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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.

Proposed Innovation, Cybersecurity and Technology (H) Committee

Final H Committee 2022 Proposed Draft Charges - Clean Version 12/1/21

Final H Committee 2022 Proposed Draft Charges - Redline Version 12/1/21

Comments to the Draft Charges 11/18/21 Revised

Draft Charges 11/2/21

____________________________________________________________________________________________________________

MO880 - 2020 revisions-12042020 as Amended

The below document is exposed for comments until COB January 18, 2024 by the Solvency Workstream of the Climate & Resiliency (EX) Task Force. Please submit comments to Dan Daveline.

LIFE WORKSTREAM 

Feedback requested on Barriers to Access to Life Insurance -- ACLI Letter 

Draft Finanical Literacy Course Endorsement - Comments due April 1, 2024

              Consumer Reps Comments

              ACLI Comments

Draft Financial Wellness Resource Guide -  Comments due April 1, 2024

            Brenda Cude comments

         

Enhanced Cash Surrender Value Offer Survey

 

Annuity Suitability (A) Working Group Adopted FAQ Guidance Document  Adopted FAQ Guidance Document

The following document is being exposed for a 21-day public comment period ending Wednesday, June 5, 2024:

Note the exposure questions included in the cover page.

Please send comments to Jennifer Frasier by close of business on June 5th, 2024.

The following document is being re-exposed for a 14-day public comment period ending Wednesday, May 22, 2024:

Please send comments to Scott O'Neal by close of business on May 22nd, 2024.

The following documents are being exposed for a 21-day public comment period ending Wednesday, May 29, 2024:

Please send comments to Scott O'Neal by close of business on May 29th, 2024.

The following document is being exposed for a 21-day public comment period ending Wednesday, May 22, 2024:

Please send comments to Scott O'Neal by close of business on May 22nd, 2024.

The following document is being re-exposed for a 21-day public comment period ending Wednesday, May 15, 2024:

Please send comments to Scott O'Neal by close of business on May 15th, 2024.

The following document is being exposed for a 30-day public comment period ending Friday, May 3rd, 2024:

Note: Please provide comments on the language in the APF and the exposure questions provided in the cover letter.

Please send comments to Scott O'Neal by close of business on May 3rd, 2024.

The following document is being exposed for a 60-day public comment period ending Friday, May 17th, 2024:

Please send comments to Scott O'Neal by close of business on May 17th, 2024.

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.

The following document is being exposed for a 30-day public comment period ending Thursday, May 9th, 2024:

Additionally, commenters are asked to consider whether more expedient changes to only the mortality and expense assumptions would be desirable (potentially for the 2025 Valuation Manual) or if the entire package (including updated surrender assumptions) should be considered for adoption as it is ready.

Please send comments to Scott O'Neal by close of business on May 9th, 2024.

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.

The attached Amendment Proposal Form to modify Valuation Manual, section VM-26, Section 3.B. Contract Reserves for Credit Disability Insurance proposes to remove the 12% addition to the 1985 CIDA incidence rates for newly issued contracts, since the addition of the 12% constitutes a margin that is no longer needed or justified by experience.

Please provide comments to eking@naic.org by Friday, March 22.

 

The Working Group requests comments on the Minnesota Approach with any suggested adjustments as a candidate for a Single LTCI Multistate Rate Review Approach.  The Minnesota Approach is described here: https://content.naic.org/sites/default/files/documents/ltci-msa-framework.pdf

Suggested adjustments should be related to the concepts contained in the attached link: Recommendation on a single MSA actuarial approach after regulator feedback Document.

Please provide comments to eking@naic.org by Friday, May 3.

_______________________________________________________

To: Long-Term Care Actuarial (B) Working Group Members, Interested Regulators, and Interested Parties

Potential upcoming focus points for discussion on a single actuarial approach to multi-state long-term care rate increase reviews include:

  • Can adjustments to the Minnesota cost-sharing formula result, generally, in older age / higher duration / higher past rate increase policyholders having their future rate increases be more limited than under the current approach? 
  • Would such an adjusted Minnesota approach align with key principles (either developed by ACLI / AHIP or others that may be important to regulators and interested parties) such that it could be considered a candidate for the single actuarial approach?
  • Should interest rate history and expectations be a part of a single actuarial approach like it is with the Minnesota approach?

Comments are requested by close of business April 21, 2022

ERISA Handbook case summary - Rutledge 

     Comments received 

PCMA

ATAP

Consumer Reps

NCPA 

AHIP

    HMO Model Draft Adopted by the Subgroup, July 13, 2020

    There are no exposure drafts at this time.

