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.
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.
The Task Force exposed the following memorandum, please submit comments to Dan Daveline before March 12, 2025.
Annuity Suitability (A) Working Group Adopted FAQ Guidance Document
Chair Draft Safe Harbor Guidance Document (Draft Date Sept. 23, 2024)
The following document is being exposed for a 21-day public comment period ending Tuesday, April 29:
Please send comments to Scott O'Neal by April 29, 2025.
The following document is being exposed for a 14-day public comment period ending Wednesday, April 16:
Please send comments to Scott O'Neal by April 16, 2025.
The following document is being exposed for a 21-day public comment period ending Wednesday, April 23:
Please send comments to Scott O'Neal by April 23, 2025.
The following document is being exposed for a 28-day public comment period ending Wednesday, April 30:
Please send comments to Scott O'Neal by April 30, 2025.
The following document is being exposed for a 32-day public comment period ending Thursday, April 24:
Please send comments to Scott O'Neal by April 24, 2025.
The following document is being exposed for a 21-day public comment period ending April 13:
Please send comments to Scott O'Neal by April 13, 2025.
There are no exposure drafts at this time.
The following document is being exposed by the chair for a public comment period ending Monday, June 30, 2025:
Please send comments to Jennifer Frasier by close of business on June 30, 2025.
The following documents are being exposed for a public comment period ending, Wednesday, March 26, 2025:
- SPA Policy Holder Behavior Assumptions Proposed Edits (Clean)
- SPA Policy Holder Behavior Assumptions Proposed Edits (Redline)
Please send comments to Amy Fitzpatrick by close of business on March 26, 2025.
The following document is being exposed, with specific comment periods for the questions outlined below:
- For items 1 – 3 (Reinvestment Guardrail, SERT Threshold, SERT Mortality Sensitivity), please provide related comments by Feb. 25 to allow for discussion at a Feb. 26 meeting.
- For item 4, please provide comments by Mar. 17.
Please send comments to Amy Fitzpatrick according to the timing outlined above.
The following document is being exposed for a 30-day public comment period ending Thursday, March 13:
Please send comments to Scott O'Neal by Thursday, March 13, 2025.
The following document's exposure period is being extended. It is now ending Friday, Nov. 22 Monday, Nov. 4:
Please send comments to Scott O'Neal by Nov. 22 Nov. 4, 2024
The following document is being exposed for a 30-day public comment period ending Thursday, Nov. 14, 2024:
Please send comments to Scott O'Neal by Nov. 14, 2024
Additionally, an excel tool that compares the 12/31/23 AIRG and GOES 2024 FT1 UST SERT Scenarios has been included to aid review of the scenarios.
There are no exposure drafts at this time.
The following document is being exposed for a 45-day public comment period ending Monday, April 7, 2025:
Please send comments to Jane Ren by April 7, 2025
Model #171 Revisions Tracked Redline Version (as adopted by the Committee on Nov. 19)
Model #171 Revisions Clean Version (as adopted by the Committee on Nov. 19)
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 Task Force requests comments on the American Academy of Actuaries draft Knowledge Statements for Appointed Actuary for Health Blank.
Health Knowledge Statements_Draft.pdf
Please provide comments to eking@naic.org by Thursday, Oct. 31.
The Long-Term Care Actuarial (B) Working Group is considering revised cost-sharing factors to accompany implicit cost-sharing contained in the blended / if-knew aspect of the MSA approach adopted by the Working Group and the Long-Term Care Insurance (B) Task Force in late 2024.
Please provide comments to eking@naic.org on the following cost-sharing proposals by May 12, 2025:
Missouri Proposal:
• No haircut for the first 100%.
• 35% for the portion of cumulative rate increase between 100% and 400%
• 70% for the portion of cumulative rate increase between 400% and 800%
• 85% for the portion of cumulative rate increase between 800% and 1000%
• 95% haircut for the portion of the cumulative rate increase in excess of 1000%
“Alternative” Proposal, discussed on the February 21, 2025 Working Group call:
• 5% haircut for the first 100%.
