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.
2021 Proposed Charges
Submit comments to Jennifer Gardner by Oct. 28, 2020.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
RBO Principles
RBO Consumer Notices Principles
Comments due to Eric King by Monday, Nov. 9, 2020.
There are no exposure drafts at this time.
Comments due to Todd Sells by COB Oct. 5, 2020
Liquidity Assessment Subgroup Revised Model 440 - Sept 1 Draft for Referral
Comments due to Tim Nauheimer and Todd Sells by COB Feb. 10, 2020
Liquidity Stress Test Framework Draft
See Financial Stability (EX) Task Force page for Liquidity Stress Test Framework Draft Exposure Document
Draft Revised UTPA Amended Language Addressing Rebating 8/10/20
Comments regarding the revised proposed amendments should be submitted to Denise Matthews by Aug. 28, 2020.
AI Principles as Adopted by AIWG 7/1/20
Comments due to Denise Matthews by July 20, 2020.
Draft UTPA Amended Language Addressing Rebating 6/23/20
Comments regarding the proposed amendments should be submitted to Denise Matthews by July 15, 2020.
ND Draft Anti-Rebating Bulletin 11/25/19
ND Draft Anti-Rebating Bulletin 10/4/19
ND Anti-Rebating Guideline 7/23/19
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
3-14-20 #245 Draft Revisions (based on 3-13-20 Conference call)
Draft Model #275 Revisions FAQ Implementation Document, Draft Dated Sept. 4 Draft FAQ
Comments on the substance of the attached Sample Policy Overviews are requested by August 28.
Comments received:
The following document is being exposed for a 7-day public comment period.
Please send comments to Reggie Mazyck by close of business on Oct. 28, 2020.
The following documents are being exposed for a 10-day public comment period.
Please send comments to Reggie Mazyck by close of business on Nov. 2, 2020.
These documents are being exposed for a 30-day public comment period.
Please send comments to Reggie Mazyck by close of business on Nov. 10, 2020.
Past Exposures:
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.
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.
There are no exposure drafts at this time.
QTL Template.xlsx Pennsylvania Revised Draft QTL Template Draft May 28, 2020
QTL Template Instructions.docx Revised Draft QTL Template Instructions May 28, 2020
MHPAEA assumptions exposure.docx MHPAEA Draft Assumptions March 10, 2020
There are no exposure drafts at this time.
HMO Model Adopted by the Regulatory Framework Task Force, Sept. 24, 2020
RFTF 2021 Proposed Charges Revised Regulatory Framework Task Force 2021 Proposed Charges Revised Oct. 12, 2020
ERISA Handbook OCTOBER 11, 2018 Draft
Comments requested by October 26, 2018
ERISA Handbook Draft Revisions 7-20-18 (footnotes corrected 8/16/18)
Comments requested by 9-28-18
HMO Model Draft Adopted by the Subgroup, July 13, 2020
PBM Model Draft Draft Dated July 6, 2020
There are no exposure drafts at this time.
LPI Model - Redlined
Comments due to Aaron Brandenburg by Nov. 3, 2020.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
Comments on Academy's Qualification Standards
Submit comments to Kris DeFrain by Oct. 19, 2020.
There are no exposure drafts at this time.
There are no current exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
None at this time.
Comments Due Date: November 13, 2020
New Draft Long-Term Care Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
Comments Due Date: November 13, 2020
New Inland Marine Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
The Inland Marine In Force and Inland Marine Claims SDRs were adopted by the Working Group on its July 23, 2020 call.
The Limited Long-Term Care Exam Standards, Dec. 11, 2019 draft, were adopted by the Working Group on its July 23, 2020 call.
New Farmowners Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
The Farmowners In Force SDR and Farmowners Claims SDR were adopted by the Working Group on its Dec. 18, 2019 call, and adopted by the Market Regulation and Consumer Affairs (D) Committee on its July 27, 2020 call.
Cybersecurity (EX) Task Force Referral to Market Conduct Examination Standards (D) Working Group
The following items have been tabled by the Working Group until further notice.