    FINAL DRAFT VERSION OF DISCLOSURE NOTICE EXPOSED_0.pdf

    The Working Group's proposed Disclosure Notice of Premium Increase Guidance documents are exposed for comment until Feb. 1, 2024. Please send comments to NAIC staff person Sara Robben at srobben@naic.org.

    There are no exposure drafts at this time.

    There are no Exposure Drafts at this time.  

    The following document is being exposed for a 30-day comment period ending May 31, 2024.

    Please have comments submitted to Bree Wilson by close of business on Friday May 31, 2024.

    MCAS Data Call (post 6/5/2023)

    New Public Adjuster Licensing Charge

    Adopted by the Producer Licensing (D) Task Force: May 31, 2023

    Adopted by the Market Regulation and Consumer Affairs (D) Committee: July 27, 2023

    Review and amend, as needed, the Public Adjuster Licensing Model Act (#228) to enhance consumer protections in the property and casualty claims process.

    The Adjuster Licensing (D) Working Group has been given the task of reviewing the NAIC State Licensing Handbook, specifically Chapter 18 Adjuster Licensing.

    The State Licensing Handbook was last updated and made available in 2021.  The Producer Licensing Uniformity (D) Working Group has been given the charge to review the full handbook for any potential updates.  To assist with this, the Adjuster Licensing (D) Working Group will review Chapter 18 and discuss necessary updates which will be presented to the Producer Licensing Uniformity (D) Working Group.  

    To complete this review, the Working Group is exposing Chapter 18 for review and soliciting suggestions/comments with a deadline of Wednesday, May 1, 2024. *Please submit all suggestions in red-lined format.

    The Word and PDF version of Chapter 18 Adjuster Licensing can be found below.

    The Working Group will hold open monthly Webex conference calls to review comments received and finalize potential revisions. 

    Monthly Calls Through July:

    • Wednesday, May 15th (Call information included and calendar notice will be sent separately)
    • Wednesday, June 12th   (Regulator Only)
    • Wednesday, July 10th   (Open)

    State Licensing Handbook: Chapter 18 Adjuster Licensing -  WORD / PDF

    Comments Received:

    In 2022, the Working Group began working on their charge to:

    Review existing NAIC Models and Guidelines that address the use of lead generators for sales of Health Insurance products and identify models and guidelines that need to be updated or developed to address current marketplace activities. 

    The Working Group exposed suggested amendments on the Unfair Trade Practices Act  (Model 880) for comment. Throughout the year the Working Group met via conference calls to discuss the comments received and revised the Draft as necessary.

    The Working Group has exposed the 2nd Draft amendments for additional comments. (Draft Version 11.3.22).  

    These comments will be discussed at during the Working Group meeting taking place at the Spring National Meeting in Louisville, KY.  

    The Working Group will hold conference calls as necessary to finalize the amendments.  The final draft will be distributed prior adoption. 

     

    Draft  # 1: 

    Model 880 - Amendments Draft #1 8.31.22 

     

    Draft #2:

    Model 880 - Amendments Draft #2 11.3.22

     

    Draft #3:

    Model 880 - Amendments Draft #3 6.29.23

     

    New Comments Received:

     

    State Comments:

     

    Industry Comments:

     

     

    Draft Chapter 23-Conducting the Life and Annuity Examination October 4, 2023 Draft (The Oct. 4, 2023 draft contains changes from the previous version, dated June 6, 2023. The October 4, 2023 updates in the draft are highlighted in green, they occur on pages 14, 17, 29, 31, 32, 33, 38, 40, 45, 52, 55 and 56.)

    NOTE: The Oct. 4, 2023 draft Chapter 23 was adopted by the Working Group at its Nov. 8, 2023 Webex meeting, the chapter underwent additional revisions during that meeting, as part of that adoption.

    Draft Chapter 23-Conducting the Life and Annuity Examination June 6, 2023 Draft (The June 6, 2023 draft contains changes from the previous version, dated Aug. 22, 2022. The June 6, 2023 updates in the draft are highlighted in blue, they occur on pages 30 and 34 (in Marketing and Sales Standards 9 and 10.)

    Draft Chapter 23-Conducting the Life and Annuity Examination August 22, 2022 Draft (The Aug. 22, 2022 draft contained updates highlighted in yellow, which took into consideration comments received on the April 19, 2022 draft; the Aug. 22 draft was discussed at the Sept. 8 and Oct. 20, 2022 meetings and at the March 28, 2023 meeting.) 