• 35% for the portion of cumulative rate increase between 100% and 400%
• 70% for the portion of cumulative rate increase between 400% and 800%
• 85% for the portion of cumulative rate increase in excess of 800%
There will be a Working Group call in mid to late May to choose between the proposals or factors in between those stated in the proposals.
Revised 2025 Charges for Prescription Drug Coverage WG Adopted by TF (Regulatory Framework (B) Task Force 2025 Proposed Revised Charges Adopted March 10, 2025)
Comments are requested by close of business April 21, 2022
ERISA Handbook case summary - Rutledge
Comments received
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The attached Catastrophe Modeling Primer is being exposed for public comment.
10_23_24 Exposure Draft of Cat Modeling Primer.pdf
Please submit comments to Sara Robben, srobben@naic.org, by close of business on Friday, Nov. 22, 2024.
There are no exposure drafts at this time.
!!FINAL VERSION OF DISCLOSURE NOTICE COMBINED_redlined changes.pdf
The Working Group's revised Disclosure Notice of Premium Increase Guidance document is exposed for comment until Aug. 30, 2024. Please send comments to NAIC staff person Anne Obersteadt at aobersteadt@naic.org.
The Task Force is exposing the Schedule P Phase 1 document for 30 days.
Property 2025 Schedule P Phase 1 Exposure
Please provide comments to Kris DeFrain, kdefrain@naic.org, by Wednesday, March 19, 2025.
The following document is being exposed for a 30 day public comment period ending January 21, 2025.
2025 P&C Statement of Actuarial Opinion Instructions
Please provide written comments to Kris DeFrain, kdefrain@naic.org by Tuesday, January 21, 2025.
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 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.
The Word and PDF version of Chapter 18 Adjuster Licensing can be found below.
The PDF Chapter 18 Adjuster Licensing Draft with track changes can be found below.
The Working Group will hold open monthly Webex conference calls to review comments received and finalize potential revisions.
2025 Monthly Calls:
- Chapter 18 Adjuster Licensing (Current Version) - WORD / PDF
- Chapter 18 Adjuster Licensing (Draft W/Track Changes) - 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:
- MO DOI Comments (7.21.23)
- NAIC Consumer Reps Comments (7.25.23)
- AHIP Comments (7.21.23)
State Comments:
- HI DOI Comments (3.29.23)
- ME DOI Comments (11.18.23)
- MO DOI Comments (3.13.23)
- OH DOI Comments - PLMA (Model 218)
- OH DOI Comment Letter 11.15.22
- OH DOI Comment Letter 11.18.22
- OK DOI Comments (9.30.22)
- RI DOI Comments (8.1.22)
Industry Comments:
- ACLI Comments (9.30.22)
- AHIP Comment (9.30.22)
- AHIP Comment (11.18.22)
- AHIP Updated Comments (11.2.22)
- Health Benefits Institute Comments (9.30.22)
- NAIC Consumer Representatives Comments (9.30.22)
- NAHU Comments (9.30.22)
Draft Chapter 21A-Conducting the Property and Casualty Travel Insurance Examination February 11, 2025 Draft (Updated to add Review Procedures and Criteria and Documents to be Reviewed) Comments Due Date March 12, 2025
2024 Exposure Drafts:
Draft Chapter 23-Conducting the Life and Annuity Examination Chapter October 4, 2024 Draft (Updated to correspond to Actuarial Guideline XLIX-A—The Application of the Life Illustrations Model Regulation to Policies with Index-Based Interest (AG 49-A). NOTE: The Oct. 4, 2024 draft Chapter 23 was adopted by the Working Group at its Nov. 7, 2024 Webex meeting,
2023 and Prior Years' Exposure Drafts:
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)
- Revised Travel In Force SDR, October 25, 2023 Draft Redline
- Revised Travel In Force SDR, October 25, 2023 Draft Redline Accepted
- Revised Travel Claims SDR, October 25, 2023 Draft Redline
- Revised Travel Claims SDR, October 25, 2023 Draft Redline Accepted
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
- Travel In Force SDR, August 17, 2022 Draft
- Travel Claims SDR, August 17, 2022 Draft
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)
- WI 05-25-22 Comments
- MO 05-27-22 Comments
- VA 05-27-22 Comments
- AHIP 05-27-22 Comments
- ABHW 05-27-22 Comments
- BCBSA 05-27-22 Comments
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)
- ACLI 05-18-22 Comments
- NV 04-14-22 Comments
- AHIP/BCBSA 04-15-22 Comments
- AHIP/BCBSA 04-15-22 FAH Market Conduct Communications 04-15-22 Excerpt
- State Farm Nov. 24, 2021 Comments
- ACLI Dec. 17, 2021 Comments
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).