Draft New Health Reform Market Conduct Examination Standards for Nondiscrimination for inclusion in the Market Regulation Handbook
Aug. 10, 2015 Draft
Draft New Health Reform Market Conduct Examination Standards for Nondiscrimination for inclusion in the Market Regulation Handbook
Aug. 3, 2015 Draft
Section D. Standards of Chapter 14-Sampling of the Market Regulation Handbook 9/18/14
There are no exposure drafts at this time.
The Antifraud Technology (D) Working Group has been reviewing the 2011 NAIC Antifraud Plan Guideline for potential revisions. The focus has been to reorganize the guidelines into a more intuitive order, to eliminate repetitive requirements within the existing guidelines, and add suggestions to better meet existing requirements for nearly all states.
In order to finalize the review of the NAIC Antifraud Plan Guideline the Working Group will be holding conference calls through October. The dates for the scheduled conference calls are listed below.
Conference Call Schedule:
- Thursday, September 17th - 9am Alaska/10am Pacific/11am Mountain/12pm Central/1pm Eastern
- Wednesday, October 14th - 9am Alaska/10am Pacific/11am Mountain/12pm Central/1pm Eastern
- Thursday, October 29th - 9am Alaska/10am Pacific/11am Mountain/12pm Central/1pm Eastern
Comments Received by January 5, 2020
- MN DOI - 1.2.20
- Center For Economic Justice - 3.12.20
- Coalition Against Insurance Fraud - 12.26.20
- NAMIC - 1.11.20
- NICB - 12.26.20
Comments Received by September 8, 2020 (Draft 3 8.3.20)
- AIG - 9.5.20
- Center For Economic Justice - 9.8.20
- Coalition Against Insurance Fraud - 9.8.20
- All Comments Compiled - 9.16.20
Guideline Drafts
- NAIC 2011 Antifraud Plan Guideline - Draft 2 W/Track Changes 3.12.20)
- NAIC 2011 Antifraud Plan Guideline - Draft 3 Redline (8.3.20) / NAIC 2011 Antifraud Plan Guideline - Draft 3 - Clean (8.3.20)
- NAIC 2011 Antifraud Plan Guideline - Draft 4 - Redline (10.14.20) / NAIC 2011 Antifraud Plan Guideline - Draft 4 - Clean (10.14.20)
There are no exposure drafts at this time.
There are no exposure drafts at this time.
State Licensing Handbook Review
In 2019 the Producer Licensing Uniformity (D) Working Group was given the charge to review the State Licensing Handbook. The Working Group split out the review process into sections consisting of five chapters for each review period. The comments received and the redline chapters can be found attached below. The Handbook will be presented to the Executive Committee for final adoption at the Summer National Meeting.
COMMENTS RECEIVED:
- No comments at this time.
REDLINED CHAPTERS:
NAIC Uniform Application
The NAIC Uniform Applications were adopted by the Market Regulation and Consumer Affairs (D) Committee at the 2018 NAIC Summer National Meeting. At this time the applications have not been presented to the NAIC Executive Committee pending an additional review and discussion of the revisions.
Continuing Education Reciprocity Agreement
In 2019 the Working Group reviewed the Continuing Education Reciprocity (CER) Agreement. The NAIC's General Counsel advised the Working Group that a revision of the agreement would not be feasible due to the date of the CER Agreement and inaccurate/dated information it contains. The decision was to create a new CER Agreement. During the Fall National Meeting the Producer Licensing (D) Task Force adopted the 2019 CER Agreement. The agreement will be presented to the Executive Committee during the Summer National Meeting for final adoption. The adopted draft is attached below.
There are no exposure drafts at this time.
Below are the revised drafts of the NAIC Holding Company Act and Regulation which incorporate the decisions made by the Working Group on the Oct. 20th call. Submit comments by COB October 30th to Dan Daveline.
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 proposals are exposed for a 30-day comment period ending Sept. 25th. Please submit comments via email to Jane Barr.
