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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.

Life RBC

WG

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.

2027 or

later

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

2026 or

later

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

6/30/2026 - Collateral Loans proposal 2025-16-L MOD was adopted for 2027 implementation.

L9

Life RBC WG

2

2027 or later

Comment letters – Pac Life and ACLI

INVAWG referral

11/14/2025

05/26/2026

L10

Life RBC WG

1

2027 or later 

In light of the Financial Condition (E) Committee’s directive, the Life Risk-Based Capital (E) Working Group is tasked with developing a reinsurance recapture charge for reinsurance ceded to entities domiciled in non-reciprocal jurisdictions, effective for year-end 2027:

1. A reinsurance recapture RBC factor to be applied to ceded reserves and modified coinsurance balances for all reinsurance located outside of reciprocal jurisdictions while of course considering an overcollateralizing of the reserves in establishing the required RBC. The factor would account for the additional capital that would be required if a ceding company had to recapture those reserves. 
2.  To account for increased credit risk for reinsurers that have lower financial strength ratings, modify the reinsurance methodology used in the life RBC formula for recoverability risk by aligning with the approach used in the property/casualty (P/C) RBC formula.

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.

Proposal 2025-12-IRE SVO Funds Alignment was withdrawn. The Working Group can consider reviewing the edits made in Asset Concentration Page to seek alignment with SIRI.

2026 or later

(Completed)

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

2026 or later

(Completed)

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. 

Proposal 2025-12-IRE SVO Funds Alignment was withdrawn.

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.

Proposal 2026-12-IRE (CLO Factors) was adopted on 6/23/26.

The Working Group is considering refinement of modeling assumptions for CLO C-1 Model, as well as looking to proceed with evaluation of RBC treatment for other ABS asset types.

1/12/2022

8/13/2022

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)

Proposal 2026-12-IRE (CLO Factors) was adopted on 6/23/26. It was concluded that RBC factors for CLO residuals should be retained at 45%.

The Academy is looking into further refinement to CLO modeling assumptions which may impact residual tranche factors.

Per the request of E Committee comments were solicited requesting the need for outside review.

Academy has developed principles to guide/ inform the mapping. The Working Group endorsed the principles during 12/2/2023 Fall National Meeting.

See IR4 for milestones.

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

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.

Consider:

1. further investigating all geographic concentration related issues.

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

2026 Summer Meeting

(Completed)

11/12/25 Proposal 2025-20-CR was exposed for a 60-day comment period ending 1/11/26.

3/24/26 Proposal was adopted by the Task Force.

2026 Summer Meeting

(Completed)

2026 Summer Meeting

(Completed)

P11

Cat Risk SG

1

2026 Fall Meeting

P12

P&C RBC WG

1

2026 Summer Meeting (Completed)

P13

Cat Risk SG

1

2026 Summer Meeting (Completed)

Adopted 2026-03-CA (YE-2026)

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

Adopted proposal 2023-01-CA

Year-end 2026 or later 

(Completed)

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

Separation of H-2 Underwriting Review

Adopted 2025-15-CA Mod 5/15/2026

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

Separation of H-2 Underwriting Review

Adopted 2025-15-CA Mod 5/15/2026

CA4

CADTF

2

2027 or later

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

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

6/30/26 –The TF adopted proposal 2025-16-L MOD to effect changes in Life RBC for collateral loans with effect from YE 2027.

Pending to evaluate for P/C and Health RBC formulas.

CA5

CADTF

2 

(Completed)

5/15/25 – TF discussed received comments.

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

6/30/26 – the TF adopted changes to preamble to be incorporated into RBC publication, starting YE 2026.

CA6

CADTF 

2

2027 or later

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 

CA7

CADTF

1

2027 or later

CA8

CADTF

1

2027