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NAIC EXPOSURE DOCUMENT INDEX

The following is a list of documents exposed by various work groups of the NAIC to the public. For additional information regarding these and other documents, their comment periods and pending actions – please visit the appropriate Committees & Activities page.

There are no exposure drafts at this time.

See Financial Stability (EX) Task Force page for Liquidity Stress Test Framework Draft Exposure Document

AI Principles as Adopted by AIWG 7/1/20
Comments due to Denise Matthews by July 20, 2020.

Draft UTPA Amended Language Addressing Rebating 6/23/20
Comments regarding the proposed amendments should be submitted to Denise Matthews by July 15

ND Draft Anti-Rebating Bulletin 11/25/19

ND Draft Anti-Rebating Bulletin 10/4/19

ND Anti-Rebating Guideline 7/23/19

There are no exposure drafts at this time.

There are no exposure drafts at this time.

Proposed Subgroup Charges:

Proposed charges for three Subgroups are released for a two-week comment period. The Subgroups are intended to consolidate the workstreams of the Task Force as noted in the attached. Comments are due to Jane Koenigsman  by close of business on Thursday, July 16, 2020.

Reduced Benefit Options Draft Principles Document:

The RBO draft principles document is released for a 30-day comment period.  Comments are due to Eric King by close of business on Monday, Aug. 3, 2020.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

APF 2019-33
Please send comments to Reggie Mazyck by close of business on Oct. 5, 2020.

APF 2019-34
Please send comments to Reggie Mazyck by close of business on Sept. 18, 2020.

MO805 06/11/2020 LATF Adoption 

Life MI Subgroup Recomendation for 2020 Life MI Scale 

APF 2020-03
Generally Recognized Expense Tables (GRET) Recommendation
Please send comments to Reggie Mazyck by close of business on Aug. 25, 2020.

APF 2020-02
Please send comments to Reggie Mazyck by close of business on Mar. 4, 2020.

Amendment Proposal 2019-56 Revisions to VM-51 Data Elements for AUW – Comments due to Reggie Mazyck by October 7, 2019.
APF 2019-56 Revised Data Elements VM51 (Word)
Appendix- VM51 Data Elements markup simple (Word)
Please note that a version of 2019-56 reflecting the potential adoption of edits to amendment 2018-59 will be posted when it becomes available.

There are no exposure drafts at this time.

Comments received on Jan. 28 exposure of revisions to AG49:
Academy Comments
ACLI Comments
Allianz Comments
Global Atlantic AG49 Draft
Global Atlantic Comments
Independent Proposal Comments
IUL Coalition Comments
IUL Coalition AG49 Redline
Securian/Nationwide/Penn Mutual/Prudential/Mutual of Omaha Comments
Vincent Tsang Comments

Please provide comment on the options presented on the January 28, 2020 Subgroup call (and included in the call materials) related to the Supplemental Option Budget. Comments which provide pros and cons of either option, provide an additional option, or include proposed draft revisions to Actuarial Guideline 49 would be appreciated.

Submit comments to Reggie Mazyck by Feb. 14.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

Exposure of LR027 for VA Framework v.02.06.19
Comments should be sent electronically to David Fleming by COB Wednesday, March 6, 2019.

Re-Exposure of Proposed Revisions to Actuarial Guideline XLIII-CARVM for Variable Annuities (AG 43)
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Section 6, Standard Projection Requirements
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Section 7, Alternative Methodology, and associated edits to Section 3, Reserve Methodology

Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Section 8, Scenario Generation
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Re-Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Sections 1 through 5
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Definitions of Terms in Requirements (VM-01)
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Section 9
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of revised AG 43
Comments should be sent electronically to David Fleming by COB Friday November 9, 2018.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Varialble Annuities (VM-21), Sections 1 through 5
Comments should be sent electronically to David Fleming by COB Monday November 19, 2018.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Sections 11 and 12
Comments should be sent electronically to David Fleming by COB Monday November 19, 2018.

