EXPOSURE DOCUMENT INDEX

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.

• Direction to NAIC Staff on RBC Blanks Proposal

LIFE WORKSTREAM 

Comments request by Sept 5 on Draft Survey on Criminal History

AAA Comments

ACLI Comments

DC DISB Comments

Peter Kochenburger Comments

CEJ Comments 

Shannon Ross Comments

SPECIAL SECTION: Health Care Reform (PPACA) Implementation:
NAIC Activities | FAQ

Enhanced Cash Surrender Value Offer Survey

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

COMMENTS ON THE JULY 11, 2024 DRAFT GUIDANCE DOUMENT ARE REQUESTED BY COB JULY 26, 2024 

        AUWG Regulatory Guidance - July 11 Draft

COMMENTS ON THE JUNE 3, 2024 DRAFT GUIDANCE DOCUMENT AND DRAFT REFERRAL REQUESTED BY COB JUNE 30, 2024

        AUWG Regulatory Guidance - June 3 Draft 

              Comments received

              1 - ACLI 

              2 - Consumer Reps

        AUWG Referral to Market Conduct Examination Guidelines (D) Working Group - June 3 Draft

        Full Guidance with Appendices (PDF)

        Explanation of revisions to June 3 Drafts

COMMENTS ON JAN 11, 2023 DRAFT REFERRAL REQUESTED BY MARCH 24, 2023 

        AUWG Referral to Market Conduct Examination Guidelines (D) Working Group 

              Comments received

              1 -  cej_comments_naic_auwg_230324_mceg_wg_referral_0.pdf

COMMENTS ON THE JAN 25, 2023 DRAFT GUIDANCE DOCUMENT ARE REQUESTED BY APRIL 14, 2023

        AUWG Draft Regulatory Guidance Document 

             Comments received 

             1 - ACLI%20Comments%20on%20the%20AUWG%20Draft%20Regulatory%20Guidance.pdf

             2 - CEJ%20Comments%20on%20AUWG%20Draft%20Regulatory%20Guidance_0.pdf

             3 - CIR%20Comments%20on%20AUWG%20Draft%20Regulatory%20Guidance.pdf

             4 - Connecticut%20DOI%20Comments%20on%20Draft%20Regulatory%20Guidance.pdf

Chair Draft Safe Harbor Guidance Document (Draft Date Sept. 23, 2024)

The following documents are being exposed for a 45-day public comment period ending Monday, Jan. 27:

• APF 2024-16

Please send comments to Scott O'Neal by Jan. 27, 2024

This can also be found under the “Exposure Drafts” tab on the Life Actuarial (A) Task Force Web page.

The following document is being exposed for a 14-day public comment period ending Monday, Dec. 2:

• APF 2024-13

Please send comments to Scott O'Neal by Dec. 2, 2024

The following document is being exposed for a 21-day public comment period ending Monday, Dec. 9:

• APF 2024-15

Please send comments to Scott O'Neal by Dec. 9, 2024

The following documents are being exposed for a 51-day public comment period ending Wednesday, Jan. 8:

• Academy Knowledge Statements Presentation 1124
• Academy Qualified Actuary Knowledge Statement Comment Letter 1124
• Academy Response to LATF Public Comments 1024
• LATF Appointed Actuary Knowledge Statements Redline Changes 1124

Please send comments to Scott O'Neal by Jan. 8, 2024

The following document is being exposed for a 58-day public comment period ending Wednesday, Jan. 15:

• Asset Adequacy Testing (AAT) for Reinsurance Actuarial Guideline (AG) Exposure Questions 111824
• AAT for Reinsurance AG Presentation LATF 111524
• Draft AG ReAAT 111524

Please send comments to Scott O'Neal by Jan. 15, 2024

There are no exposure drafts at this time.

There are no Exposure Drafts at this time. 

The following document is being exposed for a public comment period ending, Friday, February 7, 2025:

• SPA Policyholder Behavior Assumptions Proposed Edits

Please send comments to Amy Fitzpatrick by close of business on February 7, 2025.

The following documents are being exposed for a  public comment period ending Monday, December 9, 2024:

• NJ DOBI - Response 
• NJ DOBI - Proposed Amendment 
• NJ DOBI - VM-22 Longevity Reinsurance Reserving Proposal

Please send comments to Amy Fitzpatrick by close of business on December 9, 2024.

The following document's exposure period is being extended. It is now ending Friday, November 22nd Monday, November 4^th:

• Draft GOES Model Governance Framework

Please send comments to Scott O'Neal by November 22nd November 4^th, 2024

The following document is being exposed for a 30-day public comment period ending Thursday, Nov. 14, 2024:

• GOES SG SERT Scenario, DR, and Scenario Statistics Exposure 101624

Please send comments to Scott O'Neal by Nov. 14^th, 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.