    New Draft Chapter 23-Conducting the Life and Annuity Examination April 19, 2022 Draft (Updated to correspond to revisions adopted by the NAIC in February 2020 to the Suitability in Annuity Transactions Model Regulation (#275))

    New Draft Travel Insurance-Related Standardized Data Requests (Revised October 2023 by the Travel Insurance regulator-only SMEs, taking the comments received from Virginia Oct. 28, 2022, Missouri Sept. 16, 2022 and the CEJ Sept. 16, 2022 into consideration)

    NOTE: The Oct. 25, 2023 new draft Travel Insurance In-Force SDR and the Oct. 25, 2023 new Travel Insurance Claims SDR were adopted by this Working Group at its Nov. 8, 2023 Webex Meeting
     

    Draft Chapter 4-Collaborative Actions June 6, 2023 Draft (The purpose of the revisions is to incorporate changes into Chapter 4, providing nonregulators with transparency and insight regarding the multistate process that occurs at the Market Actions (D) Working Group (MAWG))

    NOTE: The June 6, 2023 draft Chapter 4 was adopted by the Working Group at its July 18, 2023 Webex meeting, the chapter underwent additional revisions during that meeting, as part of that adoption.

    Revised Draft Chapter 24B-Conducting the MHPAEA-Related Examination July 11, 2022 Draft (This draft was discussed at the July 14, 2022 Webex. Changes were made to Standard 5 on pages 14-15 and Standard 6 on pages 17-18; they are shown in yellow highlight. These revisions were made to the July 6, 2022 Chapter 24B Draft).

    NOTE: The Chapter 24B-Conducting the MHPAEA-Related Examination adopted by this Working Group on July 14, 2022 and by the Market Regulation and Consumer Affairs (D) Committee on August 12, 2022 at the Summer 2022 Hybrid National Meeting is provided at this link Chapter 24B-Conducting the MHPAEA-Related Examination Adopted 8-12-2022. Regulators, this document is also provided on the Market Regulation Handbook Web Page on StateNet.

    New Draft Chapter 24B-Conducting the MHPAEA-Related Examination July 6, 2022 Draft (Updated with regard to the Working Group's June 9th discussion on comments received on the April 19, 2022 Chapter 24B Draft)

    New Draft Chapter 24B-Conducting the MHPAEA-Related Examination April 19, 2022 Draft (Updated to correspond with updated federal guidance on Mental Health and Substance Use Disorder Parity Compliance)

    New Draft Chapter 1-Introduction July 6, 2022 Draft (Revisions relate to the Working Group's discussion re: the Oct. 27, 2021 Chapter 20 draft in its previous meetings on Nov. 4, 2021, March 10, 2022, April 21, 2022 and June 9, 2022)

    NOTE: The posted revisions to the July 6, 2022 draft Chapter 1-Introduction were adopted by the Working Group on its July 14, 2022 call.

    New Draft Chapter 20-General Examination Standards July 6, 2022 Draft (Revisions relate to the Working Group's discussion re: the Oct. 27, 2021 Chapter 20 draft in its previous meetings on Nov. 4, 2021, March 10, 2022, April 21, 2022 and June 9, 2022)

    NOTE: The posted revisions to the July 6, 2022 draft Chapter 20-General Examination Standards were adopted by the Working Group on its July 14, 2022 call.

    New Draft Chapter 20-General Examination Standards, Oct. 27, 2021 Draft (Revisions Relating to the Insurance Holding Company System Regulatory Model Act  (#440)

    New Draft Chapter 21-Conducting the Property and Casualty Examination, April 19, 2022 Draft Revisions to the 4-19-22 draft are shown in yellow highlight (Revisions Relating to the Real Property Lender-Placed Insurance Model Act (#631)

    NOTE: The posted revisions to the April 19, 2022 Conducting the Property and Casualty Examination chapter were adopted by the Working Group on its April 21, 2022 call.

    New Draft Chapter 21-Conducting the Property and Casualty Examination, Oct. 27, 2021 Draft (Revisions Relating to the Real Property Lender-Placed Insurance Model Act (#631)

    New Draft Chapter 24-Conducting the Health Examination, Sept. 30, 2021 Draft (Revisions Relating to the Health Maintenance Organization Model Act (#430)

    NOTE: The draft Chapter 24 was adopted by the Working Group on its November 4, 2021 conference call,

    New Draft Chapter 25-Conducting the Medicare Supplement Examination, Sept. 27, 2021 Draft (Revisions Relating to the Model Regulation to Implement the NAIC Medicare Supplement Insurance Minimum Standards Model Act (#651)

    NOTE: The draft Chapter 25 was adopted by the Working Group on its November 4, 2021 conference call, the chapter underwent an additional revision as part of that adoption.

    Updated Draft Title Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook

    New Draft Title Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook

    NOTE: The Title SDRs were adopted by the Working Group on its September 2, 2021 conference call, the Title Claims SDR underwent an additional revision as part of that adoption.

    New Draft Chapter 24-Conducting the Health Examination for inclusion in the Market Regulation Handbook (Revised Guidance Regarding Supplementary and Short-Term Health Insurance)

    NOTE: 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

    NOTE: 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

    NOTE: The Inland Marine In Force and Inland Marine Claims SDRs were adopted by the Working Group on its July 23, 2020 call.