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.

HMO Model Adopted by the HMO Issues (B) Subgroup, July 13, 2020

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

There are no exposure drafts at this time.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

There are no current exposure drafts at this time.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

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

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

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

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

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

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

The Farmowners In Force SDR and Farmowners Claims SDR were adopted by the Working Group on its Dec. 18, 2019 call, and adopted by the Market Regulation and Consumer Affairs (D) Committee on its July 27, 2020 call.

Cybersecurity (EX) Task Force Referral to Market Conduct Examination Standards (D) Working Group

The following items have been tabled by the Working Group until further notice.

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

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

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

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

 

There are no exposure drafts at this time.

Antifraud Plan Guideline

The Antifraud Technology (D) Working Group is reviewing the April 2011 Antifraud Plan Guideline developed by the Antifraud (D) Task Force. The Working Group will be holding monthly conference calls to review comments and finalize revisions by 2020 Fall National Meeting.

 

Conference Call Schedule:

  • Thursday, May 21st   -  11am Alaska/12pm Pacific/1pm Mountain/2pm Central/3pm Eastern
  • Thursday, June 18th  -  11am Alaska/12pm Pacific/1pm Mountain/2pm Central/3pm Eastern
  • Thursday, July 16th   -  11am Alaska/12pm Pacific/1pm Mountain/2pm Central/3pm Eastern

 

 

Comments Recieved by December 31, 2019

 

Comments Applied to Guideline

 

 

There are no exposure drafts at this time.

State Licensing Handbook Review

In 2019 the Producer Licensing Uniformity (D) Working Group was given the charge to review the State Licensing Handbook. The Working Group split out the review process into sections consisting of five chapters for each review period.  The comments received and the redline chapters  can be found attached below.  The Handbook will be presented to the Executive Committee for final adoption at the Summer National Meeting.

COMMENTS RECEIVED:

Chapters 1 – 5

Chapters 6-10

Chapters 11-15

Chapters 16-20

Chapters 21-25

  • No comments at this time.

Chapters 26-30

REDLINED CHAPTERS:

 


NAIC Uniform Application

The NAIC Uniform Applications were adopted by the Market Regulation and Consumer Affairs (D) Committee at the 2018 NAIC Summer National Meeting. At this time the applications have not been presented to the NAIC Executive Committee pending an additional review and discussion of the revisions.

Continuing Education Reciprocity Agreement

In 2019 the Working Group reviewed the Continuing Education Reciprocity (CER) Agreement. The NAIC's General Counsel advised the Working Group that a revision of the agreement would not be feasible due to the date of the CER Agreement and inaccurate/dated information it contains. The decision was to create a new CER Agreement. During the Fall National Meeting the Producer Licensing (D) Task Force adopted the 2019 CER Agreement. The agreement will be presented to the Executive Committee during the Summer National Meeting for final adoption. The adopted draft is attached below.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

The Group Capital Calculation (E) Working Group has exposed the following for a 30-day comment period.

Please submit comments to Dan Daveline by COB, August 24, 2020.

There are no exposure drafts at this time. 

 

There are no exposure drafts at this time.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

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.

Blanks (E) Working Group
Items Received for Comment

Last Updated June 16, 2020

Please address comment letters to Jacob Garn, Chair of the Blanks (E) Working Group, and direct to Mary Caswell and Calvin Ferguson.