• SERT Scenarios – 123123 GOES vs. AIRG UST

There are no exposure drafts at this time.

The following document is being exposed for a 90-day public comment period ending Tuesday, Jan. 21, 2025:

• Draft Additions to the Variable Annuities Supplement in the Annual Statement

Please send comments to Jane Ren by Jan. 21, 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, October 31.

The Working Group requests comments on the Minnesota Approach with adjustments to haircut percentages and cumulative rate increase ranges of the cost-sharing formula as shown in Proposal A and Proposal B below as candidates for a Single LTCI Multistate Rate Review Approach. The adjustments are intended to address the “85/25/400” issue as discussed at the Working Group’s Aug. 12 meeting.

 LTCAWG Proposals A & B.pdf

The Minnesota Approach, including the current cost-sharing formula, is described here: https://content.naic.org/sites/default/files/documents/ltci-msa-framework.pdf

Please provide comments to eking@naic.org by Friday, September 27.

_____________________________________________________________________

The Working Group requests comments on the Minnesota Approach with adjustments to haircut percentages or cumulative rate increase ranges of the cost-sharing formula as a candidate for a Single LTCI Multistate Rate Review Approach. The adjustments are intended to increase cost-sharing burden for the company where cumulative rate increases are very high (which tends to be the case for higher-age policyholders, higher-duration policies) and potentially decrease cost-sharing burden for the company for lower-duration policies.

The Minnesota Approach, including the current cost-sharing formula, is described here: https://content.naic.org/sites/default/files/documents/ltci-msa-framework.pdf

Please provide comments to eking@naic.org by Thursday, August 1.

_______________________________________________________

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?

Proposed Revisions to Model #171 (Track Version) (Adopted by the Task Force on Nov. 4, 2024)

Proposed Revisions to Model #171 (Clean Version) (Adopted by the Task Force on Nov. 4, 2024)

Proposed 2025 Charges (Regulatory Framework Task Force 2025 Proposed Charges)

Proposed Revisions to Model #171 (Tracked Version) (Adopted by the Subgroup on Oct. 17, 2024)

Proposed Revisions to Model #171 (Clean Version) (Adopted by the Subgroup on Oct. 17, 2024)

Comments are requested by close of business April 21, 2022

ERISA Handbook case summary - Rutledge 

     Comments received 

PCMA

ATAP

Consumer Reps

NCPA 

AHIP

The following document is being exposed for a public comment period ending Friday, December 13th, 2024: 

• Long-Term Care Insurance Multistate Rate Review Framework

Please send comments to Jane Koenigsman by EOD December 13th. 

Redline LTC Guide as adopted by WG

TF-adopted Ltd LTCI Model Act

TF-adopted Ltd LTCI Model Regulation

LTC Redline Model Act

LTC Redline Model Regulation 

Revised Task Force 2018 Proposed Charges

MLR #640

MLR #641

LTC Model Act (#640)

LTC Model Regulation (#641)

LTC Guidance Manual

Model 651 Sections 9.1 and 9.2

Medigap Plans Sold on or after 1-1-2020 Chart

Plan G or High Deductible Plan G Chart

Plan F or High Deductible Plan F Chart

LTC Guide 2013 Edition REDLINED

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, November 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 Appendix B-RGLM to White Paper revised document for 30 days.

Appendix B-RGLM to White Paper Revised _without Redline.pdf

Appendix B-RGLM to White Paper Revised _with Redline.pdf

Please provide comments to Kris DeFrain, kdefrain@naic.org, by Friday, September 13, 2024.

The following document is being exposed for a 21-day public comment period ending Monday, October 14^th:

AOWG Regulatory Guidance - 2024 Exposure Draft.docx

Please send comments to Kris DeFrain by October 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. 

Proposed  Amendments to the Public Adjuster Licensing Model Act (#228)

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.

Public Adjuster Model Draft

Public Adjuster Model Comments

MLR Public Adjuster Model

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. 

Remaining Monthly Calls:

• Wednesday, November 6, 2024 at 2PM EST/1PMCST

• Chapter 18 Adjuster Licensing (Current Version) -  WORD / PDF
• Chapter 18 Adjuster Licensing (Draft W/Track Changes) - PDF

Comments Received:

• DE DOI Comments
   
• FL DOI Comments
   
• KY DOI Comments
   
• NC DOI Comments
   
• TX DOI Comments
   
• UT DOI Comments
   
• VA DOI Comments
   
• State Farm Comments /  Part 2
   
• SILA Comments (2019)

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 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.)