- Industry Trade Associations Nov. 11, 2021 Comments Received by the NAIC on Nov. 23, 2021
- Examination Resources Dec. 17, 2021 Comments
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
- Title In Force SDR March 23, 2021 Draft
- Title Claims SDR March 23, 2021 Draft
- RI 04/01/21 Comments
- NE 04/23/21 Comments
- CEJ 04/23/21 Comments
- ALTA 04/23/21 Comments
- CO 04/29/21 Comments
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.
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.
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 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.
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.
There are no exposure drafts at this time.
MCAS - Pet Insurance Scorecard Ratios Draft
- Pet Insurance Scorecard Ratios v1.9 2/21/2024
Charge to Assess Currently Available Market Analysis Data
- Market Analysis Data Sources 6/23/2023
Draft Documents
Other Health
Other Health MCAS Blank DRAFT - 03/25/25
Other Health Data Call and Definitions DRAFT - 03/25/25
Comments to Working Group
ACLI Comments on Other Health MCAS Draft - 04/17/25
Consumer Rep Comments on Other Health MCAS Draft - 04/17/25
Missouri Comments on Other Health MCAS Draft - 04/16/25
Private Passenger Auto
Private Passenger Auto MCAS Blank Draft - Proposed Edit - 04/03/25
Private Passenger Auto MCAS Blank DRAFT - 03/25/25
Comments to Working Group
Missouri Comments on PPA MCAS Draft - 04/17/25
MCAS Proposals
LPI Cancellations
Proposal 2025.1 - LPI Cancellations
CCIA and APCIA Comments on Proposal 2025.1 - 03/19/25
Response from CEJ to CCIA and APCIA Comment Letter - 03/31/25
Comments to Working Group
CEJ Comments on LPI Proposal - 04/16/25
MO Comments on LPI Proposal - 04/17/25
Complaint Data Elements
Wording of Complaint Data Elements
Comments to Working Group
OK Comments on Complaint Data Elements - 04/17/25
CEJ Comments on Complaint Data Elements - 04/16/25 (See Page 2 - Renaming Certain Data Elements...)
MO Comments on Complaint Data Elements - 04/17/25
Market Regulation Certification Program v2.44 clean 05/09/2023
Certification Program Scoring Matrix 04/19/2023
Market Regulation Certification Implementation Plan Adopted 12/9/2022
The Task Force's Improper Marketing of Health Insurance (D) Working Group has been working on its 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, Oct. 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, Nov. 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):
- Missouri DOI Comments
- Missouri DOI Comments (within Model)
- Virginia DOI Comments
- Coalition Against Insurance Fraud and NAIC Consumer Representatives Comments
- Coalition Against Insurance Fraud and NAIC Consumer Representatives Comment Letter
---------------------------
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
There are no exposure drafts at this time.
UNIFORM LICENSING STANDARDS
The Working Group has requested state updates to the Uniform Licensing Standards Compliance Charts.
The ULS charts were last updated in 2017. To confirm we have the correct information; we are asking each state to review the ULS Checklist and provide their responses.
For any non-compliance areas please indicate whether it is due to a regulation/rule or a department process. In addition, if there is any legislation pending please update the chart with that information.
Please send your responses back to me at Gwelker@naic.org and Courtney.Khodabakhsh@oid.ok.gov by end of day on Thursday, Nov. 21.
NAIC STATE LICENSING HANDBOOK REVIEW
The Producer Licensing Uniformity (D) Working Group has been given the charge to: Provide oversight and ongoing updates to the State Licensing Handbook, as needed.