Ref No. Description Comment Deadline

2020-02BWG

 

Modify the instructions and illustration for Note 10L to reflect the disclosure changes for SSAP No. 97—Investments in Subsidiary, Controlled, and Affiliated Entities adopted by the Statutory Accounting Principles (E) Working Group. 7/28/2020
2020-22BWG Modify the instructions and illustration for Note 3A and a new Note 3E with instructions and illustrations to be data captured. Modify the blank and instructions for Schedule D, Part 6, Sections 1 and 2 (SAPWG 2020-03). 7/28/2020
2020-24BWG Remove questions 29, 30, 31 and 32 from the Supplemental Exhibits and Schedules Interrogatories. Renumber the remaining questions. 7/28/2020
2020-25BWG Add a new Column 5 to the blank for Schedule T with instructions to specifically capture the CHIP premium. Existing columns after the new Column 5 will be renumbered. 7/28/2020
2020-26BWG Add a new Column 5 to Schedule DB, Part D, Section 1 and renumber the remaining columns. Add instruction for the new Column 5, add the column reference to Column 7, and adjust other column references in crosschecks. Correct column references for this schedule on the Liability Page, Asset Page and Schedule DB Verification. Modify instruction language for the disclosure Note 8A(8). 7/28/2020
2020-27BWG

Add new category line to Schedule E, Part 2, for Qualified Cash Pools Under SSAP No. 2R (8799999) and renumber the remaining category lines. Add new disclosure 5R to the Notes to Financial Statements. The new disclosure will be data captured.

7/28/2020

 

 

Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated 7/31/2020

Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to Julie GannRobin Marcotte, Jim PinegarFatima Sediqzad and Jake Stultz.

For the status of all SAPWG agenda items, please refer to the Maintenance Agenda.
 

EXPOSURES with COMMENT DEADLINE of AUGUST 14, 2020

INT 20-02

 

Extension of the Ninety-Day Rule for the Impact of COVID-19 Exposed revisions extend this interpretation, issued in response to COVID-19, to the third quarter 2020 financial statements. With these revisions, this interpretation will expire December 30, 2020; therefore, it will not be applicable for year-end 2021. Adoption of this extension may be considered by an e-vote if there are no concerns with the extension received during the exposure period.
INT 20-04   Mortgage Loan Impairment Assessment Due to COVID-19 Exposed revisions extend this interpretation, issued in response to COVID-19, to the third quarter 2020 financial statements. With these revisions, this interpretation will expire December 30, 2020; therefore, it will not be applicable for year-end 2021. Adoption of this extension may be considered by an e-vote if there are no concerns with the extension received during the exposure period.
INT 20-05   Investment Income Due and Accrued Exposed revisions extend this interpretation, issued in response to COVID-19, to the third quarter 2020 financial statements. With these revisions, this interpretation will expire December 30, 2020; therefore, it will not be applicable for year-end 2021. Adoption of this extension may be considered by an e-vote if there are no concerns with the extension received during the exposure period.
EXPOSURES with COMMENT DEADLINE of SEPTEMBER 18, 2020
2019-24

SSAP No. 71

Levelized and Persistency Commission Exposed revisions clarify existing levelized commissions guidance which requires full recognition of the funding liabilities incurred to date for commission expenses prepaid on behalf of an insurer. The exposed revisions are consistent with the 2019 Fall National Meeting exposure, with the inclusion of guidance to clarify that reporting entities that have not complied with the original intent shall reflect the change as a correction of an error, in accordance with SSAP No. 3—Accounting Changes and Corrections of Errors, in the year-end 2020 financials.
2019-34 SSAP No. 25 Related Parties, Disclaimers of Affiliation and Variable Interest Entities Revisions clarify that non-controlling ownership over 10% results in a related party classification regardless of any disclaimer of control or disclaimer of affiliation, a disclaimer of control does not eliminate the classification as a related party, and disclosure of material transactions are required under SSAP No. 25. The revisions also propose rejection of several U.S. GAAP standards addressing variable interest entities and include an update to the related party disclosures.
2020-17

