NAIC EXPOSURE DOCUMENT INDEX
The following is a list of documents exposed by various work groups of the NAIC to the public. For additional information regarding these and other documents, their comment periods and pending actions – please visit the appropriate Committees & Activities page.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
RBO Principles
RBO Consumer Notices Principles
Comments due to Eric King by Monday, Nov. 9, 2020.
There are no exposure drafts at this time.
Comments due to Todd Sells by COB Oct. 5, 2020
Liquidity Assessment Subgroup Revised Model 440 - Sept 1 Draft for Referral
Comments due to Tim Nauheimer and Todd Sells by COB Feb. 10, 2020
Liquidity Stress Test Framework Draft
See Financial Stability (EX) Task Force page for Liquidity Stress Test Framework Draft Exposure Document
Draft Revised UTPA Amended Language Addressing Rebating 10/30/20
Comments regarding the revised proposed amendments should be submitted to Denise Matthews by Wed., Nov. 18, 2020.
Draft Revised UTPA Amended Language Addressing Rebating 8/10/20
Comments regarding the revised proposed amendments should be submitted to Denise Matthews by Aug. 28, 2020.
AI Principles as Adopted by AIWG 7/1/20
Comments due to Denise Matthews by July 20, 2020.
Draft UTPA Amended Language Addressing Rebating 6/23/20
Comments regarding the proposed amendments should be submitted to Denise Matthews by July 15, 2020.
ND Draft Anti-Rebating Bulletin 11/25/19
ND Draft Anti-Rebating Bulletin 10/4/19
ND Anti-Rebating Guideline 7/23/19
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
3-14-20 #245 Draft Revisions (based on 3-13-20 Conference call)
Draft Model #275 Revisions FAQ Implementation Document, Draft Dated Sept. 4 Draft FAQ
Comments on the substance of the attached Sample Policy Overviews are requested by August 28.
Comments received:
The following documents are being exposed for a public comment period ending January 31st, 2021.
Please send comments to Reggie Mazyck by close of business on January 31st, 2021.
The following document is being exposed for a 60-day public comment period.
Please send comments to Reggie Mazyck by close of business on Feb 4, 2021.
The following document is being exposed for a 30-day public comment period.
Please send comments to Reggie Mazyck by close of business on Dec. 11, 2020.
Past Exposures:
Amendment Proposal 2019-56 Revisions to VM-51 Data Elements for AUW – Comments due to Reggie Mazyck by October 7, 2019.
APF 2019-56 Revised Data Elements VM51 (Word)
Appendix- VM51 Data Elements markup simple (Word)
Please note that a version of 2019-56 reflecting the potential adoption of edits to amendment 2018-59 will be posted when it becomes available.
There are no exposure drafts at this time.
Comments received on Jan. 28 exposure of revisions to AG49:
Academy Comments
ACLI Comments
Allianz Comments
Global Atlantic AG49 Draft
Global Atlantic Comments
Independent Proposal Comments
IUL Coalition Comments
IUL Coalition AG49 Redline
Securian/Nationwide/Penn Mutual/Prudential/Mutual of Omaha Comments
Vincent Tsang Comments
Please provide comment on the options presented on the January 28, 2020 Subgroup call (and included in the call materials) related to the Supplemental Option Budget. Comments which provide pros and cons of either option, provide an additional option, or include proposed draft revisions to Actuarial Guideline 49 would be appreciated.
Submit comments to Reggie Mazyck by Feb. 14.
The VM-22 (A) Subgroup is exposing the Academy Annuity Reserves Work Group (ARWG) presentation on the Preliminary Framework Elements for Fixed Annuity PBR for a 45-day public comment period ending Dec. 14.
Please submit comments to Reggie Mazyck (RMazyck@naic.org) by close of business Dec.14.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
QTL Template.xlsx Pennsylvania Revised Draft QTL Template Draft May 28, 2020
QTL Template Instructions.docx Revised Draft QTL Template Instructions May 28, 2020
MHPAEA assumptions exposure.docx MHPAEA Draft Assumptions March 10, 2020
There are no exposure drafts at this time.
PBM Model Draft PBM Model Act Draft Date Oct. 29, 2020
ERISA Handbook OCTOBER 11, 2018 Draft
Comments requested by October 26, 2018
ERISA Handbook Draft Revisions 7-20-18 (footnotes corrected 8/16/18)
Comments requested by 9-28-18
HMO Model Draft Adopted by the Subgroup, July 13, 2020
PBM Model Draft Draft Dated Oct. 29, 2020
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no current exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
None at this time.