The Working Group distributed a State Licensing Handbook checklist listing out each chapter with an option to select “YES or NO” whether the chapter should be opened for review.
The Working Group met by conference call on September 10, 2024 to discuss the comments received and determine the chapters that may need further review.
The discussions generated a list of chapters that will need to be reviewed and are copied below. The Working Group plans to meet on Nov. 7, 2024, to discuss the chapters and determine a plan of action to finalize the review of each chapter.
Per these discussions the Working Group will provide a report to the Producer Licensing (D) Task Force with the findings and plan of action to review and potentially revise.
State Licensing Handbook - Chapters
- 1 – Modern Producer Licensing
- 6 – Prelicensing Education
- 7 – Application Review for Initial Licenses
- 8 – Testing Programs
- 9 – Lines of Insurance
- 10 – Surplus Lines Producer Licenses
- 11 - Appointments
- 12 – Business Entity
- 13 – Temporary Licenses
- 14 – Continuing Education
- 18 – Adjuster
- 19 – Bail Bonds Agent
- 24 – Managing General Agents
- 25 – Multiple Employer Welfare Arrangements
- 30 – Viatical and Life Settlement Brokers
Checklist Individual Responses:
The State Licensing Handbook (individual chapters and appendix) can be found on the NAIC website: https://content.naic.org/state_licensing_handbook.htm
The Working Group will continue to meet monthly in order to review the State Licensing Handbook.
_________________________________________________________________________
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".
The Working Group met by conference call through July to finalize the review and adopt the revisions.
Adopted NAIC Uniform Applications
Uniform Application for Individual (Initial) - Adopted by PLUWG May 7, 2024
Uniform Application for Individual (Renewal) - Adopted by PLUWG June 4, 2024
Uniform Application for Business Entity License (Initial) - Adopted by PLUWG June 4, 2024
Uniform Application for Business Entity License (Renewal) - Adopted by PLUWG June 4, 2024
UNIFORM APPLICATION MATERIALS
2018 NAIC Uniform Application for Business Entity License Revisions Checklist - Excel
2018 NAIC Uniform Application for Individual License Revisions Checklist - Excel
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
- Individual Initial Application Comments
- Individual Renewal Application Comments
- Business Entity Initial Application Comments
- Business Entity Renewal Application Comments
Working Group Minutes (2018)
- 12.19.17 Minutes
- 3.15.18 Minutes
- 4.11.18 Minutes
- 5.2.18 Minutes
- 5.9.18 Minutes
- 6.6.18 Minutes
- 6.13.18 Minutes
- 7.10.18 Minutes
NAIC State Licensing Handbook
The Producer Licensing Uniformity (D) Working Group has asked the Uniform Education (D) Working Group to review State Licensing Handbook chapters specific to continuing education. The three chapters identified are:
- Chapter 6 – Prelicensing Education
- Chapter 8 Testing Programs
- Chapter 14 Continuing Education.
To efficiently review these chapters the Working Group is asking to review Chapter 6 – Prelicensing Education first. Once comments have been received the Working Group will meet by conference call to review and begin reviewing potential revisions for the State Licensing Handbook. The chapters have been copied below.
Please submit your suggestions/comments to Gwelker@naic.org.
- SLH- Chapter 6 Prelicensing Education
- SLH - Chapter 8 Testing Programs
- SLH - Chapter 14 Continuing Education
*The Working Group is currently taking comments on all three chapters. The Working Group will continue to meet monthly to review and finalize.
CE Audit Procedures
The Uniform Education (D) Working Group adopted the NAIC CE Audit Guidelines on Oct. 29, 2024. The adopted document can be found below. The Producer Licensing (D) Task Force will review the document at the Fall National Meeting as part of the Working Group reports.
CE Audit Guidelines (Adopted by UEWG on Oct. 29, 2024)
Checklist Responses:
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 (EX) Committee during the Summer National Meeting for final adoption. The adopted draft is attached below.