- 2020-01 Electronic Notary -the purpose of this modification to Form 11 (Biographical Affidavit) and Form 15 (Affidavit of Lost Certificate of Authority) to accept an electronic notary in addition to a wet notary. States- comments should include whether your state has specific language that would need to be included on the notary page of either form.
- 2020-02 Inclusion of the corporate governance annual disclosure (CGAD) as a requirement to the Primary – Redomestication application.
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 RFSWG and ORSA Implementation Subgroup agreed to expose the proposed Handbook revisions for a 30-day public comment period ending on Sep. 30. Comments should be submitted to Bruce Jenson (BJenson@naic.org).
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 October 21, 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 |
| 2020-28BWG | Remove the disclosure for the Affordable Care Act Section 9010 Assessment from Note 22 - Events Subsequent. The purpose of this proposal is to reflect disclosure changes adopted by the Statutory Accounting Principles (E) Working Group superseding SSAP No. 106—Affordable Care Act Section 9010 Assessment (Ref #2020-05). The Affordable Care Act Section 9010 assessment has been repealed effective Jan. 1, 2021, and these revisions will remove the disclosure. | 11/23/2020 |
| 2020-29BWG | Remove the line category and reference to the NAIC Bond Fund List (Bond List) from the investment schedule instructions and blank. The purpose of this proposal is to reflect disclosure changes adopted by the Statutory Accounting Principles (E) Working Group superseding SSAP No. 26R—Bonds and SSAP No. 30R—Unaffiliated Common Stock (Ref #2020-01) to eliminate references to the NAIC Bond Fund List (Bond List). | 11/23/2020 |
| 2020-30BWG | Move the interrogatory question regarding Communication of Internal Control Related Matters Noted in Audit from the Annual Supplemental Exhibits and Schedules Interrogatories to the Quarterly Supplemental Exhibits and Schedules Interrogatories to be answered for the 2nd Quarter. For Title, a new page in the quarterly statement will be added for the Supplemental Exhibits and Schedules Interrogatories. | 11/23/2020 |
| 2020-31BWG |
Replace the Life, Health and Annuity Guaranty Association Model Act Assessment Base Reconciliation and the Adjustments to the Life, Health and Annuity Guaranty Association Model Act Assessment Base Reconciliation Exhibits with modernized exhibits in order to promote consistent reporting of assessable premiums among industry members and to reflect changes in guaranty association laws adopted over the past two decades. DRAFTING NOTE LIFE, HEALTH and PROPERTY ANNUAL STATEMENT BLANK AND INSTRUCTIONS Edit the blank and instructions for the Life, Health and Annuity Guaranty Association Assessable Premium Exhibits Part 1 and Part 2. The Exhibits are to continue to be filed as stand-alone supplemental exhibits in each of the Life, Health and Property blanks due April 1. |
11/23/2020 |
| ACA Guidance |
Memo from Statutory Accounting Principles (E) Working Group providing guidance for the ACA disclosure in Note 22. Because the federal ACA insurer fee, which is also known as the health insurance tax, has been repealed effective Jan. 1, 2021, proposal 2020-28BWG proposes to officially remove the disclosure from the annual statement when adopted. |
11/23/2020 |
| Health Care Receivables Guidance |
Provides guidance on reporting collection and offset amounts on Exhibit 3A, which the Health Risk-Based Capital (E) Working Group is requesting to be posted to the BWG Web page. NOTE: This document has not yet been approved by Health Risk-Based Capital (E) Working Group and is pending final approval on 10/29. |
11/23/2020 |
|
|
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 |
Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated 10/13/2020
Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to Julie Gann, Robin Marcotte, Jim Pinegar, Fatima Sediqzad and Jake Stultz.