The posted revisions to the Conducting the Health Examination chapter were adopted by the Working Group on its November 19, 2020 call.
New Draft Long-Term Care Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
The Long-Term Care In Force and Long-Term Care Claims SDRs were adopted by the Working Group on its November 19, 2020 call.
New Inland Marine Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
The Inland Marine In Force and Inland Marine Claims SDRs were adopted by the Working Group on its July 23, 2020 call.
The Limited Long-Term Care Exam Standards, Dec. 11, 2019 draft, were adopted by the Working Group on its July 23, 2020 call.
New Farmowners Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
The Farmowners In Force SDR and Farmowners Claims SDR were adopted by the Working Group on its Dec. 18, 2019 call, and adopted by the Market Regulation and Consumer Affairs (D) Committee on its July 27, 2020 call.
Cybersecurity (EX) Task Force Referral to Market Conduct Examination Standards (D) Working Group
The following items have been tabled by the Working Group until further notice.
Draft New Health Reform Market Conduct Examination Standards for Nondiscrimination for inclusion in the Market Regulation Handbook
Aug. 10, 2015 Draft
Draft New Health Reform Market Conduct Examination Standards for Nondiscrimination for inclusion in the Market Regulation Handbook
Aug. 3, 2015 Draft
Section D. Standards of Chapter 14-Sampling of the Market Regulation Handbook 9/18/14
On October 29, 2020 the Antifraud Technology (D) Working Group completed their review and adopted revisions to the NAIC Antifraud Plan Guideline (#1690). The focus was to reorganize the guidelines into a more intuitive order, to eliminate repetitive requirements within the existing guidelines, and add suggestions to better meet existing requirements for nearly all states.
The Antifraud (D) Task Force is soliciting comments on the revisions with a deadline of Thursday, November 12, 2020. Comments/suggestions can be sent to Greg Welker gwelker@naic.org
The track changes draft, and the track changes accepted draft adopted by the Working Group can be found below.
- NAIC Antifraud Guideline Plan - Clean - Adopted by the ATWG 10.29.20
- NAIC Antifraud Guideline Plan - Track Changes - Adopted by the ATWG 10.29.20
The Antifraud (D) Task Force will potentially adopt the revisions to the Antifraud Plan Guideline (#1690) on its November 16, 2020 - Open Webex Meeting.
The Antifraud Technology (D) Working Group has been reviewing the 2011 NAIC Antifraud Plan Guideline for potential revisions. The focus has been to reorganize the guidelines into a more intuitive order, to eliminate repetitive requirements within the existing guidelines, and add suggestions to better meet existing requirements for nearly all states.
In order to finalize the review of the NAIC Antifraud Plan Guideline the Working Group will be holding conference calls through October. The dates for the scheduled conference calls are listed below.
Conference Call Schedule:
- Thursday, September 17th - 9am Alaska/10am Pacific/11am Mountain/12pm Central/1pm Eastern
- Wednesday, October 14th - 9am Alaska/10am Pacific/11am Mountain/12pm Central/1pm Eastern
- Thursday, October 29th - 9am Alaska/10am Pacific/11am Mountain/12pm Central/1pm Eastern
Comments Received by January 5, 2020
- MN DOI - 1.2.20
- Center For Economic Justice - 3.12.20
- Coalition Against Insurance Fraud - 12.26.20
- NAMIC - 1.11.20
- NICB - 12.26.20
Comments Received by September 8, 2020 (Draft 3 8.3.20)
- AIG - 9.5.20
- Center For Economic Justice - 9.8.20
- Coalition Against Insurance Fraud - 9.8.20
- All Comments Compiled - 9.16.20
Guideline Drafts
- NAIC 2011 Antifraud Plan Guideline - Draft 2 W/Track Changes 3.12.20)
- NAIC 2011 Antifraud Plan Guideline - Draft 3 Redline (8.3.20) / NAIC 2011 Antifraud Plan Guideline - Draft 3 - Clean (8.3.20)
- NAIC 2011 Antifraud Plan Guideline - Draft 4 - Redline (10.14.20) / NAIC 2011 Antifraud Plan Guideline - Draft 4 - Clean (10.14.20)
There are no exposure drafts at this time.
There are no exposure drafts at this time.
State Licensing Handbook Review
In 2019 the Producer Licensing Uniformity (D) Working Group was given the charge to review the State Licensing Handbook. The Working Group split out the review process into sections consisting of five chapters for each review period. The comments received and the redline chapters can be found attached below. The Handbook will be presented to the Executive Committee for final adoption at the Summer National Meeting.
COMMENTS RECEIVED:
- No comments at this time.