SSAP No. 97

Sub 1

Sub 2

Updating the SCA Review Process Revisions update the subsidiary, controlled and affiliated entities (SCA) review process descriptive language and the procedures for availability and delivery of completed SCA reviews for domestic regulators and financial statement filers.
2020-18 SSAP No. 97 SSAP No. 97 Update Revisions remove the statement that guarantees or commitments from the insurance reporting entity to the SCA can result in a negative equity valuation.
2020-19 SSAP No. 37 Clarifying Edits - Participating in Mortgages Revisions clarify that a participant’s financial rights in a mortgage participation agreement may include the right to take legal action against the borrower or participate in the determination of legal action, but they do not require that the participant has the right to solely initiate legal action; foreclosure; or under normal circumstances, require the ability to communicate directly with the borrower.
2020-20

 

SSAP No. 2R

 

Cash Equivalent Disclosures Revisions require the identification/disclosure of cash equivalents, or substantially similar investments, that remain on the same reporting schedule for more than one consecutive reporting period. This is an expansion of the current disclosure requirements that only referenced short-term investments and to clarify that the disclosure is satisfied through the use of the code on the investment schedules.
2020-21 SSAP No. 43R Designation Categories for RMBS/CMBS Investments Revisions reflect the updated NAIC designation category guidance for residential mortgage-backed securities (RMBS)/commercial mortgage-backed securities (CMBS) recently adopted to the Purposes and Procedures Manual of the NAIC Investment Analysis Office (P&P Manual).
2020-22 SSAP No. 26R Accounting for Perpetual Bonds Revisions clarify that perpetual bonds shall be reported at fair value, not to exceed any currently effective call price, with a proposed effective date of January 1, 2021, with early application permitted.
2020-23 SSAP No. 22R Leasehold Improvements Revisions update the amortization guidance for leasehold improvements. The updated language will allow leasehold improvements to have lives that match the associated lease term, which agrees with U.S. Generally Accepted Accounting Principles (GAAP).
2020-24 SSAP No. 43R Accounting and Reporting of Credit Tenant Loans Exposed agenda item to solicit comments on two options for the accounting of credit tenant loans (CTLs). The Valuation of Securities (E) Task Force will be notified of this exposure with a request for further confirmation that a Securities Valuation Office (SVO)-Listing could be developed to capture the CTLs that meet the SVO’s structural and legal analysis and possess bond characteristics. 
2020-25EP

SSAP No. 5R

SSAP No. 62R

Editorial Updates Exposed editorial revisions.
2020-26 Appendix D ASU 2015-10, Technical Corrections and Improvements Exposed revisions to reject ASU 2015-10 as not applicable to statutory accounting.
2020-27 Appendix D ASU 2019-09, Financial Services–Insurance (Topic 944): Effective Date Exposed revisions to reject ASU 2019-09 as not applicable to statutory accounting.
2020-28 Appendix D ASU 2020-01, Investments—Equity Method and Joint Ventures (Topic 323), and Derivatives and Hedging (Topic 815), Clarifying the Interactions between Topic 321, Topic 323, and Topic 815 Exposed revisions to reject ASU 2020-01 as not applicable to statutory accounting.
2020-29 Appendix D ASU 2020-05, Effective Dates for Certain Entities Exposed revisions to reject ASU 2020-05 as not applicable to statutory accounting.
2020-30

SSAP No. 53

SSAP No. 54R

SSAP No. 66

Premium Refunds and Other Adjustments Exposed agenda item with a request for comments on the development of authoritative guidance for policyholder refunds and other premium adjustments for accident and health and property and casualty lines of business. Assistance from industry was requested in developing principles-based guidance, particularly for the varieties of data-telematics policies.
EXPOSURES with COMMENT DEADLINE of JULY 31, 2020
2019-21

SSAP No. 43R

IP No. 1XX

SSAP No. 43R

Interested Party Comment Letter, July 31, 2020

Exposed a preliminary issue paper to provide initial information and key concepts that are being considered. Comments and information are requested on the issues and questions presented within the document.