For the status of all SAPWG agenda items, please refer to the Maintenance Agenda.
| EXPOSURES with COMMENT DEADLINE of DECEMBER 4, 2020 | |||
|---|---|---|---|
| 2019-21 |
SSAP No. 43R |
Exposed the Iowa Insurance Division proposal to establish principles on what is intended to be captured on Schedule D-1: Long-Term Bonds. For further clarity, this exposure is not proposing to expand the scope of SSAP No. 26R—Bonds, but rather identify principles of investments that should be captured on Schedule D-1, regardless if the investment is in scope of SSAP No. 26R or SSAP No. 43R. Comments are requested by Dec. 4, 2020. The Iowa proposal is the exposed item. (For reference purposes, the previously exposed issue paper and July 31, 2020 comment letter are also provided as attachments.)
|
|
| EXPOSURES with COMMENT DEADLINE of OCTOBER 30, 2020 | |||
| 2019-24 | SSAP No. 71 | Levelized and Persistency Commission | Revisions clarify existing levelized commissions guidance, which requires full recognition of funding agreement liabilities incurred for commission expenses obligated when an insurance policy is written. (This guidance clarifies that writing the insurance policy is the obligating event for initial sales commission.) Key changes from the prior exposure: 1) Improved description of the funding agreements; 2) Deletes previously proposed revisions regarding of other types of commission; 3) Removes the prior exposed reference to a correction of an error; 4) Applies to contracts in effect as of January 1, 2021. |
| EXPOSURES with COMMENT DEADLINE of SEPTEMBER 18, 2020 | |||
| 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 |
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. |
| 2020-30 |
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 DEFERRED for SUBSEQUENT INTERIM or NATIONAL MEETING |
|||
|
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. |
|
|
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. |
|
|
SSAP No. 68 SSAP No. 97 |
Attribution of Goodwill | This agenda item addresses attribution and tracking of goodwill when multiple SCAs are purchased. | |
|
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. |
|
There are no exposure drafts at this time.
Health Care Receivable Guidance
Please send comments to Crystal Brown by the close of business, October 19, 2020.
Proposal 2020-07-H - Bonds and Miscellaneous Assets Page Numbers
Please send comments to Crystal Brown by the close of business, October 12, 2020.
There are no exposure drafts at this time.
Comments should be sent electronically to Dave Fleming by COB Wednesday, Oct. 7, 2020.
Exposure on Suggested Edits to the RBC Forms & Instructions for C-2b Longevity Risk
Comments should be sent electronically to Dave Fleming by COB Monday, August 10, 2020.
Exposure Drafts Still Open For Consideration with Comment Received:
- American Academy of Actuaries (AAA) proposed instructions for the C-3 Phase I proposal
- Modified C-3 Phase 3 Scope Proposal
- Comment Letters Received:
- AAA Draft C-3 Instructions and Appendices
- Comment Letters Received:
- AAA September 2009 Report on RBC C3 Requirements for Life Products
Please send any comments on the exposure drafts to Dave Fleming.
There are no exposure drafts at this time.
The following proposal is exposed for a 30-day comment period. Please submit comments to Eva Yeung by COB November 18, 2020.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The Financial Analysis Solvency Tools (E) Working Group has posted the following document for a 30 day exposure period ending October 23, 2020:
Please submit all comments to Rodney Good (rgood@naic.org) by end of business on October 23, 2020
There are no exposure drafts at this time.
The following revisions are exposed for a 30 day comment period ending Nov 4, 2020.
Comments can be sent to Bailey Henning (bhenning@naic.org) and are due by close of business Nov 4, 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.
The following documents have been exposed for public comment by the Receivership Large Deductible Workers’ Compensation (E) Working Group:
- Attachment A - Draft Guideline for Administration of Large Deductible Policies
- Attachment B - Receiver Handbook Revisions
These documents being exposed for a 30 days comment period ending on 10/30/2020. Please submit to Sherry Flippo (sflippo@naic.org) by the close of business on Friday, Oct. 30.
There is no Exposure Draft 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.
During the 2020 Summer National Meeting, the Financial Regulation Standards and Accreditation (F) Committee exposed the following items. Comment letters should be emailed to me at bmeyer@naic.org prior to Friday September 11, 2020.
There are no exposure drafts at this time.
There are no exposure drafts at this time.