REDLINED CHAPTERS:
NAIC Uniform Application
The NAIC Uniform Applications were adopted by the Market Regulation and Consumer Affairs (D) Committee at the 2018 NAIC Summer National Meeting. At this time the applications have not been presented to the NAIC Executive Committee pending an additional review and discussion of the revisions.
Continuing Education Reciprocity Agreement
In 2019 the Working Group reviewed the Continuing Education Reciprocity (CER) Agreement. The NAIC's General Counsel advised the Working Group that a revision of the agreement would not be feasible due to the date of the CER Agreement and inaccurate/dated information it contains. The decision was to create a new CER Agreement. During the Fall National Meeting the Producer Licensing (D) Task Force adopted the 2019 CER Agreement. The agreement will be presented to the Executive Committee during the Summer National Meeting for final adoption. The adopted draft is attached below.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
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There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
Blanks (E) Working Group
Items Received for Comment
Last Updated December 16, 2020
Please address comment letters to Jacob Garn, Chair of the Blanks (E) Working Group, and direct to Mary Caswell and Calvin Ferguson.
| Ref. No. | Description | Comment Deadline |
| 2020-32BWG | Add a new Health Care Receivables Supplement to the Life/Fraternal Annual Statement that adds Exhibits 3 and 3A from the Health Annual Statement to the Life/Fraternal annual filings. Add a guidance document reference to Exhibit 3A of the Health Annual Statement. | 2/16/2021 |
| 2020-33BWG | Modify Annual Statement Lines (ASLs) used on Underwriting and Investment (U&I) Exhibits, State Page and Insurance Expense Exhibit (IEE). Change Health ASL categories used in Property to be consistent with other statement types. Update ASL references used in crosschecks. Update definitions used in the appendix for the Health ASLs. | 2/16/2021 |
| 2020-34BWG | Add definitions for the Occupational Accident, Fiduciary Liability, Premises and Operations (OL&T and M&C), Professional Errors and Omissions Liability, Kidnap & Ransom Liability and Tuition Reimbursement Plans products to the appropriate line of business in the appendix. | 2/16/2021 |
| 2020-35BWG | Expand the number of characters used from 7 to 10 in the investment line categories for Schedules D, DA, DL and E excluding Schedule D, Part 6 (Sections 1 and 2) and Schedule E (Part 1 and 3). Add line categories for Unaffiliated Certificates of Deposit and Exchange Traded Funds. Split the line categories for Mutual Funds, Investment Unit Trusts and Closed-End Funds into lines indicating if the fund has been assigned a designation by the Securities Valuation Office (SVO). Make changes to Summary Investment Schedule, Summary by Country and Schedule D, Part 1A (Sections 1 and 2) to reflect the additional line categories. | 2/16/2021 |
| 2020-36BWG |
Modify the General Schedules Investment Instructions and Schedule DB General Instructions to reflect treatment of publicly traded stock warrants as being in the scope of SSAP No. 30R—Unaffiliated Common Stock or SSAP No. 32R—Preferred Stock and reporting as common and preferred stock (SAPWG Ref #2020-33). |
2/16/2021 |
| 2020-37BWG |
Add a new Schedule Y, Part 3 to capture all entities with ownership greater than 10%, the ultimate controlling parties of those owners and other entities that the ultimate controlling party controls (SAPWG Ref #2020-34). |
2/16/2021 |
| 2020-38BWG |
Make changes to the Accident and Health Policy Experience Exhibit by adding new columns, removing lines distinguishing with and without contract reserves, adding some new product lines, eliminating summary tables, changing the date that the exhibit is due and having it reported by state. |
2/16/2021 |
Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated 12/18/2020
Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to Julie Gann, Robin Marcotte, Jim Pinegar, Fatima Sediqzad and Jake Stultz.
For the status of all SAPWG agenda items, please refer to the Maintenance Agenda.