• MO 07-06-23 Comments
• IRI 07-06-23 Comments
• CEJ 09-06-23 Comments Received 09-07-23

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.) 

• Joint CEJ & IIABA 09-16-22 Comments
• CEJ 09-16-22 Comments
• IRI 09-16-22 Comments

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))

• VA 05-25-22 Comments
• MO 05-27-22 Comments
• IRI 05-27-22 Comments

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
  • VA 10-28-22 Comments
  • MO 09-16-22 Comments
  • CEJ 09-16-22 Comments

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))

• MO 07-06-23 Comments

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

• Title In Force SDR August 26, 2021 Draft
• Title Claims SDR August 26, 2021 Draft

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.

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

• Long-Term Care In Force SDR October 14, 2020 Draft
• Long-Term Care Claims SDR October 14, 2020 Draft

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

• Inland Marine In Force SDR February 24, 2020 Draft
• Inland Marine Claims SDR February 24, 2020 Draft

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

• Nebraska December 3, 2019 Comments

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

• Farmowners In Force SDR, December 11, 2019 Draft
• Farmowners Claims SDR, October 29, 2019 Draft

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

• WV 03/16/2017 Comments
• CEJ 03/12/2017 Comments

Draft New Health Reform Market Conduct Examination Standards for Nondiscrimination for inclusion in the Market Regulation Handbook
Aug. 10, 2015 Draft

• NAIC Consumer Representatives' 9/03/15 Comments
• National Women's Law Center (NWLC) 9/03/15 Comments

Draft New Health Reform Market Conduct Examination Standards for Nondiscrimination for inclusion in the Market Regulation Handbook
Aug. 3, 2015 Draft

• WA 8/04/15 Comments

Section D. Standards of Chapter 14-Sampling of the Market Regulation Handbook 9/18/14

• MO 9/11/14 Comments
• AIA 9/12/14 Comments

There are no exposure drafts at this time.

MCAS - Pet Insurance Scorecard Ratios Draft

• Pet Insurance Scorecard Ratios v1.9 2/21/2024
  • NAMIC     3/21/2024
  • NAPHIA   3/22/2024

Charge to Assess Currently Available Market Analysis Data

• Market Analysis Data Sources 6/23/2023

Draft Documents

MCAS Proposals

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, October 16, 2023.  

The Task Force met by conference call on October 20^th 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):

• Model 880 Amendments - Draft #6 (10.20.23)
   

Comments Received on Draft #6 (10.20.23):

• ACLI & AHIP Comment Letter

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

Draft #5 (8.14.23):

• Model 880 Amendments - Adopted by IMHIWG 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

Artificial Intelligence (AI) in MIS Recommendations

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

• Texas 11/19/2021
• NAMIC 11/19/2021
• CEJ 11/22/2021

RIRS Coding Change Proposal

RIRS Coding Change Proposal  posted 3/25/2021

• CEJ 5/1/2021
• California 6/16/2021

There are no exposure drafts at this time.

Product Filing Review Handbook 11/2023

PFRH Table of Contents 11/2023

PFRH Table of Chapter Numbering and Name Changes 11/2023

Product Filing Review Handbook August, 2016

Product Filing Review Handbook 11/2023

• Pennsylvania 01/18/2024

PFRH Table of Contents 11/2023

PFRH Table of Chapter Numbering and Name Changes 11/2023

Product Filing Review Handbook August, 2016

Public Adjuster Licensing Model Act – Comment Deadline of Aug. 30

Uniform Application Estimate Review - Comment Deadline of Sept. 12

Appendix A to Uniform Application Estimate Review - Comment Deadline of Sept. 12

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, November 21^st. 

• Uniform Licensing Standards Chart

NAIC STATE LICENSING HANDBOOK REVIEW 

The Producer Licensing Uniformity (D) Working Group has been given the charge to:  Provide oversight and ongoing updates, as needed, to the State Licensing Handbook.

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 November 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:

• CA
   
• ID
   
• KS
   
• NC
   
• OH
   
• RI
   
• TX
   
• VA
   
• WA
   
• Compiled 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 and 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

CE Audit Procedures

The Uniform Education (D) Working Group adopted the NAIC CE Audit Guidelines on October 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)

CE Audit Procedures Checklist

Checklist Responses:

• CA DOI
   
• FL DOI (Comments to draft)
   
• KS DOI
   
• ME DOI
   
• NC DOI
   
• NM DOI
   
• RI DOI

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.

• 2019 Continuing Education Reciprocity Agreement

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Testing and Examination Pass Rates

• 2020 Pass Rates
   
• 2022 Pass Rates
   
• 2023 Pass Rates

Exposure Drafts Still Open For Consideration with Comments Received:

Investment Framework

• Memo from E Committee to Interested Parties
• Investment Framework as Revised E Committee
• Investment Framework Workplan
• Comment Letters

There are no Exposure Drafts at this time.