------------------------------------------------------------
Testing and Examination Pass Rates
Exposure Drafts Still Open For Consideration with Comments Received:
Investment Framework
The Working Group exposed the following for a 24-day comment period. Please submit comments to Maggie Chang by March 7, 2025.
- The American Council of Life Insurers’ (ACLI’s) RBC Principles for Bond Funds Presentation
- The NAIC’s Memorandum of Bond Funds Reported in 2023 Annual Statement Filings
The Risk-Based Capital Investment Risk and Evaluation (E) Working Group has exposed the following item with a 21-day public comment period. Please submit comments to NAIC staff, Dave Fleming, by COB Thursday, June 13, 2024.
Included for reference is the presentation from the NAIC’s Structured Securities Group. The Working Group is specifically requesting comment on which items should be included in the proposal’s Exempted Residual Tranches and Interests list which would receive a 30% factor with all other residual tranches and interests receiving a 45% factor.
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.
There are no exposure drafts at this time.
The following document is being exposed for a 45-day public comment period ending Friday, May 30:
Please send comments to Bruce Jenson by May 30, 2025.
There are no exposure drafts at this time.
During the December 12th, regulator call, the National Treatment and Coordination (E) Working Group discussed a new Corporate Amendment change type. The new change type is Reinstatement. The Working Group is exposing the new change type for Corporate Amendments and Instructions for a 45-day comment period ending February 17, 2025, please submit comments on the edits or suggestions to Bon Rector.
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, July 12, 2024
Comment Letters:
The following documents are being exposed for a public comment period ending Tuesday, December 10, 2024:
- Proposed Contractor Oversight Additions to Accreditation Review Team Guidelines
- Proposed Contractor Oversight Additions to the Financial Analysis Handbook - Part 1
- Proposed Contractor Oversight Additions to the Financial Analysis Handbook - Part 2
- Proposed Contractor Oversight Additions to the Financial Condition Examiners Handbook
Please send comments to Bruce Jenson by Tuesday, December 10, 2024
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 March 21, 2025
Please address comment letters to Roy Eft, Chair of the Blanks (E) Working Group, and direct to NAIC support staff, Mary Caswell and Jill Youtsey.
| Ref No. | Description | Comment Deadline |
| 2024-19BWG Modified | Update Schedule BA line categories and instructions for the expansion of collateral loans. Add two electronic-only columns to Schedule BA, Part 1, for reporting fair value of collateral backing and the percentage of the collateral. Update the asset valuation reserve (AVR) instructions and blank for the added collateral loan lines. | April 29, 2025 |
| 2025-01BWG | Update the Notes to Financial Statements Note 8 – Derivatives to include adopted revisions to SSAP No. 86—Derivatives. Update Note 11 – Debt for the adopted revisions to SSAP No. 15—Debt and Holding Company Obligations. | April 29, 2025 |
| 2025-02BWG | Update Notes to Financial Statements Note 9 – Income Taxes to include adopted revisions to SSAP No. 101—Income Taxes. | April 29, 2025 |
| 2025-03BWG | Modify the Life Insurance (State Page) to include accident and health data for direct premium earned and direct losses incurred. | April 29, 2025 |
| 2025-04BWG | Add a new part to the Notes to Financial Statements Note 28 – Health Care Receivables to include Medicare Part D prescription payment plans. | April 29, 2025 |
| 2025-05BWG | Add a new part to Schedule S to report reinsurance agreements with funds withholding and modified coinsurance. | April 29, 2025 |
| 2025-06BWG | Update Note 5L – Restricted Assets Instructions and Illustrations to make the changes for clarification on what should be reflected within the restricted asset note. | April 29, 2025 |
| 2025-07BWG | Update Schedule P with editorial revisions exposed at the Casualty Actuarial and Statistical (C) Task Force. | April 29, 2025 |
