The 2026 update to the European Life Settlement Association’s (ELSA, publisher of Longevity and Mortality Investor) Licensed Provider Matrix suggests a continuing evolution of the secondary life settlement market.
On the surface, that claim might appear counterintuitive. ELSA’s annual exercise to map the landscape of licensed life settlement providers – the buyer of record of life insurance policies in the industry’s secondary market – identified 30 firms that were licensed in at least one state at the beginning of this year, down 1 from the 31 recorded in 2025, and the providers in this market this year collectively held a total of 685 licenses, down 25, or 3.5%, compared to 2025.
While five new licenses were added in aggregate, 30 were not renewed, which might be viewed as a reduction in competition (and capacity) in the secondary market — and therefore, reduced consumer access — but according to John McCarroll, General Counsel and Chief Compliance Officer at Fifth Season Investments, looking under the hood tells a different story.
“The firms dropping licenses are generally those that have been exiting the market over the past few years,” he said.
“Some states license providers for more than one year, so the reality has been that some of the firms that have dropped off the list in recent years haven’t been meaningful participants the market for a while.”
Texas and Maryland lost the most licenses this year, dropping three each, but despite that, the Lone Star State remains in the top spot for consumer choice, with 24 different potential buyers for a life insurance policy. Connecticut, Florida, Indiana, Iowa, and Massachusetts each dropped two licenses.
There were gains, however. And Arizona and New York — two populous states with high concentrations of wealthier seniors, the cohort that delivers the majority of the paper to the secondary market each year — each added a license, as did Idaho. 26 states saw no change.
While overall license numbers across the space have dipped, the decision to let a license expire is rarely straightforward. Indeed, the operational and regulatory reasons why a life settlement provider might choose to drop licenses are numerous.
“There is a lot of consideration that goes into whether a provider wants to be licensed in any given state. Each state’s insurance department enforces its own regulatory framework, reporting rules, net worth requirements, and legal liability, so maintaining active licenses across all 40-odd, regulated jurisdictions can easily run into hundreds of thousands of dollars annually in direct and indirect overhead,” said McCarroll.
“Add to that the fact that the more populous states account for a higher percentage of the policies seen in the secondary market and it may be that a provider might not feel the cost benefit analysis of being licensed in a certain state ticks their boxes.”
The reduction in the total number of provider licenses does not seem to have impacted the market’s ability to get deals over the line – at all.
In April, life settlement provider Coventry published its 2025 Life Settlement League Table Report, which details the number of policies purchased, the amount paid to consumers, and the aggregate face value of these policies, using market data derived from public records filings and provider disclosures.
The data compiled by Coventry shows that the total number of policies purchased in the secondary market rose from 2,697 in 2024 to 2,972 in 2025, an increase of more than 10% year-over-year. Total death benefit purchased increased to approximately $3.79bn (up from $3.59bn in 2024), while total consideration paid to policy sellers rose to over $652m, up from $632m.
According to Chris Conway, Managing Director at Vitaro Group, even if the number of licenses fell by a statistically significant amount, the where is just as important as the number but even so, the impact on activity at the market level would be negligible.
“If the market lost a lot of licenses from states where there are already fewer firms participating, then it could be that supply from those states becomes smaller, as reduced access would mean fewer bids, other things being equal,” he said.
“But when you look at the states that provide the bulk of the supply — New York, California, Florida, Texas, etc. — there is plenty of competition and consumer choice there. Even cutting the number of licenses in half in those states would likely not impact aggregate transaction numbers. You’d just have a smaller number of providers buying more policies.”
It would be little surprise to the market, then, if the shrinkage continues next year, and the year after. But the trend towards a soft-oligopolistic structure simply reflects a market that continues to evolve.
“Our market has had its fair share of growing pains in the past two decades, and there have been a couple of instances of taking two steps forward and then one step back,” said Conway.
“But the trend you’re seeing in the provider market is a consequence of the development of the secondary life settlement market. For consumers, choice is excellent in most states. For investors in life settlements, you can see how the number of licenses has almost zero impact on transaction levels. In some markets, fewer participants can meaningfully impact transactions. That’s not the case in the life settlement market.”