| EXPOSURES with COMMENT DEADLINE of FEBRUARY 26, 2021 | |||
|---|---|---|---|
| 2020-36 |
SSAP No. 86 SSAP No. 108 |
Derivatives Hedging Fixed Indexed Products | Exposed agenda item to solicit comments from state insurance regulators and industry on establishing accounting and reporting guidance for derivatives hedging the growth in interest for fixed indexed annuity products. A notification of the exposure will be sent to the Life Actuarial (A) Task Force. |
| EXPOSURES with COMMENT DEADLINE of JANUARY 22, 2021 | |||
| INT 20-03 | SSAP No. 36 | Troubled Debt Restructuring Due to COVID -19 |
In response to the extension of the CARES Act, this exposure proposes a similar extension of INT 20-03; i.e., until the earlier of Jan. 1, 2022, or 60 days after the national emergency regarding COVID-19 terminates. As originally adopted, this interpretation clarifies that a modification of mortgage loan or bank loan terms in response to COVID-19 shall follow the provisions detailed in the April 7, 2020, “Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus,” and the provisions of the CARES Act in determining whether the modification shall be reported as a troubled debt restructuring. |
| INT 20-07 |
SSAP No. 26R SSAP No. 36 SSAP No. 43R SSAP No. 103R |
Troubled Debt Restructuring of Certain Instruments Due to COVID-19 |
In response to the extension of the CARES Act, this exposure proposes a similar extension of INT 20-07; i.e., until the earlier of Jan. 1, 2022, or 60 days after the national emergency regarding COVID-19 terminates. As originally adopted, this interpretation provides practical expedients in assessing whether modifications in response to COVID-19 are insignificant under SSAP No. 36—Troubled Debt Restructuring and in assessing whether an exchange is substantive under SSAP No. 103R—Transfers and Servicing of Financial Assets and Extinguishments of Liabilities. |
| 2019-24 | SSAP No. 71 | Levelized and Persistency Commission | Exposed previously exposed nonsubstantive revisions with minor clarifications noting that the revisions shall apply to contracts in effect on the date of adoption. Revisions distinguish traditional persistency commission from a funding agreement. The Statutory Accounting Principles (E) Working Group directed NAIC staff to draft an issue paper documenting the discussion. |
| 2019-34 | SSAP No. 25 | Related Parties, Disclaimer of Affiliation and Variable Interest Entities | Revisions clarify the identification of related parties, with changes from the prior exposure to reflect discussions with interested parties. The revisions also include a new disclosure recommended by the Group Solvency Issues (E) Working Group. |
| 2020-22 | SSAP No. 26R | Accounting for Perpetual Bonds | Revisions clarify that perpetual bonds with a call feature shall apply the yield-to-worst concept and be reported at amortized cost. Fair value is required for all other perpetual bonds. |
| 2020-32 | SSAP No. 26R | Disclosure Update | Revisions expand the disclosures for called bond to also include bonds terminated through a tender offer. |
| 2020-33 | SSAP No. 32R | Publicly Traded Preferred Stock Warrants | Revisions capture publicly-traded preferred stock warrants within scope of SSAP No. 32R and require fair value reporting. |
| 2020-34 | SSAP No. 43R | GSE CRT Program | Revisions incorporate minor scope modifications allowing Freddie Mac Structured Agency Credit Risk (STACR) and Fannie Mae Connecticut Avenue Securities (CAS) issued through a Real Estate Mortgage Investment Conduit (REMIC) structure.to remain in scope of SSAP No. 43R. |
| 2020-35 | SSAP No. 97 | SSAP No. 97 – Audit Opinions | Exposed agenda item with a request for comments on the extent to which situations exist that hinder the admittance of paragraph 8.b.iii. entities (U.S. and foreign noninsurance U.S. GAAP basis SCAs) due to the inability to quantify the departure from of U.S. GAAP. |
| 2020-37 | SSAP No. 56 | Separate Account Product Mix | Exposed agenda item to solicit comments regarding the degree of product granularity that should be captured in Separate Account general interrogatory 1.01. |
| 2020-38 | SSAP NO. 56 | Pension Risk Transfer Disclosure | Exposed agenda item to solicit comments regarding possible modifications to specifically address pension risk transfers (PRTs), including items such as separate identification transactions, guarantees, reserve assumptions. |
| 2020-39 | Appendix F | Interpretation Policy Statement | Appendix F—Policy Statements: Revisions clarify the issuance and adoption process of accounting interpretations in the NAIC Policy Statement on Maintenance of Statutory Accounting Principles. |
| 2020-40 | Preamble | Prescribed Practices | Revisions clarify that while any state in which a company is licensed can issue prescribed practices, the prescribed practices directed by the domiciliary state shall be reflected in the financial statements filed with the NAIC and are the financial statements subject to independent audit requirements. |
| 2020-41 | SSAP No. 43R | ASU 2020-06, Convertible Instruments | Revisions reject Accounting Standards Update (ASU) 2020-06, Debt—Debt with Conversion and Other Options (Subtopic 470-20) and Derivatives and Hedging—Contracts in Entity’s Own Equity (Subtopic 815-40), Accounting for Convertible Instruments and Contracts in an Entity’s Own Equity, as this ASU primarily addresses various convertible debt valuation models along with bifurcating embedded derivative components, which are not concepts supported under statutory accounting. |