| 2025-08BWG | Remove Life/Fraternal General Interrogatory #14 that reports total dividends paid to stockholders and renumber remaining general interrogatory. This interrogatory is not included across all annual statement blanks and is not clearly included as a required disclosure in SSAP No. 72. (SAPWG Ref # 2025-07) | April 29, 2025 |
| 2025-09BWG | Update Life/Fraternal Note to Financial #35 for separate account transfers. Also add a general interrogatories to Separate Account Blank for transfers and repurchase agreements and reverse repurchase transactions. (SAPWG Ref #2024-10) | April 29, 2025 |
| 2025-10BWG | Update Note 5L to identify assets held under funds withholding agreements (including modco) that are affiliated with the reinsurer. Also updated the list of required quarterly disclosures to include Note 5L – Restricted Assets. With this change, this disclosure will be required in all interim and annual financial statements. (SAPWG Ref # 2025-05) | April 29, 2025 |
| 2025-11BWG | Remove the capital structure code reporting column on Schedule D, Part 1, Sections 1 and 2. (SAPWG Ref #2025-04) | April 29, 2025 |
| 2025-12BWG | “Remove” Line 8 – Unrated Multi-Class Securities Acquired by Conversion from AVR: Default Component – Basic Contribution. Relabel the line with “intentionally left blank” to prevent renumbering all lines in the AVR schedule and to be used in the future if there are other AVR updates. (SAPWG Ref # 2025-06) | April 29, 2025 |
| 2025-13BWG | Update Notes to Financial Statements Note 13K with disclosure updates to SSAP No. 41—Surplus Notes (SAPWG Ref # 2024-28) | April 29, 2025 |
| 2025-14BWG | Add instructions to include Medicare Part D Prescription Payment Plan information to the Health Care and other amounts receivable line on the Asset Page, Supplemental Health Care Exhibit, Exhibit 3 – Health Care Receivables, and Exhibit 3A – Analysis of Health Care Receivables. (SAPWG INT 24-02: Medicare Part D Prescription Payment Plan) | April 29, 2025 |
| 2025-15BWG | Update Note 8 – Derivatives in the Notes to Financial Statements and Schedule DB to clarify the terminology used for derivative financing premium. (SAPWG Ref # 2024-23) | April 29, 2025 |
Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated March 24, 2025
Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to Julie Gann, Robin Marcotte, Jake Stultz, Jason Farr and Wil Oden.
For the status of all SAPWG agenda items, please refer to the Maintenance Agenda. (updated December 17, 2024)
| EXPOSURES with PUBLIC COMMENT PERIOD ending MAY 2, 2025 | |||
| 2023-24 |
Issue Paper |
Current Expected Credit Losses (CECL) | Exposed issue paper maintains pre-CECL GAAP impairment guidance for the historical record |
| 2024-07 | Annual Statement | Reporting of Funds Withheld and Modco Assets | Exposed revisions capture information on modified coinsurance (modco)/funds withheld assets. This exposure has been modified to remove the initially proposed Schedule F, Part 7, from the proposal and add a Part 8 to Schedule S for the life/fraternal instructions and blank. The Schedule S draft includes aggregated data and is consistent with AVR reporting. |
| 2025-04 | Annual Statement | Capital Structure Code | Exposed agenda item proposes to remove the “capital structure code” reporting column in Schedule D-1-1: Long-Term Bonds – Issuer Credit Obligations (D-1-1) and Schedule D-1-2: Asset-Backed Securities (D-1-2). |
| 2025-05 |
SSAP No. 1 Annual Statement |
Reinsurer Affiliated Assets | Exposed revisions expand the restricted asset note disclosure to capture information on all funds withheld assets that are related to the reinsurer and require the disclosure in all quarterly and annual financial statements. |
| 2025-06 | Annual Statement | AVR Line: Unrated Multi-Class Securities | Exposed agenda item proposes revisions to the life/fraternal annual statement blank to remove reporting line 8, “Unrated Multi-Class Securities Acquired by Conversion,” from the asset valuation reserve (AVR). (Under the proposal, the line will be renamed to “intentionally left blank” to prevent renumbering AVR / RBC references.) |