    New Limited Long-Term Care Exam Standards Chapter 26A December 11, 2019 draft for Inclusion in the Market Regulation Handbook

    NOTE: The Limited Long-Term Care Exam Standards, Dec. 11, 2019 draft, were adopted by the Working Group on its July 23, 2020 call. 

    New Limited Long-Term Care Exam Standards Chapter 26A October 29, 2019 draft for Inclusion in the Market Regulation Handbook

    New Farmowners Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook

    NOTE: 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.

    Proposed Market Regulation Handbook Substantive Revisions Received from the Market Information Systems Research and Development (D) Working Group 7-12-16

    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

    There are no exposure drafts at this time.

    MCAS - Pet Insurance Scorecard Ratios Draft

    Charge to Assess Currently Available Market Analysis Data

    The Task Force's - Improper Marketing of Health Insurance (D) Working Group has been working on their charge to: 

    Review existing NAIC Models and Guidelines that address the use of lead generators for sales of Health Insurance products and identify models and guidelines that need to be updated or developed to address current marketplace activities. 

    The Working Group began reviewing the Unfair Trade Practices Act  (Model 880) in 2022. During the 2023 Summer National Meeting the Working Group adopted amendments to Model 880 (8.14.23). 

    The Task Force opened the adopted draft (8.14.23) for comment through Monday, October 16, 2023.  

    The Task Force met by conference call on October 20th to review comments received on draft amendments for the Unfair Trade Practices Act (Model #880). 

    During the conference call the Task Force agreed to accept additional revisions from the comments received.  The additional revisions have been applied to Draft #6 (10.20.23).

    The Draft #6 (10.20.23) was open for comment until Friday, November 10, 2023. 

    The Task Force will review the updated draft (10.20.23) for potential adoption.

     

    Draft #6 (10.20.23):

    Comments Received on Draft #6 (10.20.23):

     

    -----------------------------------------------------------------

    Draft #5 (8.14.23):

     

    Comments Received on Draft #5 (8.14.23):

    ---------------------------

     

     

    Antifraud Plan Repository Workflow

    The Antifraud Technology (D) Working Group has been working on their first charge which is to:  Review and provide recommendations for the development of an Antifraud Plan Repository to be used by insurers to create and store an electronic fraud plan for distribution among the states/jurisdictions. To assist with this process the Working Group created a subject matter expert (SME) group to finalize the Antifraud Plan Repository Workflow document. The SME Group exposed the draft to the Antifraud Technology (D) Working Group on May 6, 2022.    

    The Working Group adopted the draft on May 19, 2022 and it was presented to the Antifraud (D) Task Force.  The Task Force will hold a meeting on June 30, 2022 to review any comments received and potentially adopt the draft. 

    Antifraud Plan Repository Workflow

     

     

     

     

     

    Artificial Intelligence (AI) in MIS Recommendations

    MIS R&D WG Statement on AI posted 10/20/2021

    RIRS Coding Change Proposal

    RIRS Coding Change Proposal  posted 3/25/2021

    NAIC UNIFORM APPLICATION REVIEW (2024)

    In 2018 the Working Group reviewed and adopted revisions to the uniform applications (Individual and Business Entity).  These revisions were not fully adopted by the NAIC Membership. This year direction has been given to the Working Group to review the current revisions, finalize necessary changes and adopt. Once adopted they will be presented to the Producer Licensing (D) Task Force.

    To assist with the review a check list has been created with all revisions adopted during the 2018 review.  The checklist has 2 parts - "Initial" and "Renewal". 

    Please review the 2018 Uniform Application for Individual License Revisions Checklist document and provide your responses to either “accept” or “reject”. 

    The deadline for review is Friday, April 26, 2024. Please submit your responses to Gwelker@naic.org

     

    UNIFORM APPLICATION MATERIALS

     

    2018 NAIC Uniform Application for Individual License Revisions Checklist - Excel  (Deadline 4.26.24)
     

    2018 NAIC Uniform Applications

    • Individual Initial Application w/Track Changes - Word / PDF
       
    • Individual Renewal Application w/Track Changes - Word / PDF
       
    • Business Entity Initial Application w/Track Changes - Word / PDF
       
    • Business Entity Renewal Application w/Track Changes - Word / PDF

     

    2018 NAIC Uniform Application Comments 

     

    Working Group Minutes (2018)

     

     

     

     

     


     

    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.

    ------------------------------------------------------------

    Testing and Examination Pass Rates

     

    The following document is being exposed for a 30-Day public comment period ending on November 6th, 2023

    Please submit comments to Sherry Flippo by EOD on November 6th. 2023

     

    The Working Group has exposed the following for public comment. Please submit comments to Dave Fleming by COB May 15, 2024.


