CNO Financial Group, Inc.

Refer to "Governmental Regulation" in our 2025 Annual Report on Form 10-K for information on our insurance and other governmental regulatory matters, other than those amended or supplemented here.

Risk-Based Capital

NAIC developments related to the RBC framework are described below.

•RBC Task Force. Formed in 2025 to enhance insurance commissioner-level oversight of the RBC framework, the Risk-Based Capital Model Governance (EX) Task Force adopted “Guiding Principles” in December 2025 that address the purpose and use of, and standards for maintaining and updating, RBC. In 2026, this task force is also undertaking to identify gaps in the RBC framework that could pose a risk to regulators’ assessment of solvency and may therefore merit changes to the RBC framework, and developing a governance process for retrospective and future adjustments to RBC.

•RBC Revisions. In June 2023, the NAIC increased the RBC factor for structured security residual tranches from 30% to 45%, which became effective for year-end 2024 RBC filings. The NAIC has been assessing the RBC treatment of CLOs and in March 2026 released an initial proposal for new C-1 (asset risk) factors for CLOs in the life RBC formula to take effect for year-end 2026.

Actuarial Guideline for Reinsurance Asset Adequacy Testing. On August 13, 2025, the NAIC adopted an actuarial guideline (AG 55) requiring disclosure related to reserve adequacy for reserves reported as of December 31, 2025 in an insurer’s annual statement. The guideline requires asset adequacy testing for reinsured long-duration insurance business that relies heavily on asset returns (i.e., “asset-intensive reinsurance transactions”) within the scope of the guideline that either meet certain size-based thresholds or result in significant reinsurance collectability risk (as determined by the cedent’s appointed actuary). Such asset adequacy testing is to be performed using a cash flow testing methodology. The actuarial guideline requires disclosure by the ceding insurer, meaning that it will not require that additional reserves be posted at the reinsurer level (although the ceding insurer may decide to post reserves). It is important to note that domestic regulators will continue to have the authority to take action on known issues, or issues that may become known as part of such new reporting (including requiring that additional reserves be held).

The paragraph under the “Governmental Regulation” section in our Annual Report on Form 10-K under the “Federal Initiatives” sub-section has been restated as the following:

Federal legislation and administrative policies in other areas, including employee benefit plan and individual retirement account (“IRA”) regulation, could also impact the insurance industry. In that regard, in April 2024, the U.S. Department of Labor (the “DOL”) issued a regulation that was intended to change the definition of "fiduciary" for purposes of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), and parallel provisions of the Internal Revenue Code of 1986, as amended (the “Code”), when a financial professional, including an insurance producer, provides investment advice to plans subject to ERISA and IRAs subject to Section 4975 of the Code and issued amendments to various existing prohibited transaction exemptions (“PTEs”) that financial professionals rely on when they make investment recommendations to such investors. Thereafter, two federal district courts blocked these changes, which prevented the changes from becoming effective. The DOL initially appealed these court orders, but on November 24, 2025, the DOL filed an unopposed motion to dismiss its consolidated appeals. In March 2026, the same federal district courts vacated the regulation changing the definition of “fiduciary” and the related PTE amendments. Shortly thereafter, the DOL issued a rule confirming that it intends to revert to its 1975 “five-part-test” for determining “fiduciary” status within the meaning of ERISA or Section 4975 of the Code when a financial professional provides investment recommendations to retirement plan investors. We are monitoring these developments, including the potential impact on our business of any such changes.