of our subsidiaries, to establish a cybersecurity program.

The NYDFS cybersecurity regulation includes specific technical safeguards as well as requirements regarding governance, incident planning, training, encryption of nonpublic information, data management, system testing and regulator notification in the event of certain cybersecurity events.

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We anticipate that more states will begin adopting the Insurance Data Security Model Law, sometimes with state-specific modifications, in the near term, although it is not yet an accreditation standard.

The NAIC has also adopted a guidance document that sets forth twelve principles for effective insurance regulation of cybersecurity risks based on similar regulatory guidance adopted by the Securities Industry and Financial Markets Association and the “Roadmap for Cybersecurity Consumer Protections,” which describes the protections to which the NAIC believes consumers should be entitled from their insurance companies, agents and other businesses concerning the collection and maintenance

of consumers’ personal information, as well as what consumers should expect when such information has been involved in a data breach.

We expect cybersecurity risk management, prioritization and reporting to continue to be an area of significant regulatory focus by such regulatory bodies and self-regulatory organizations.

We expect cybersecurity risk management, prioritization and reporting to

continue to be an area of significant regulatory focus by such regulatory bodies and self-regulatory organizations.

As noted above, state governments, Congress, and federal and state agencies may consider and enact additional legislation or promulgate regulations governing privacy, cybersecurity, and data breach reporting requirements.

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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1. Business