| 2025-07 | Annual Statement | Dividend General Interrogatory Update | Exposed revisions to the life/fraternal annual statement blank remove a general interrogatory on dividends received. |
| 2025-08 | SSAP No. 84 | Medicare Part D Prescription Drug Payment Plan Disclosures | Exposed revisions add 2025 year-end disclosures on the Medicare Part D prescription payment plan amounts. |
| EXPOSURES with PUBLIC COMMENT PERIOD ending JUNE 6, 2025 | |||
| 2023-14 |
SSAP No. 7 Annual Statement |
Hypothetical IMR Memo | Exposed memorandum details the discussions and recommended conclusion of the Interest Maintenance Reserve (IMR) ad hoc group to remove hypothetical IMR. |
| 2025-01 | SSAP No. 25 | Sale Leaseback Clarification | Exposed revisions clarify that sale leasebacks with restrictions on access to the cash proceeds do not qualify for sale leaseback accounting and shall be accounted for by the seller using the financing method. |
| 2025-02 | SSAP No. 15 | ASU 2024-04, Induced Conversions of Convertible Debt Instruments | Exposed revisions adopt, with modification, ASU 2024-04 for statutory accounting within SSAP No. 15. |
| 2025-03 | SSAP No. 7 | ACLI Discussion Document | Exposed proposed guidance defines interest maintenance reserve (IMR).The ACLI discussion document shared with the IMR ad hoc group on the IMR definition has also been included. |
| 2025-09 | SSAP No. 51 | VM-22 Update Coordination | Exposed consistency revisions reflect new VM-22, Statutory Maximum Valuation Rates for Income Annuities, principle-based reserve (PBR) requirements. |
| 2025-10 | Appendix D | ASU 2023-07, Improvements to Reportable Segment Disclosures | Exposed revisions reject ASU 2023-07 in Appendix D as not applicable to statutory accounting. |
| 2025-11 | Appendix D | ASU 2024-03 and ASU 2025-01, Reporting Comprehensive Income | Exposed revisions reject ASU 2024-03 and ASU 2025-01 in Appendix D as not applicable to statutory accounting. |
| 2025-12EP | Preamble | Editorial Revisions | Exposed editorial footnote revisions clarify the treatment of issue papers in Level 5 of the statutory hierarchy and update the reference to U.S. Securities and Exchange Commission (SEC) rules and interpretations as authoritative U.S. GAAP for SEC registrants. |
| EXPOSURES DEFERRED for SUBSEQUENT INTERIM or NATIONAL MEETING | |||
| 2018-07 | SSAP No. 41 | 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 interim or national meeting. |
| 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 interim or national meeting. | |
|
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 interim or national meeting. | |
| SSAP No. 62 | Retroactive Reinsurance Exception | The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent interim or national 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. |
| Appendix A-791 | A-791, Paragraph 2.c. | Proposed revisions were discussed at the SAPWG Dec. 17, 2024, meeting. A joint meeting with the Life Actuarial (A) Task Force to continue discussions is scheduled for April 10. | |
| SSAP No. 61 | Risk Transfer Analysis on Combination Reinsurance Contracts | Proposed revisions were discussed at the SAPWG Dec. 17, 2024, meeting. A joint meeting with the Life Actuarial (A) Task Force to continue discussions is scheduled for April 10. | |
| 2024-12 | SSAP No. 27 | Updates to SSAP No. 27 | This agenda item was deferred at the 2024 Summer National Meeting to be discussed at a subsequent meeting. |
The following documents are exposed for a 30-day comment period ending April 23, 2025, please submit comments to Eva Yeung.
- Proposal 2024-25-CA (Principle-Based Bond Project for P/C and Health – Re-expose
- Referral from the LRBC regarding an ACLI Comment Letter
- Proposal 2024-26-CA (Tax Credit Investments for P/C and Health) - Re-expose
- Proposal 2025-07-CA (Trend Test)
The following document is exposed for a 45-day public comment period ending May 9. please submit comments to Eva Yeung.
- Re-expose Proposal 2024-16-CA (Revised Preamble) with the following questions:
- As it is currently drafted, the proposed edits in Proposal 2024-16-CA do not include any edits to the 5-year Historical Data page in Annual Statement Blanks. Are there any comments/ objections adopting the proposed edits to preamble “as is”?