| 2020-42 | Appendix D | ASU 2020-07, Presentation and Disclosures by Not-for-Profit Entities | Revisions reject ASU 2020-07, Presentation and Disclosures by Not-for-Profit Entities as not applicable to statutory accounting. |
| EXPOSURES with COMMENT DEADLINE of DECEMBER 4, 2020 | |||
| 2019-21 |
SSAP No. 43R |
Exposed the Iowa Insurance Division proposal to establish principles on what is intended to be captured on Schedule D-1: Long-Term Bonds. For further clarity, this exposure is not proposing to expand the scope of SSAP No. 26R—Bonds, but rather identify principles of investments that should be captured on Schedule D-1, regardless if the investment is in scope of SSAP No. 26R or SSAP No. 43R. Comments are requested by Dec. 4, 2020. The Iowa proposal is the exposed item. (For reference purposes, the previously exposed issue paper and July 31, 2020 comment letter are also provided as attachments.) | |
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EXPOSURES DEFERRED for SUBSEQUENT INTERIM or NATIONAL MEETING |
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SSAP No. 41R |
Surplus Note Accounting – Referral from the Reinsurance (E) Task Force |
The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent call or meeting. |
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SSAP No. 68 |
ASU 2014-17, Business Combinations, Pushdown Accounting |
The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent call or meeting. |
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SSAP No. 68 SSAP No. 97 |
Attribution of Goodwill | This agenda item addresses attribution and tracking of goodwill when multiple SCAs are purchased. | |
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SSAP No. 62R |
Retroactive Reinsurance Exception |
The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent call or meeting. |
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There are no exposure drafts at this time.
Academy Report to Incorporate Investment Income in UW Risk of Health RBC Formula
Academy Follow-Up on Investment Income in H2
Please send comments to Crystal Brown by the close of business, January 18, 2021.
Comments should be sent electronically to Dave Fleming by COB Wednesday, Oct. 7, 2020.
Exposure on Suggested Edits to the RBC Forms & Instructions for C-2b Longevity Risk
Comments should be sent electronically to Dave Fleming by COB Monday, August 10, 2020.
Exposure Drafts Still Open For Consideration with Comment Received:
- American Academy of Actuaries (AAA) proposed instructions for the C-3 Phase I proposal
- Modified C-3 Phase 3 Scope Proposal
- Comment Letters Received:
- AAA Draft C-3 Instructions and Appendices
- Comment Letters Received:
- AAA September 2009 Report on RBC C3 Requirements for Life Products
Please send any comments on the exposure drafts to Dave Fleming.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The Financial Analysis Solvency Tools (E) Working Group has posted the following document for a 30 day exposure period ending October 23, 2020:
Please submit all comments to Rodney Good (rgood@naic.org) by end of business on October 23, 2020
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no Exposure Drafts at this time.
The Receivership Financial Analysis (E) Working Group (R-FAWG) of the Receivership and Insolvency (E) Task Force (RITF) requests feedback on any recommended best practices for overcoming challenges that states, receivers, and guaranty associations have faced in the administration of a receivership due to the current pandemic and related travel/business restrictions, work-from-home, economic impact, etc.
- Please consider including a description of the following, specific to the administration of receiverships during the pandemic:
- Challenges or issues you’ve faced
- Best practice(s) for overcoming and dealing with the challenge/issue
- Circumstances to avoid or watch for
- Critical planning steps and processes to consider
- Identify any increased cyber security protocols or data security protocols to consider
- Please do not include names of insurance companies, persons or entities. If any part of your feedback/best practices should be for regulators only, please label it as such.
The feedback received is intended to be compiled and made available to serve as a helpful aid as we navigate the receivership process in the current environment.
Please submit feedback to jkoenigsman@naic.org
The Receivership Law Working Group has exposed the following documents:
Please submit comments to Jane Koenigsman by January 22, 2021
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The following document is being exposed for a 60-day public comment period:
Comments should be sent electronically to Charles Therriault and Denise Genao-Rosado by COB Friday, February 5, 2021.
The following documents are being exposed for a 60-day public comment period:
Comments should be sent electronically to Charles Therriault and Denise Genao-Rosado by COB Monday, January 18, 2020.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
During the 2020 Summer National Meeting, the Financial Regulation Standards and Accreditation (F) Committee exposed the following items. Comment letters should be emailed to me at bmeyer@naic.org prior to Friday September 11, 2020.
There are no exposure drafts at this time.
There are no exposure drafts at this time.