EXPOSURES DEFERRED for SUBSEQUENT INTERIM or NATIONAL MEETING

2018-07

SSAP No. 41R

Surplus Note Accounting – Referral from the Reinsurance (E) Task Force

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

2019-12

SSAP No. 68

ASU 2014-17, Business Combinations, Pushdown Accounting

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

2019-49

SSAP No. 62R

Retroactive Reinsurance Exception

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

The Capital Adequacy (E) Task Force is exposing the following proposasl for a 30-day comment period ending Sept. 4th.

  • 2020-02- CA - removing ACA Fee Sensitivity test from each formula. Submit comments to the Health RBC Working Group Chair by emailing to staff support Crystal Brown.
  • 2021 Charges – submit comments to Tom Botsko, Task Force chair by emailing to staff support Jane Barr.

There are no exposure drafts at this time.

Exposure on Suggested Edits to the RBC Forms & Instructions for C-2b Longevity Risk
Comments should be sent electronically to Dave Fleming by COB Monday, August 10, 2020.

2018-11-L-Life RBC Tax Proposal
Please send comments to Dave Fleming by the close of business, June 5, 2018. (Please consider whether a printed copy in its entirety is needed as there are 161 pages in the document.)

Asset Valuation Reserve Proposal

2017 to 2018 Comparison

Worksheet Showing Factors:

AVR RBC 2017 and Proposed 2018 Factors

Please send comments to Dave Fleming by the close of business, June 5, 2018.

Exposure Drafts Still Open For Consideration with Comment Received:

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

There are no exposure drafts at this time.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

The Financial Analysis Solvency Tools (E) Working Group has exposed the following for a 30-day comment period.

Please submit comments to Ralph Villegas, at rvillegas@naic.org by August 26th.

There are no exposure drafts at this time.

There are no exposure drafts at this time. 

There are no exposure drafts at this time.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

On May 4, 2020, the Reinsurance (E) Task Force exposed a new Uniform Checklist for Reciprocal Jurisdiction Reinsurers and updates to the existing Uniform Application Checklist for Certified Reinsurers. These updates are a result of the 2019 revisions to the Credit for Reinsurance Model Law (#785) and the Credit for Reinsurance Model Regulation (#786). The public comment period deadline is May 26, 2020, and comments should be directed to NAIC support staff Jake Stultz and Dan Schelp.

Comment Letters:


On February 5, 2020, the Reinsurance (E) Task Force exposed a memorandum and supporting documents providing a comparison between the Term and Universal Life Insurance Reserve Financing Model Regulation (#787) and Actuarial Guideline XLVIII (AG 48). Specifically, the memorandum requests comments on whether compliance with AG 48 should be considered to be “substantially similar” to Model #787 under the NAIC Financial Standards and Accreditation Program. The public comment period deadline is February 26, 2020, and comments should be directed to NAIC support staff Jake Stultz and Dan Schelp.

Comment Letters:

 

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.

Exposure of LR027 for VA Framework v.02.06.19
Comments should be sent electronically to David Fleming by COB Wednesday, March 6, 2019.

Re-Exposure of Proposed Revisions to Actuarial Guideline XLIII-CARVM for Variable Annuities (AG 43)
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Section 6, Standard Projection Requirements
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Section 7, Alternative Methodology, and associated edits to Section 3, Reserve Methodology

Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Section 8, Scenario Generation
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Re-Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Sections 1 through 5
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Definitions of Terms in Requirements (VM-01)
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Section 9
Comments should be sent electronically to David Fleming by COB Tuesday, January 22, 2019.

Exposure of revised AG 43
Comments should be sent electronically to David Fleming by COB Friday November 9, 2018.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Varialble Annuities (VM-21), Sections 1 through 5
Comments should be sent electronically to David Fleming by COB Monday November 19, 2018.

Exposure of Proposed Revisions to Requirements for Principle-Based Reserves for Variable Annuities (VM-21), Sections 11 and 12
Comments should be sent electronically to David Fleming by COB Monday November 19, 2018.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

 

 

 

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