Capital Adequacy (E) Task Force Working Agenda (Revised June 2024)
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2026 # |
Owner |
2026 Priority |
Expected Completion Date |
Working Agenda Item |
Source |
Comments |
Date Added to Agenda |
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Ongoing Items – Life RBC |
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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. | |||
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L2 |
Life RBC WG |
1 |
2026 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 | |
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L3 |
Life RBC WG |
1 |
2026 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 Jersey |
Being addressed by the Longevity (E/A) Subgroup | |
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L4 |
Life RBC WG |
1 |
2026 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 |
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Being addressed by the Generator of Economic Scenarios (GOES) (E/A) Subgroup | |
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Carryover Items Currently being Addressed – Life RBC |
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L5 |
Life RBC WG |
1 |
2027 or later |
Update C3 Phase I to modernize the cash-flow testing methodology and revise the scope to include FIAs. |
AAA |
Being addressed by the American Academy of Actuaries | |
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L6 |
Life RBC WG |
1 |
2026 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. | |||
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L7
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Life RBC WG |
2 |
2026 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 | 12/2/23 - received CADTF referral for Negative Interest Maintenance Reserve (IMR). | |
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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 Structures | SAPWG 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 |
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L9 |
Life RBC WG |
2 |
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-L | SAPWG 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 |
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New Items – Life RBC |
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2026 # |
Owner |
2026 Priority |
Expected Completion Date |
Working Agenda Item |
Source |
Comments |
Date Added to Agenda |
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Ongoing Items – RBC IR & E |
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Carryover Items Currently being Addressed – RBC IR &E |
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IR1 |
RBC IRE |
2 |
2026 or later |
Supplemental 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
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IR2 |
RBC IRE |
2 |
2026 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 |
1/12/2022
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IR3 |
RBC IRE |
2 |
2026 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. |
1/12/2022
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IR4 |
RBCIRE |
1 |
2026 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 |
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IR5 |
RBC IRE |
1 |
2026 or later |
Evaluate the appropriate RBC treatment of Residual Tranches.
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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)
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1/12/2022 |
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IR6 |
RBC IRE |
1 |
2026 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.
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1/12/2022
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IR7 |
RBC IRE |
2 |
2026 or later |
Evaluate asset concentration related issues and the potential changes to the risk-based capital formulas to address the risk. |
Referral from CADTF |
4/30/24 – Task Force referred to the Working Group. |
10/22/2024 |
New Items – RBC IR &E
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2026 # |
Owner |
2026 Priority |
Expected Completion Date |
Working Agenda Item |
Source |
Comments |
Date Added to Agenda |
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Ongoing Items – P&C RBC |
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P1 |
Cat Risk SG |
1 |
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Continue development of RBC formula revisions to include a risk charge based on catastrophe model output: |
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Year-end 2027 or later |
a) Evaluate other catastrophe risks for possible inclusion in the charge |
Referral from the Climate and Resiliency Task Force. March 2021 |
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4/26/2021 |
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P2 |
PCRBCWG |
1 |
Ongoing |
Review and analyze the P/C RBC charges that have not been reviewed since developed. |
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3/23/2023 |
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Carryover Items Currently being Addressed – P&C RBC |
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P3 |
P&C RBC WG |
2 |
Year-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:
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Referral from Operational Risk Subgroup |
1) Sent a referral to the Academy on 6/14/18 conference call. |
1/25/2018 |
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P4 |
P&C RBC WG |
1 |
2027 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. |
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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 |
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P5 |
P&C RBC WG |
1 |
2027 Summer Meeting or later |
Evaluate the Underwriting Risk Line 1 Factors in the P/C formula. |
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7/30/2020 |
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P6 |
Cat Risk SG |
1 |
2026 Summer Meeting |
Quantify the R5 Ex-cat Factors for wildfire peril to determine the R5 excluding the wildfire peril in addition to earthquake, and hurricane. |
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3/21/2023 |
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P7 |
Cat Risk SG |
2 |
2026 Fall Meeting |
Consider:
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6/10/24 Exposed a referral from the Tas Force for a 30-day comment period ending July 10. |
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New Items – P&C RBC |
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P8 |
Cat Risk SG |
1 |
2026 Summer Meeting |
Evaluate 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. | ||
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P9 |
Cat Risk SG |
1 |
2026 Summer Meeting |
Evaluate 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. | ||
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P10 |
P&C RBC WG |
1 |
2026 Summer Meeting |
Evaluate the possibility of updating the Loss and Premium concentration factors in PR017 and PR018 | |||
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2026 # |
Owner |
2026 Priority |
Expected Completion Date |
Working Agenda Item |
Source |
Comments |
Date Added to Agenda |
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Ongoing Items – Health RBC |
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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 |
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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 |
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Carryover Items Currently being Addressed – Health RBC |
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X3 |
Health RBC WG |
2 |
Year-End 2026 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) Adopted proposal 2023-01-CA |
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X4 |
Health RBC WG |
1 |
Year-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 |
HRBCWG |
Separation of H-2 Underwriting Review |
9/29/25 |
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X5 |
Health RBC WG |
1 |
Year-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 |
HRBCWG |
Separation of H-2 Underwriting Review |
9/29/25 |
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X6 |
Health RBC WG |
1 |
Year-End 2027 or later |
Develop implementation of updated factors for pages XR013, PR020, and LR020. |
HRBCWG |
Separation of H-2 Underwriting Review |
9/29/2050 |
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X7 |
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 |
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New Items – Health RBC |
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X8 |
Health RBC WG |
2 |
Year-End 2027 or later |
Discuss incorporating designations for non-bond debt on schedule BA resulting from the adoption of the principle-based bond definition. |
Referral from SAP WG |
WG will review 2025 filings to determine prevalence |
4/30/25 |
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X9 |
Health RBC WG |
3 |
Year-End 2028 or later |
Analyze long-term care insurance (LTCI) underwriting performance to create a more nuanced set of risk factors that consider pricing changes over time. |
HRBCWG |
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4/30/25 |
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2026 # |
Owner |
2026 Priority |
Expected Completion Date |
Working Agenda Item |
Source |
Comments |
Date Added to Agenda |
|
Ongoing Items – Task Force |
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CA1 |
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Ongoing |
Update RBC as deemed necessary upon changes adopted by other Working Groups. | |||
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CA2 |
CADTF |
3 |
Ongoing |
Receivable for Securities factor | Consider evaluating the factor every 3 years. (2024, 2027, 2030 etc.) |
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CA3 |
CADTF |
1 |
Ongoing |
Update the annual investment income adjustment to the comprehensive medical, medicare supplement, and dental and vision factors. | HRBC WG | 6/30/25 – the TF adopted the proposal. | 4/30/2024 |
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CA4 |
CADTF |
2 |
2026 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. | 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 |
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CA5 |
CADTF |
2 |
Pending |
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 |
5/15/25 – TF discussed received comments. 10/31/25 – pending until further direction from MOGO |
4/30/2024 |
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CA6 |
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 – 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 |
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Carryover Items Currently being Addressed – Task Force |
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New Items –Task Force |
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CA7 |
CADTF |
1 |
2025 |
Evaluate 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. |
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