    The Working Group has exposed the following for public comment. Please submit comments to Dave Fleming by COB April 8, 2024.


    The Working Group has exposed the following for public comment. Please submit comments to Dave Fleming by COB May 12, 2023.


    The referral below requires a response from the Capital Adequacy (E) Task Force and the Risk-based Capital Investment Risk and Evaluation (E) Working Group by May 15, 2023. Please submit your comments to Eva Yeung or Dave Fleming by COB March 31, 2023.


    The Working Group has exposed the following for public comment. Comment is specifically requested from RBC vendors with respect to the proposed sensitivity test as it was submitted past the RBC deadline for exposure. Please submit comments to Dave Fleming by COB April 12, 2023.  

    There are no exposure drafts at this time.

    The Group Capital Calculation (E) Working Group is exposing the following documents, please submit comments to Dan Daveline by COB, Wednesday, February 21, 2024.

    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 National Treatment and Coordination (E) Working Group has exposed the following document with a public comment period ending April 1, 2024. Comments should be directed to NAIC staff, Jane Barr.

    Comments on exposed items should be addressed to Director Elizabeth Kelleher Dwyer and Commissioner Glen Mulready, Co-Chairs of the Restructuring Mechanisms (E) Working Group, and directed to NAIC staff, Robin Marcotte and Dan Daveline.

    The following documents have been exposed with a public comment period ending Friday, June 14, 2024.

    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 April 1, 2024

    Please address comment letters to Pat Gosselin, Chair of the Blanks (E) Working Group, and direct to NAIC support staff, Mary Caswell and Jill Youtsey.

    Ref No. Description Comment Deadline
    2023-12BWG Modified Categorize debt securities on Schedule BA that do not qualify as bonds under SSAP No. 26R—Bonds or SSAP No. 43R—Loan-Backed and Structured Securities and are captured in the scope of SSAP No. 21R—Other Admitted Assets. (SAPWG Ref #2023-16) 4/23/2024
    2024-01BWG Update the Investment Schedules General Instructions to identify that common and preferred stock residual interests should be reported on Schedule BA. (SAPWG Ref #2023-23). 4/23/2024
    2024-02BWG Remove categories from Schedule DA, Part 1, and Schedule E, Part 2, that should be reported on Schedule BA. Add clarifying instructions on what should be included in Other Short-Term and Other Cash Equivalent categories. 4/23/2024
    2024-03BWG Update General Interrogatory 35 for private letter rating security reporting to clarify what should be included. 4/23/2024
    2024-04BWG Add clarifying language to the VM-20, Requirements for Principle-Based Reserves for Life Products, supplement in the life blank to include separate accounts where applicable. 4/23/2024
    2024-05BWG Add clarifying language to Annual General Interrogatory 29.05 (Quarterly General Interrogatory 17.5) to clarify that all investment advisors with discretion to make investment decisions, including sub-advisors, should be disclosed through the interrogatory. 4/23/2024
    2024-06BWG P/C changes: Limit the requirement to send qualification documentation to the board of directors only at the initial appointment and not annually thereafter. Title changes: Update the title instructions so they are more similar to the P/C instructions. 4/23/2024
    2024-07BWG Update the illustration under Note 5S(A) – Investments for Net Negative (Disallowed) Interest Maintenance Reserve (IMR) to add separate account breakout. Add a new general interrogatory for a company attestation for separate accounts. (This goes with adopted Blanks (E) Working Group proposal 2023-13BWG). 4/23/2024
    2024-08BWG Update the Interest Maintenance Reserve and Asset Valuation Reserve instructions for specific allocation guidance for NAIC Designation Changes for Debt Securities (excluding LBSS), Mortgage Loans, and perpetual preferred stocks. (SAPWG Ref #2023-15 and Ref #2023-29). 4/23/2024
    2024-09BWG Add a note (5T) to the Notes to Financials to be data captured to report the aggregate collateral loans by qualifying investment collateral. 4/23/2024
    2024-10BWG Remove the ACA SSAP No. 107 disclosure on the transitional reinsurance program and the risk corridors program from Note 24E in the Notes to Financials (Note 24F for Property/Casualty) in the Annual Statement Instructions. 4/23/2024
    2024-11BWG Update the annual and quarterly instructions and blanks for the New Market Tax Credit changes. Changes will be made to: Annual – Assets, Notes to Financial Statements 5K, 14A, and 21E, AVR, and Schedule BA, Part 1, 3, and Verification Between Years. Quarterly changes – Assets and Schedule BA, Part 3 and Verification Between Years. 4/23/2024

     

     

    Exposure Drafts Outstanding
    Statutory Accounting Principles (E) Working Group
    Last Updated May 20, 2024

    Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to Julie GannRobin Marcotte, Jake StultzJason Farr and Wil Oden.