- Please provide examples of ways how risk-based capital ratios are used other than the intended purposes of identifying potentially weakly capitalized companies
The following documents are exposed for a 30-day comment period ending April 23, 2025, please submit comments to Derek Noe.
- INT 24-01 Principles-Based Bond Definition Implementation Questions and Answers
- 2025-03-CA Underwriting Risk Inv Update
- INT 24-02 Medicare Part D Prescription Payment Plan
- The intent of the exposure is to solicit feedback regarding the potential ramifications of the adoption of the INT 24-02, which was adopted by Statutory Accounting Principles (E) Working Group on March 24, 2025. Please refer to https://content.naic.org/committees/e/statutory-accounting-principles-wg/adoptions for details.
The following document is exposed for a 30-day comment period ending April 23, 2025, please submit comments to Kazeem Okosun / Maggie Chang.
The Life Risk-Based Capital (E) Working Group agreed to expose the following item for a 30-day public comment period:
- 2024-21-L Tax Credit MOD
- 2024-24-L MOD Principal-Based Bond Project
- 2025-01-L C-2 Mortality Risk
- 2025-05-L Asset Concentration
Comments should be sent electronically to Kazeem Okosun by Sunday, March 23rd, 2025
The Life Risk-Based Capital (E) Working Group agreed to expose the following item for a 75-day public comment period:
Comments should be sent electronically to Kazeem Okosun by COB Monday, Jan. 6, 2025
Deferred Proposal
The Life Risk-Based Capital (E) Working Group agreed to defer the proposal.
The following document is exposed for a 30-day comment period ending April 23, 2025, please submit comments to Eva Yeung.
The following document is exposed for a 30-day comment period ending April 23, 2025, 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.
The following revisions are currently out for exposure:
- Handbook Revision Proposals
- Coordination Guidance on Timing of FEETS Calls
- Examiner-In-Charge (EIC) Responsibilities
Please send any comments to Elise Klebba (eklebba@naic.org) by close of business on April 30, 2025.
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.
The following documents are being exposed for 30-day public comment period:
- P&P Manual Amendment to Require the Filing of Private Rating Letter Rationale Reports Withing 90-days of an Affirmation, Update, or Change.
- P&P Manual Amendment to Require that Private Rating Letter Rationale Reports Possess Analytical Substance.
Comments should be sent electronically to Charles Therriault and Denise Genao by April 25, 2025.
The following document is being exposed for a 30-day public comment period ending Thursday, March 13:
Please send comments to Scott O'Neal by Thursday, March 13, 2025.
The following document's exposure period is being extended. It is now ending Friday, Nov. 22 Monday, Nov. 4:
Please send comments to Scott O'Neal by Nov. 22 Nov. 4, 2024
The following document is being exposed for a 30-day public comment period ending Thursday, Nov. 14, 2024:
Please send comments to Scott O'Neal by Nov. 14, 2024
Additionally, an excel tool that compares the 12/31/23 AIRG and GOES 2024 FT1 UST SERT Scenarios has been included to aid review of the scenarios.
There are no exposure drafts at this time.
The following document is being exposed for a 45-day public comment period ending Monday, April 7, 2025:
Please send comments to Jane Ren by April 7, 2025
The Committee exposed proposed revisions to the Review Team Guidelines that were developed by the Risk-Focused Surveillance (E) Working Group and relate to the oversight of contractors in the examination and analysis functions. Comments on the exposure are due by Friday, April 25, 2025, to Bailey Henning.
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.
Article III is being exposed as a result of the drafting group call on Dec. 19, 2024, and the regulator-only working group call on Jan. 17, 2025. Comments on Article III are NOT being requested at this time. Comments will be requested after the full exposure of the model.
Section 5 is being exposed as a result of drafting group calls on Sept. 30, Oct. 31, and the regulator-only working group call on Nov. 4. Comments on Section 5 are NOT being requested at this time. Comments will be requested after the next full exposure of the model.
Section 5 Third-Party Service Provider Arrangements
Chair Draft Amendments to Model #672 dated Aug. 5, 2024, exposed for 30-day public comment Aug. 20, 2024, with period ending Sept. 18, 2024: