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Capital Adequacy (E) Task Force Working Agenda (Revised December 2025)

The purpose of the Working Agenda page is to inform stakeholders and interested parties/regulators the priority and details of projects among the Task Force and its respective Working Groups.

2026 #Owner2026 PriorityExpected Completion DateWorking Agenda ItemSourceCommentsDate Added to Agenda
Ongoing Items – Life RBC
L1Life RBC WGOngoingOngoingMake technical corrections to Life RBC instructions, blank and /or methods to provide for consistent treatment among asset types and among the various components of the RBC calculations for a single asset type.   
L2Life RBC WG12026 or later

1. Monitor the impact of the changes to the variable annuities reserve framework and risk-based capital (RBC) calculation and determine if additional revisions need to be made.

2. Develop and recommend appropriate changes including those to improve accuracy and clarity of variable annuity (VA) capital and reserve requirements.

CADTFBeing addressed by the Variable Annuities Capital and Reserve (E/A) Subgroup 
L3Life RBC WG12026 or later

1. Provide recommendations for the appropriate treatment of longevity risk transfers by updating the approach to develop the C-2 capital amount for longevity reinsurance products.

2. Monitor and make recommendations as needed based on the impact from changes to the non-variable annuity reserve framework.

New JerseyBeing addressed by the Longevity (E/A) Subgroup 
L4Life RBC WG12026 or laterMonitor the economic scenario governance framework, review material economic scenario generator updates, key economic conditions, and metrics, support the implementation of an economic scenario generator for use in statutory reserve and capital calculations and develop and maintain acceptance criteria Being addressed by the Generator of Economic Scenarios (GOES) (E/A) Subgroup 
Carryover Items Currently being Addressed – Life RBC
L5Life RBC WG12027 or laterUpdate C3 Phase I to modernize the cash-flow testing methodology and revise the scope to include FIAs.AAABeing addressed by the American Academy of Actuaries 
L6Life RBC WG12026 or laterReview companies at action levels, including previous years, to determine what drivers of the events are and consider whether changes to the RBC statistics are warranted. Deliberate the relevant weights assigned to various risk components.   
L7

Life RBC

WG

22026 or later

In light of SAPWG INT to permit admittance of negative IMR, SAPWG requested CADTF to consider:

1. The elimination of any admitted net negative IMR from Total Adjusted Capital (TAC).

2. Sensitivity testing with and without negative IMR.

        CADTF12/2/23 - received CADTF referral for Negative Interest Maintenance Reserve (IMR). 
L8

Life RBC

WG

2

2026 or

later

Consider SAPWG Referral for Investments in Tax Credit Structures, specifically to consider possible factor changes for investments in Tax Credit StructuresSAPWG referral

3/27/24 – received         SAPWG referral on Tax Credit Investments 2025 to address the structural and instructional changes.

5/1/25 -

Tax Credit Investment Proposal 2024-21-L MOD was adopted

 
L9Life RBC WG2

2026 or

later

Consider possible structural changes to account for reporting changes for collateral loans addressed through instructional changes for 2024 with the adoption of proposal 2024-15-LSAPWG referral

2/29/24 – received SAPWG regarding collateral loan reporting changes

6/16/24 – Collateral loans proposal 2024-15-L was adopted

6/5/25 – received another referral from SAPWG on Collateral Loan Schedule BA reporting changes

 
New Items – Life RBC
2026 #Owner2026 PriorityExpected Completion DateWorking Agenda ItemSourceCommentsDate Added to Agenda
Ongoing Items – RBC IR & E
        
Carryover Items Currently being Addressed – RBC IR &E
IR1RBC IRE22026 or laterSupplemental Investment Risks Interrogatories (SIRI)

Referred from CADTF

Referral from Blackrock and IL DOI

The Task Force received the referral on Oct. 27. This referral will be tabled until the bond factors have been adopted and the TF will conduct a holistic review all investment referrals.1/12/2022

11/19/2020
IR2RBC IRE22026 or later

NAIC Designation for Schedule D, Part 2 Section 2 - Common Stocks

Equity investments that have an underlying bond characteristic should have a lower RBC charge.  Similar to existing guidance for SVO-identified ETFs reported on Schedule D-1, are treated as bonds.

Referred from CADTF

Referral from SAPWG

8/13/2018

10/8/19 - Exposed for a 30-day Comment period ending 11/8/2019
3-22-20 - Tabled discussion pending adoption of the bond structure and factors.
1/12/2022

10/11/2018
IR3RBC IRE22026 or laterComprehensive Fund Review for investments reported on Schedule D Pt 2 Sn2

Referred from CADTF

Referral from VOSTF

9/21/2018

Discussed during Spring Mtg. NAIC staff to do analysis.
10/8/19 - Exposed for a 30-day comment period ending 11/8/19
3-22-20 - Tabled discussion pending adoption of the bond structure and factors.
1/12/2022

11/16/2018
IR4RBCIRE12026 or later

Evaluate the appropriate RBC treatment of Asset-Backed Securities (ABS), including Collateralized Loan Obligations (CLO), collateralized fund obligations (CFOs), or other similar securities carrying similar types of tail risk (Complex Assets).

Address the tail risk concerns no captured by reserves for privately structured securities.

Request from E Committee, SAPWG, VOSTF

Referral from the Macroprudential (E) Working Group

Per the request of E Committee comments were solicited asking if these types of assets should be considered a part of the RBC framework.

1/12/2022

8/13/2022

IR5RBC IRE12026 or laterEvaluate the appropriate RBC treatment of Residual Tranches.Request from E Committee, SAPWG, VOSTF

Per the request of E Committee comments were solicited asking if these types of assets should be considered a part of the RBC framework.

Proposal 2023-09-IRE was adopted in 2023 to effect a 45% factor for residual tranches/interest for life insurers with effect from YE 2024 reporting. This was deemed an interim solution, subject to positive or negative adjustments based on American Academy of Actuaries’ study. (IR4)

1/12/2022
IR6RBC IRE12026 or laterPhase 2 Bond analysis - evaluate and develop an approach to map other ABS to current bond factors following the established principles from Phase I where the collateral has an assigned RBC.  This project will likely require an outside consultant and the timeline could exceed 2-3 years.Request from E CommitteePer the request of E Committee comments were solicited requesting the need for outside review.1/12/2022
IR7RBC IRE22026 or laterEvaluate asset concentration related issues and the potential changes to the risk-based capital formulas to address the risk.Referral from CADTF4/30/24 – Task Force referred to the Working Group.10/22/2024

New Items – RBC IR &E

2026 #Owner2026 PriorityExpected Completion DateWorking Agenda ItemSourceCommentsDate Added to Agenda
Ongoing Items – P&C RBC
P1Cat Risk SG1 Continue development of RBC formula revisions to include a risk charge based on catastrophe model output:   
Year-end 2027 or latera) Evaluate other catastrophe risks for possible inclusion in the charge
   - determine whether to recommend developing charges for any additional perils, and which perils or perils those should be.
Referral from the Climate and Resiliency Task Force. March 2021 4/26/2021
P2PCRBCWG1OngoingReview and analyze the P/C RBC charges that have not been reviewed since developed.  3/23/2023
Carryover Items Currently being Addressed – P&C RBC
P3P&C RBC WG2Year-end 2027 or later

Evaluate a) the current growth risk methodology whether it is adequately reflects both operational risk and underwriting risk; b) the premium and reserve based growth risk factors either as a stand-alone task or in conjunction with the ongoing underwriting risk factor review with consideration of the operational risk component of excessive growth; c) whether the application of the growth factors to NET proxies adequately accounts for growth risk that is ceded to reinsures that do not trigger growth risk in their own right.

Referral to the Academy:

https://naiconline.sharepoint.com/teams/FRSRBC/PRBC/2018%20Calls%20-%20PRBC/PCRBC/06_14/attC01_Growth%20Risk%20Referral%20to%20Academy.pdf

Referral from Operational Risk Subgroup1) Sent a referral to the Academy on 6/14/18 conference call.1/25/2018
P4P&C RBC WG12027 Summer Meeting or laterContinue working with the Academy to review the methodology and revise the underwriting (Investment Income Adjustment, Loss Concentration, LOB UW risk) charges in the PRBC formula as appropriate.  

11/16/23 The Academy provided a presentation on their Underwriting Risk Report at the Joint PCRBC And Cat Risk SG meeting.

3/17/23 Proposal 2024-11-P was exposed for a 30-day public comment period during the Spring National Meeting.

4/25/24 Proposal 2024-11-P was adopted during the PCRBCWG interim meeting.

11/12/25 The Academy provided a presentation on loss concentration factors report at the Joint PCRBC and Cat Risk SG meeting.

6/10/2019
P5P&C RBC WG12027 Summer Meeting or laterEvaluate the Underwriting Risk Line 1 Factors in the P/C formula.  7/30/2020
P6Cat Risk SG12026 Summer MeetingQuantify the R5 Ex-cat Factors for wildfire peril to determine the R5 excluding the wildfire peril in addition to earthquake, and hurricane.3/21/2023
P7Cat Risk SG22026 Fall Meeting

Consider:

  1. further investigating all geographic concentration related issues.

    possibly modifying the property and casualty (P/C) risk-based capital formulas

 6/10/24 Exposed a referral from the Tas Force for a 30-day comment period ending July 10. 
New Items – P&C RBC
P8Cat Risk SG12026 Summer MeetingEvaluate the possibility of adding Wildfire peril in the Rcat component 11/12/25 Proposal 2025-20-CR was exposed for a 60-day comment period ending 1/11/26. 
P9Cat Risk SG12026 Summer MeetingEvaluate the possibility of separating earthquake and hurricane loss experience data in PR100s. 11/12/25 Proposal 2025-19-CR was exposed for a 60-day comment period ending 1/11/26. 
P10P&C RBC WG12026 Summer MeetingEvaluate the possibility of updating the Loss and Premium concentration factors in PR017 and PR018   
2026 #Owner2026 PriorityExpected Completion DateWorking Agenda ItemSourceCommentsDate Added to Agenda
Ongoing Items – Health RBC
X1Health RBC WGYearlyYearlyEvaluate the yield of the 6-month U.S. Treasury Bond as of Jan. 1 each year to determine if further modification to the Comprehensive Medical, Medicare Supplement and Dental and Vision underwriting risk factors is required. Any adjustments will be rounded up to the nearest 0.5%.HRBCWG



 

Adopted 2024-09-CA (YE-2024)

11/4/2021
X2Health RBC WG3











 
Ongoing








 
Continue to monitor the Federal Health Care Law or any other development of federal level programs and actions (e.g., state reinsurance programs, association health plans, mandated benefits, and cross-border) for future changes that may have an impact on the Health RBC Formula.4/13/2010 CATF CallAdopted 2014-01H
Adopted 2014-02H
Adopted 2014-05H
Adopted 2014-06H
Adopted 2014-24H
Adopted 2014-25H
Adopted 2016-01-H
Adopted 2017-09-CA
Adopted 2017-10-H
The Working Group will continually evaluate any changes to the health formula because of ongoing federal discussions and legislation.

Discuss and monitor the development of federal level programs and the potential impact on the HRBC formula.














1/11/2018
Carryover Items Currently being Addressed – Health RBC
X3Health RBC WG2Year-End 2026 RBC or LaterConsider changes for stop-loss insurance or reinsurance.AAA Report at Dec. 2006 Meeting

(Based on Academy report expected to be received at YE-2016)
2016-17-CA

Adopted proposal 2023-01-CA

 
X4Health RBC WG1Year-end 2026 RBC or later

Change the Structure of page XR013, PR020, and LR020 to align with the lines of business found on Page 7 Analysis of Operations.

Add separate line to separate the Investment Income Adjustment from the factors

HRBCWGSeparation of H-2 Underwriting Review9/29/25
X5Health RBC WG1Year-End 2026 or later

Expand Exhibit 7 to include new modes of Managed Care Business

Expand to collect data by line of business found on Page 7 Analysis of Operations

HRBCWGSeparation of H-2 Underwriting Review9/29/25
X6Health RBC WG1Year-End 2027 or laterDevelop implementation of updated factors for pages XR013, PR020, and LR020.HRBCWGSeparation of H-2 Underwriting Review9/29/2050
X7Health RBC WG3Year-End 2025 or laterDiscuss and determine the re-evaluation of the bond factors for the 20 designations.Referral from Investment RBC July/2020Working Group will use two- and five-year time horizon factors in 2020 impact analysis. Proposal 2021-09-H - Adopted 5/25/21 by the WG9/11/2020
New Items – Health RBC
X8Health RBC WG2Year-End 2027 or laterDiscuss incorporating designations for non-bond debt on schedule BA resulting from the adoption of the principle-based bond definition.Referral from SAP WGWG will review 2025 filings to determine prevalence4/30/25
X9Health RBC WG3Year-End 2028 or laterAnalyze long-term care insurance (LTCI) underwriting performance to create a more nuanced set of risk factors that consider pricing changes over time.HRBCWG 4/30/25
2026 #Owner2026 PriorityExpected Completion DateWorking Agenda ItemSourceCommentsDate Added to Agenda
Ongoing Items – Task Force
CA1  OngoingUpdate RBC as deemed necessary upon changes adopted by other Working Groups.   
CA2CADTF3OngoingReceivable for Securities factor Consider evaluating the factor every 3 years. 
(2024, 2027, 2030 etc.)

 
 
CA3CADTF1OngoingUpdate the annual investment income adjustment to the comprehensive medical, medicare supplement, and dental and vision factors.HRBC WG6/30/25 – the TF adopted the proposal.4/30/2024
CA4CADTF22026 or laterEvaluate if changes should be made in the RBC formula to reflect the  possible changes in Schedule BA Collateral Loan reporting, including structural changes to RBC blanks and forecasting and changes of risk charges that commensurate with underlying collateral type.SAP WG

1/23/24 – the TF received a referral from SAPWG regarding collateral loan reporting changes

3/26/24 – the TF exposed this referral for a 45-day public comment period.

6/28/24 – the SAPWG provided updates on this project.

10/14/24 – the SAPWG provide another referral to the Task Force.

3/25/25 – the SAPWG provide another update at the Spring Meeting.

6/30/25 – the TF exposed another referral from SAPWG for a 45-day public comment period.

1/23/2024
CA5CADTF2PendingReview the RBC Preamble to determine whether additional modification is required to clarify and emphasize the purposes and intent of using RBC.RBC Purposes & Guidelines Ad Hoc Subgroup

5/15/25 – TF discussed received comments.

10/31/25 – pending until further direction from MOGO

4/30/2024
CA6CADTF22025 or laterEvaluate if changes should be made in the RBC formula to reflect the possible changes in the existing low-income housing tax credit investment lines in the RBC formulas to allow the expansion of including any type of state or federal tax credit program,SAPWG

4/30/24 – the referral was exposed for a 30-day public comment period.

6/28/24 – the SAPWG provided updates on this project.

11/18/24 – TF exposed proposal 2024-26-CA for a 75-day public comment period.

3/25/25 – TF re-exposed proposal for a 30-day public comment period.

5/15/25 – TF adopted Proposal 2024-26-CA

4/30/2024
Carryover Items Currently being Addressed – Task Force
        
New Items –Task Force
CA7CADTF12025Evaluate if expanding the instructions for LR034, LR035, PR033, PR034, and XR027 to facilitate consistent labeling of various company action levels across lines of business. 

3/25/25 – TF exposed proposal for a 30-day public comment period.

5/15/25 – TF adopted proposal 2025-07-CA MOD.