    For the status of all SAPWG agenda items, please refer to the Maintenance Agenda(updated March 16, 2024)

    EXPOSURES with PUBLIC COMMENT PERIOD ending JUNE 21, 2024
    2019-21 Issue Paper  Bond Project  Exposed revisions to the issue paper documents the most recent historical discussions and decisions with the principles-based bond project to reflect the final actions and adoption. Issue papers are not authoritative; they provide background on the development of guidance.  
    EXPOSURES with PUBLIC COMMENT PERIOD ending MAY 31, 2024

    2022-12

    2022-12a

    INT 03-02

    SSAP No. 25

    SSAP No. 63

    Review of
    INT 03-02
    Revisions nullify INT 03-02 and update SSAP No. 63 and SSAP No. 25 to address transfers of assets when modifying intercompany pooling agreements.
    2023-26

    SSAP No. 15

    SSAP No. 103R

    ASU 2023-06, Disclosure Improvements Revisions adopt, with modification, certain disclosures from ASU 2023-06 on unused commitments and lines of credit and disclosures for securities lending, repurchase agreements (repos), and reverse repos.
    2024-01 SSAP No. 26R Bond Definition - Debt Securities Issued by Funds Re-exposed revisions clarify the guidance for debt securities issued by funds with a specific request for regulator and industry comments on the proposed language that assists with clarifying the scope of guidance and to the types of debt securities issued by funds that should be considered as operating entities, and the proposed language to better define the extent of debt that may be issued to fund operations.
    2024-02

    SSAP No. 19

    SSAP No. 73

    ASU 2023-01, Leases (Topic 842), Common Control Arrangements Revisions adopt, with modification, the leasehold improvement guidance from ASU 2023-01 into SSAP No. 19 and SSAP No. 73.
    2024-03

    INT 21-01

    SSAP No. 20

    ASU 2023-08, Accounting for and Disclosure of Crypto Assets Revisions adopt with modification the definition of crypto assets from ASU 2023-08 into SSAP No. 20 and clarify that directly held crypto assets are nonadmitted assets for statutory accounting. INT 21-01, Accounting for Cryptocurrencies would be nullified upon the adoption of this agenda item.
    2024-04 SSAP No. 103R Conforming Repurchase Agreements Exposed agenda item details initial statutory differences between securities lending and repurchase agreements as well as other items that should be reviewed for potential clarification on the “conforming agreement” securities lending concept currently captured in the general interrogatories.
    2024-05 Appendix A-791 A-791, Paragraph 2.c. Revisions remove the first sentence of the Appendix A-791 Life and Health Reinsurance Agreements (A-791), paragraph 2.c. Question and Answer.
    2024-06 SSAP No. 61R Risk Transfer Analysis on Combination Reinsurance Contracts Revisions to SSAP No. 61R incorporate guidance from SSAP No. 62R, Exhibit A, Implementation Questions and Answers, question 10, which requires risk transfer to be evaluated in aggregate for contracts with interrelated contract features such as experience rating refunds. Additionally, a reference is added to A-791, paragraph 6, regarding the entirety of the contract.
    2024-07 Annual Statement Reporting of Funds Withheld and Modco Assets Exposed project proposes to add a new part to the Schedule S in the Life/Fraternal, and Health annual statement blanks and Schedule F in the Property/Casualty (P/C) and Title annual statement blanks, which is similar in structure to Schedule DL and would require disclosure of all assets held under a funds withheld arrangement and would include a separate signifier for modco assets.
    2024-08

    SSAP No. 21R

    SSAP No. 26R

    SSAP No. 30R

    SSAP No. 32R

    SSAP No. 43R

    SSAP No. 48

    Consistency Revisions for Residuals Revisions incorporate clarifying edits for residuals so that all applicable SSAPs refer to SSAP No. 21R for the formal definition and accounting and reporting guidance.
    2024-09 SSAP No. 2R SSAP No. 2R - Clarification Revisions eliminate lingering references in SSAP No. 2R that imply that asset-backed securities, mortgage loans, or other Schedule BA items are permitted to be reported as cash equivalents or short-term investments.
    2024-10 SSAP No. 56 SSAP No. 56 - Book Value Separate Accounts Agenda item directs NAIC staff to work with industry in determining current applications and differences in interpretations for the reporting of book value assets and to propose revisions to incorporate a consistent statutory accounting approach.
    2024-11 SSAP No. 101 ASU 2023-09, Improvements to Income Tax Disclosures Revisions adopt, with modification, certain disclosures from ASU 2023-09 and removes SSAP No. 101 disclosure, paragraph 23.b.
    2024-12

    SSAP No. 27

    Annual Statement

    Updates to SSAP No. 27 Revisions to SSAP No. 27 remove reference to FAS 105 and specifically note the financial instruments excluded from the scope of the SSAP. Revisions also update annual statement Note 16 to provide additional disclosures and instructions for derivatives and non-derivative financial instruments.
    2024-14EP Various SSAPs Accounting Practices and Procedures Manual Editorial Editorial revisions remove the “Revised” and “R,” previously intended to identify a substantively revised SSAP, from SSAP titles and SSAP references within the Manual.

    EXPOSURES DEFERRED for SUBSEQUENT INTERIM or NATIONAL MEETINGS

    2018-07

    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.

    2019-12

    Comments

    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.

    2019-14

    Comments

    SSAP No. 68

    SSAP No. 97

    Attribution of Goodwill The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent call or meeting.

    2019-49

    Comments

    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.

    2023-31 SSAP No. 58 Updates from Model 630 Mortgage Guaranty Insurance Exposed intent to review the revisions to the Mortgage Guaranty Insurance Model Act (#630) for incorporation into SSAP No. 58—Mortgage Guaranty Insurance and Appendix A-630 as applicable. The exposure requests input on an effective date.

    The following documents are being exposed by the Working Group. Please submit comments to Maggie Chang by COB May 16, 2024.

    Exposure of the BA Mortgage Proposal

    Comments should be sent electronically to Dave Fleming by COB Tuesday, May 28, 2024


    The Life Risk-Based Capital (E) Working Group agreed to expose the following item for a 30-day public comment period:

    Comments should be sent electronically to Dave Fleming by COB Wednesday, May 22, 2024.  


    Exposure of the RBC Repurchase Agreement Proposal

    Comments should be sent electronically to Dave Fleming by COB Monday, April 15, 2024


    Exposure of the Other Long-Term Assets Proposal

    Comments should be sent electronically to Dave Fleming by COB Monday, February 26, 2024


    Exposure of the RBC Repurchase Agreement, TAC, and BA Mortgage Proposals

    Comments should be sent electronically to Dave Fleming by COB Monday, February 26, 2024


    Exposure of the Implementation of 2023 Mortality Risk Changes Memorandum

    Comments should be sent electronically to Dave Fleming by COB Friday, December 29, 2023


    Exposure of the American Council of Life Insurers (ACLI) Proposal for Repurchase Agreements

    Comments should be sent electronically to Dave Fleming by COB Friday, September 29, 2023


    Exposure of the 2023-08-L Comfort Trusts Proposal

    Comments should be sent electronically to Dave Fleming by COB Friday, June 2, 2023


    Exposure of the Proposed Charges of the Economic Scenarios (E/A) Subgroup

    Comments should be sent electronically to Scott O’Neal by COB Thursday, March 15, 2023 


    Exposure of the proposed revisions to CM6 and CM7 mortgages.

    Comments should be sent electronically to Dave Fleming by COB Thursday, March 16, 2023 


    Exposure of the American Academy of Actuaries’ (Academy) C2 Mortality Risk Work Group proposed changes.

    Comments should be sent electronically to Dave Fleming by COB Wednesday, March 1, 2023 


    Exposure to remove dual trend test presentation.

    Comments should be sent electronically to Dave Fleming by COB Tuesday, February 14, 2023 


    Exposure of the American Academy of Actuaries' (Academy) C2 Work Group Proposed Instruction Supplement for Applying the Newly Adopted Life Insurance C-2 Mortality Factors

    Comments should be sent electronically to Dave Fleming by COB Friday, November 11, 2022 


    Exposure of the Affiliated Investments Instructions and Structure

    Comments should be sent electronically to Dave Fleming by COB Wednesday, July 20, 2022.


    Re-Exposure of the American Academy of Actuaries’ (Academy) C2 Mortality Risk Work Group Proposed Instructions

    Comments should be sent electronically to Dave Fleming by COB Wednesday, June 15, 2022.


    Exposure of the following documents.  

    Comments should be sent electronically to Dave Fleming by COB Wednesday, May 25, 2022.


    Exposure of the Proposed Asset Valuation Reserve Factor Changes

    Comments should be sent electronically to Dave Fleming by COB Friday, March 25, 2022.


    Exposure of the C-2 Mortality Proposal

    Comments should be sent electronically to Dave Fleming by COB Monday, March 7, 2022.


    Exposure of the American Academy of Actuaries’ C-2 Mortality Work Group Recommendation on C-2 Mortality Factor Updates

    Comments should be sent electronically to Dave Fleming by COB Monday, January 10, 2022.


    Exposure of American Academy of Actuaries' and American Council of Life Insurers’ Proposed Bond Factors and Instructions 

    Additional exposure to include explicit tax factors that are a part of the development of both sets of proposed base bond factors above.

    Comments should be sent electronically to Dave Fleming by COB Thursday, May 27, 2021.


    Exposure of American Council of Life Insurers’ Proposed Factors and Instructions 

    Additional exposure to include asset concentration factor instructions that were omitted from the original document.

    Comments should be sent electronically to Dave Fleming by COB Monday, May 24, 2021.


    Exposure of American Academy of Actuaries’ Proposed Bond Factors

    Comments should be sent electronically to Dave Fleming by COB Friday, April 9, 2021.


    Exposure of Proposed Life Risk-Based Capital Mortgage Reporting Guidance Extension

    Comments should be sent electronically to Dave Fleming by COB Monday, February 22, 2021.


    Comments should be sent electronically to Dave Fleming by COB Monday, March 8, 2021.


    Comments should be sent electronically to Dave Fleming by COB Wednesday, Oct. 7, 2020.


    Comments should be sent electronically to Dave Fleming by COB Monday, August 10, 2020.


    Exposure Drafts Still Open For Consideration with Comment Received:

    Please send any comments on the exposure drafts to Dave Fleming.

    The Property and Casualty Risk-Based Capital (E) Working Group is exposing the following proposals for a 30-day public comment period ending May 25, 2024, please submit comments to Eva Yeung.

    The Catastrophe Risk (E) Subgroup re-exposing the following proposal for a 22-day public comment period ending April 8, 2024, please submit comments to Eva Yeung.

    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.

     

    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.

    On September 21, the Task Force exposed proposed new disclosures for catastrophe reinsurance programs for P&C RBC, for a 30-day exposure period ending Monday, October 23. The comment deadline for this exposure has been extended to Tuesday, Nov. 7.

    On October 27, the Task Force exposed proposed draft revisons to the Uniform Checklist for Reciprocal Jurisdiction Reinsurers for a 15-day public comment period ending on November 10.

    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 30-day public comment period ending Thursday, May 9th, 2024:

    Additionally, commenters are asked to consider whether more expedient changes to only the mortality and expense assumptions would be desirable (potentially for the 2025 Valuation Manual) or if the entire package (including updated surrender assumptions) should be considered for adoption as it is ready.

    Please send comments to Scott O'Neal by close of business on May 9th, 2024.

    Revisions to the Property and Casualty Insurance Guaranty Association Model Act (#540)

    Revisions preserve guaranty fund coverage for policyholders subject to restructuring mechanisms and that clarify guaranty fund coverage of cyber security insurance. The recommendation for accreditation is that the changes are acceptable, but not required for accreditation. Comments due by Friday, April 19, 2024, to Bailey Henning (bhenning@naic.org)

    F Cmte Exposure - RITF Memo to F Committee

     

    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 Working Group is exposing the draft E-Commerce Modernization Guide until March 14, 2024. 

    Please submit comments to Olivea Myers by COB March 14, 2024.

    There are no exposure drafts at this time.

    The attached work plan for the Third-Party Data and Models (H) Task Force is exposed for a 30-day public comment period ending Monday, May 6, 2024. Comments should be emailed to kdefrain@naic.org by close of business on May 6, 2024.

     

    2024 Charges and Work Plan

    To determine a path for the working group to proceed in order to accomplish our charges, we are seeking comments by COB May 30, 2024, in two areas:

    1. Does the working group want to continue work on Draft NAIC Privacy Model #674?
    2. Or Revise one or both of the NAIC’s existing models, either #670 or #672, taking the option provided by Industry into consideration?

    Core Privacy Issues Quick Look Introduced during May 15, 2024 Open Call:

    Core Privacy Issues Quick Look.pdf

    Industry Draft Model From 672 - 03.27.24 introduced during May 15, 2024 Open Call:

    Privacy Model Act Draft From 672 - 03.27.24.pdf

    ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

    Cover Letter for Exposure Draft of New Consumer Privacy Protections Model Law #674:

    Cover Page for Draft Model Law 7-11-23.pdf

    Second Public Exposure Draft of the new Insurance Consumer Privacy Protections Model Law #674 (Version 1.2 dated July 11, 2023) :(incorporates revisions based on comments received prior to and after the Interim Meeting) is being exposed for a public comment period from July 11, 2023 to July 28, 2023. All comments received will be discussed during open meetings beginning with the July 25, 2023 conference call.

    Exposure Draft-Consumer Privacy Protection Model Law #674 as of 7-11-23.pdf

    6/23/23 Revisions to Sections 17 through 20 of the 1/31/23 Exposure Draft Model Law #674-Comments are due July 10, 2023:

    Exposure of Sections 17-18-19-20 REV.pdf