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RBC Online Agenda

Capital Adequacy (E) Task Force Working Agenda (Revised December 8, 2023)

2024 #

Owner

2024 Priority

Expected Completion Date

Working Agenda Item

Source

Comments

Date Added to Agenda

Ongoing Items – Life RBC

L1

Life RBC WG

Ongoing

Ongoing

Make 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.

     

L2

Life RBC WG

1

2024 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.

CADTF

Being addressed by the Variable Annuities Capital and Reserve (E/A) Subgroup

 

L3

Life RBC WG

1

2024 or later

Provide recommendations for the appropriate treatment of longevity risk transfers by the updated longevity factors and consider expanding the scope to include all payout annuities.

New Jersey

Being addressed by the Longevity (E/A) Subgroup

 

L4

Life RBC WG

1

2024 or later

Monitor 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

L5

Life RBC WG

1

2024 or later

Update the current C-3 Phase I or C-3 Phase II methodology to include indexed annuities with consideration of contingent deferred annuities as well

AAA

   

L6

Life RBC WG

1

2024 or later

Review 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.

     

New Items – Life RBC

L7 Life RBC WG 1 2024 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.

CADTF    
L8 Life RBC WG 1 2024 or later Develop a structure proposal to reflect the split of the Annual Statement, Schedule D, Part 1 into two schedules pursuant to the SAPWG adopted bond project. CADTF    
L9 Life RBC WG 1 2024 or later Consider SAPWG Referral for Investments in Tax Credit Structures SAPWG    
L10 Life RBC WG 1 2024 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-L      

2024 #

Owner

2024 Priority

Expected Completion Date

Working Agenda Item

Source

Comments

Date Added to Agenda

Ongoing Items – RBC IR & E

               

Carryover Items Currently being Addressed – RBC IR &E

IR1

RBC IRE

2

2024 or later

Supplementary 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

IR2

RBC IRE

2

2024 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

IR3

RBC IRE

2

2024 or later

Structured Notes - defined as an investment that is structured to resemble a debt instrument, where the contractual amount of the instrument to be paid at maturity is at risk for other than the failure of the borrower to pay the contractual amount due. Structured notes reflect derivative instruments (i.e., put option or forward contract) that are wrapped by a debt structure.

Referred from CADTF
Referral from SAPWG
April 16, 2019

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

8/4/2019

IR4

RBC IRE

2

2024 or later

Comprehensive 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

New Items – RBC IR & E

IR5

   

2024 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).

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.

1/12/2022

IR6

   

2024 or later

Evaluate 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.

1/12/2022

IR7

   

2025 or later

Phase 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 Committee

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

1/12/2022

IR8

RBC IRE

 

2024 or later

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

Referral from the Macroprudential (E) Working Group

 

8/11/2022

IR9 RBC IRE   2024 or later Develop a structure proposal to reflect the split of the Annual Statement, Schedule D, Part 1 into two schedules pursuant to the SAPWG adopted bond project for all lines of business. CADTF    

2024 #

Owner

2024 Priority

Expected Completion Date

Working Agenda Item

Source

Comments

Date Added to Agenda

Ongoing Items – P&C RBC

 

Cat Risk SG

1

 

Continue development of RBC formula revisions to include a risk charge based on catastrophe model output:

     

Year-end 2024 or later

a) 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

03/17/24 Proposal 2023-15-CR was adopted by the Subgroup, Working Group, and the Task Force during the Spring National Meeting

4/23/24 Proposal 2023-17-CR was adopted during April 23 interim Cat Risk SG meeting.

4/25/24 Proposal was adopted during the April 25 PCRBC WG interim meeting..

4/26/2021

P2

PCRBCWG

1

Ongoing

Review 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

P3

P&C RBC WG

1

Year-end 2025 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 from Operational Risk Subgroup

1) Sent a referral to the Academy on 6/14/18 conference call.

1/25/2018

P4

P&C RBC WG

1

2024 Summer Meeting or later

Continue 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.

6/10/2019

P5

P&C RBC WG

1

2025 Summer Meeting or later

Evaluate the Underwriting Risk Line 1 Factors in the P/C formula.

   

7/30/2020

P6

Cat Risk SG

1

2025 Spring Meeting

Quantify the R5 Ex-cat Factors for wildfire peril (for informational purposes only)
Evaluate the possibility of adding PR018A to determine the R5 excluding the wildfire peril in additional to earthquake, and hurricane.

   

3/21/2023

P7

Cat Risk SG

2

2025 Spring Meeting

Evaluate the impact of flood peril to the insurance market

   

3/21/2023

P8

PCRBCWG

1

2024 Spring Meeting

Adding pet insurance line in the RBC PR017, 018, 035 and RBC Schedule P, parts due to the adoption of the Annual Statement Blanks proposal 2023-01BWG.

 

3/17/24 Proposal 2023-14-P was adopted by the Subgroup, Working Group, and the Task Force during the Spring National Meeting

7/27/2023

New Items – P&C RBC

P9

Cat Risk SG

1

2024 Summer Meeting

Create a new disclosure to collect more information of insurers catastrophe reinsurance programs.

Referral from Reinsurance (E) Task Force

3/17/24 Proposal 2023-13-CR was adopted by the Subgroup, Working Group, and the Task Force during the Spring National Meeting.

2/20/2024

P10

PCRBCWG

1

2024 Summer Meeting

Update PR019, Line 25 Annual Statement Source and the Statement Value to avoid double-counting on Stop-Loss premium.

 

3/17/24 Proposal 2024-10-P was exposed for a 30-day public comment period during the Spring National Meeting.