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.

• Proposal 2024-19-I
• SSG presentation

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.

• Memorandum on Consideration of Additional Information on Interim Factor for Residual Tranches

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

• Oliver Wyman Residual Tranche Report

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

• 2023-09-IRE Residual Factor
• 2023-10-IRE Sensitivity Test Factor

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.

• Additional Market and Analytical Information for Bond Investments 

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.  

• Revised Residuals Structure
• Sensitivity Test

There are no exposure drafts at this time.

The Financial Stability (E) Task Force has exposed the following item for a 30-day public comment period ending December 17, 2024. 

Please submit comments to Tim Nauheimer and Aida Guzman by COB December 17, 2024.

• Draft 2024 LST Framework - Nov 4

The Financial Stability (E) Task Force has exposed the following item for a 30-day public comment period ending December 17, 2024. 

Please submit comments to Tim Nauheimer and Aida Guzman by COB December 17, 2024.

• Draft 2024 LST Framework - Nov 4

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. 

During the July 24^th call,  the National Treatment and Coordination (E) Working Group discussed the below referral, which was received in 2023, and updates to the Company Licensing Best Practices Handbook. The Working Group is exposing the Company Licensing Best Practices Handbook for a 45-day comment period ending Sept. 20,  2024, please submit comments on the edits or suggestions for additional edits to Jane Barr.

• 2023 FAWG Referral to NTCWG
• Company Licensing Best Practices Handbook

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

• Best Practices Procedures for IBT/Corporate Divisions
• Restructuring Mechanisms White Paper

Comment Letters:

• AIRROC
• Enstar
• Maine Bureau of Insurance
• NOLHGA/NCIGF
• Norton Rose Fulbright
• NY Life/Western & Southern FG/Mass Mutual/Northwestern Mutual
• Risk and Regulatory Consulting

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 December 17, 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.

Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated December 17, 2024

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 August 13, 2024)

he Task Force is exposing the following proposals for a 75-day public comment period ending Feb. 1, 2025, please submit comments to Eva Yeung.

• 2024-25-CA (Principle-Based Bond Project for P/C and Health)
• 2024-26-CA (Tax Credit for Health and P/C)

The Life Risk-Based Capital (E) Working Group agreed to expose the following item for a 75-day public comment period:

• 2024-21-L Tax Credit
• 2024-24-L Principle-Based Bond Project

Comments should be sent electronically to Kazeem Okosun by COB Monday, January 6, 2025

Deferred Proposal

• 2024-07-L  Other Long-Term Assets

The Life Risk-Based Capital (E) Working Group agreed to defer the proposal.

The Capital Adequacy (E) Task Force and the Property and Casualty Risk-Based Capital (E) Working Group are exposing the following for a 7-day public comment period ending November 13, 2024, please submit comments to Eva Yeung.

• Proposal 2024-23-CR

The following document is exposed for a 30-day comment period ending Nov. 6, 2024, please submit comments to Derek Noe.

• 2024-22-CR Severe Convective Storm (2024)

The Capital Adequacy (E) Task Force and the Property and Casualty Risk-Based Capital (E) Working Group are exposing the following for a 7-day public comment period ending November 13, 2024, please submit comments to Eva Yeung.

• Proposal 2024-23-CR

The following document is exposed for a 30-day comment period ending Nov. 6, 2024, please submit comments to Derek Noe.

• 2024-22-CR Severe Convective Storm (2024)

The following document is being exposed for a public comment period ending Monday, Sept. 17^th:

• 2025 EOTF Proposed Charges

Please send comments to Bailey Henning by Sept. 17^th, 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. 

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 document's exposure period is being extended. It is now ending Friday, November 22nd Monday, November 4^th:

• Draft GOES Model Governance Framework

Please send comments to Scott O'Neal by November 22nd November 4^th, 2024

The following document is being exposed for a 30-day public comment period ending Thursday, Nov. 14, 2024:

• GOES SG SERT Scenario, DR, and Scenario Statistics Exposure 101624

Please send comments to Scott O'Neal by Nov. 14^th, 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.

• SERT Scenarios – 123123 GOES vs. AIRG UST

There are no exposure drafts at this time.

The following document is being exposed for a 90-day public comment period ending Tuesday, Jan. 21, 2025:

• Draft Additions to the Variable Annuities Supplement in the Annual Statement

Please send comments to Jane Ren by Jan. 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.

There are no exposure drafts at this time.

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:

Chair Draft Amendments to #672 8.5.24.pdf