4/25/24 Proposal was adopted during 4/25 PCRBCWG interim meeting.

2/20/2024

P11

Cat Risk SG

1

2024 Summer Meeting

Create additional Rcat pages to collect commercial Cat modelers product information known as “Climate Conditioned Catalogs”, which would provide an estimate of climate change for hurricane and wildfire.

From Solvency Workstream of the Climate & Resiliency (EX) Task Force

1/29/24 Proposal 2023-17-CR was exposed for a 30-day public comment period at the Cat Risk SG Interim Meeting on Jan. 29.

3/17/24 Proposal 2024-10-P was re-exposed for a 22-day public comment period during the Spring National Meeting.

1/29/2024

P12

PCRBCWG

1

2024 Spring Meeting

Change the RBC Schedule P short-tail lines to vendor link, which will pull directly from the Annual Statement, Schedule P short-tail lines as the adopted blanks proposal 2023-16BWG modified the Schedule P short-tail lines to show 10 years of data beginning in 2024.

 

2/21/24 Blanks Proposal 2023-16BWG was adopted at the BWG meeting

3/17/24 Proposal 2024-01-P was adopted by the Subgroup, Working Group, and the Task Force during the Spring National Meeting.

 
P13 Cat Risk SG 2 2025 Fall Meting

Consider:

  1. further investigating all geographic concentration related issues. possibly modifying the property and casualty (P/C) risk-based capital formula
  6/10/24 Exposed a referral from the Tas Force for a 30-day comment period ending July 10.  

2024 #

Owner

2024 Priority

Expected Completion Date

Working Agenda Item

Source

Comments

Date Added to Agenda

Ongoing Items – Health RBC

X1

Health RBC WG

Yearly

Yearly

Evaluate 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

X2

Health RBC WG

3

 

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 Call

Adopted 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

X3

Health RBC WG

2

Year-End 2025 RBC or Later

Consider 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

 

X4

Health RBC WG

1

Year-end 2025 RBC or later

Work with the Academy to perform a comprehensive review of the H2 - Underwriting Risk component of the health RBC formula including the Managed Care Credit review

Review the Managed Care Credit calculation in the health RBC formula - specifically Category 2a and 2b.

Review Managed Care Credit across formulas.

As part of the H2 - Underwriting Risk review, determine if other lines of business should include investment income and how investment income would be incorporated into the existing lines if there are changes to the structure.

HRBCWG

Review the Managed Care Category and the credit calculated, more specifically the credit calculated when moving from Category 0 & 1 to 2a and 2b.

4/23/2021

12/3/2018

X5

Health RBC WG

3

Year-End 2025 or later

Discuss and determine the re-evaluation of the bond factors for the 20 designations.

Referral from Investment RBC July/2020

Working Group will use two- and five-year time horizon factors in 2020 impact analysis. Proposal 2021-09-H - Adopted 5/25/21 by the WG 

9/11/2020

New Items – Health RBC

               

2024 #

Owner

2024 Priority

Expected Completion Date

Working Agenda Item

Source

Comments

Date Added to Agenda

Ongoing Items – Task Force

CA1

CADTF

2

2023

Affiliated Investment Subsidiaries Referral
Ad Hoc group formed Sept. 2016

Ad Hoc Group

Proposal 2024-08-CA was adopted at the 2024 Spring National Meeting.

Proposal adopted during 4/30 TF interim meeting

 

CA2

   

Ongoing

All investment related items referred to the RBC Investment Risk & Evaluation (E) Working Group

 

 Proposal 2024-02-CA (Residual Structure PC & Health) was exposed for comment ending Mar. 2.

3/17/24 – the TF exposed this proposal for a 30-day public comment period.

4/30/24- the RG adopted this structure proposal.

6/28/24-the TF adopted proposal 2024-18-CA to retain 20% charge for the Total Residual Tranches or Interests.

1/12/2022

CA3

CADTF

3

Ongoing

Receivable for Securities factor

 

Consider evaluating the factor every 3 years.
(2024, 2027, 2030 etc.)

Factors will be exposed for comments in April 2024.

 

Carryover Items Currently being Addressed – Task Force

               

New Items –Task Force

CA4

CADTF

2

Ongoing

Update the annual investment income adjustment to the comprehensive medical, Medicare supplement, and dental and vision factors.

 

4/30/24 – the TF exposed proposal 2024-09-CA for a 30-day public comment period.

6/28/24 – the TF adp[ted the proposal.

4/30/24

CA5

CADTF

2

2025 or later

Evaluate 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.

 

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.

1/23/2024

CA6

CADTF

2

2024 or later

Review the proposal from the ACLI to modify the treatment of repurchase agreements in the Life RBC formula to determine whether its possible application to P/C and Health formulas.

Life RBC WG

1/25/24 – the TF received a referral from LRBCWG. Proposal 2024-06-CA (Repurchase Agreements PC & Health( was exposed for comment ending Mar.2.

3/17/24 – the TF exposed this referral for a 30-day public comment period.

1/25/2024

CA7 CADTF 1 2024 or later

Review the possibility of establishing a new Working Group to evaluate the non-investment risk issues.

  1. Review the possibility of removing the TAC and ACL amounts I the annual statement’s five-year historical data page.
  2. Re-evaluate some of the missing non-investment risks to determine whether the Task Force should include them in the RBC calculation or if it should appropriately handle those risks utilizing other regulatory methods.

Review those non-investment factors and instructions that have not been reviewed since being developed to determine if modifications should be made.

    4/30/24
CA8 CADTF 2 2024 or later Review 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   4/30/24
CA9 CADTF 2 2025 or later Evaluate 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