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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.

The Task Force has released the operational sections of the Long-Term Care Insurance (LTCI) Multistate Rate Review Framework for a 45-day public comment period. This first draft represents only the operational sections of the Framework. Additional sections will be released for comment when available.

Comments should be sent electronically to NAIC staff Jane Koenigsman by close of business Monday, May 24, 2021.

There are no exposure drafts at this time.

Draft Revised UTPA Amended Language Addressing Rebating 10/30/20
Comments regarding the revised proposed amendments should be submitted to Denise Matthews by Wed., Nov. 18, 2020.


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.

The Task Force has released the operational sections of the Long-Term Care Insurance (LTCI) Multistate Rate Review Framework for a 45-day public comment period. This first draft represents only the operational sections of the Framework. Additional sections will be released for comment when available.

Comments should be sent electronically to NAIC staff Jane Koenigsman by close of business Monday, May 24, 2021.

There are no exposure drafts at this time.

There are no exposure drafts at this time.

Draft Model #275 Revisions FAQ Implementation Document, Draft Dated Sept. 4 Draft FAQ

The following document is being exposed for a public comment period ending May 25th, 2021.

Please send comments to Reggie Mazyck by close of business on May 25th, 2021.

The following document is being exposed for a public comment period ending May 3rd, 2021.

Please send comments to Reggie Mazyck by close of business on May 3rd, 2021.

The following documents are being exposed for a public comment period ending April 28th, 2021.

Please send comments to Reggie Mazyck by close of business on April 28th, 2021.

The following documents are being exposed for a public comment period ending March 26th, 2021.

Please send comments to Reggie Mazyck by close of business on March 26th, 2021.

The following documents are being exposed for a public comment period ending March 22nd, 2021.

Please send comments to Reggie Mazyck by close of business on March 22nd, 2021.

The following document is being exposed for a public comment period ending March 26th, 2021. 

  • APF 2020-12  (Specifically requesting comments on the 12 identified CDHS requirements moved to VM-01)

Please send comments to Reggie Mazyck by close of business on March 26th, 2021.

The following document is being exposed for a public comment period ending Feb 26th, 2021. 

  Please send comments to Reggie Mazyck by close of business on Feb 26th, 2021. 

The following documents are being exposed for a public comment period ending March 22nd, 2021.

Please send comments to Reggie Mazyck by close of business on March 22nd, 2021.

The following documents are being exposed for a public comment period ending March 22nd, 2021.

Please send comments to Reggie Mazyck by close of business on March 22nd, 2021.

The following document is being exposed for a 60-day public comment period. 

Please send comments to Reggie Mazyck by close of business on Feb 4, 2021.

The following document is being exposed for a 30-day public comment period.

Please send comments to Reggie Mazyck by close of business on Dec. 11, 2020.

Past Exposures: 

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.

The VM-22 (A) Subgroup is exposing the Academy Annuity Reserves Work Group (ARWG) presentation on the Preliminary Framework Elements for Fixed Annuity PBR for a 45-day public comment period ending Dec. 14.

Please submit comments to Reggie Mazyck (RMazyck@naic.org) by close of business Dec.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.

PBM Model Draft As Adopted by the Regulatory Framework (B) Task Force (March 18, 2021)

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.

PBM Model Draft PBM Model Act As Adopted by the Task Force (March 18, 2021)

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

PBM Model Draft As Adopted by the Regulatory Framework (B) Task Force (March 18, 2021)

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.

Title Insurance Consumer Shopping Tool Template
The Task Force will begin revising through drafting sessions beginning March 23, 2021. To assist in this process, the Task Force is seeking revision suggestions to be submitted to Anne Obersteadt by March 12, 2021.

There are no exposure drafts at this time.

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

Comments Due Date on both Title SDRs is: April 23, 2021

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

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

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

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

 

On October 29, 2020 the Antifraud Technology (D) Working Group completed their review and adopted revisions to the NAIC Antifraud Plan Guideline (#1690). The focus was 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.
 

The Antifraud (D) Task Force is soliciting comments on the revisions with a deadline of Thursday, November 12, 2020.  Comments/suggestions can be sent to Greg Welker gwelker@naic.org  
 

The track changes draft, and the track changes accepted draft adopted by the Working Group can be found below.
 

The Antifraud (D) Task Force will potentially adopt the revisions to the Antifraud Plan Guideline (#1690) on its November 16, 2020 - Open Webex Meeting.

 

Antifraud Plan Guideline

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

 

 

 

 

Comments Received by January 5, 2020

 

Comments Received by September 8, 2020 (Draft 3 8.3.20)

 

 

Guideline Drafts

RIRS Coding Change Proposal

RIRS Coding Change Proposal  posted 3/25/2021

Pet Insurance 

The Producer Licensing Uniformity (D) Working Group has been given the task of reviewing Pet Insurance to determine whether the current licensing standards should change. The Working Group will be meeting via Webex/conference call throughout 2021 to discuss and determine a recommendation that will be presented to the Producer Licensing (D) Task Force. 

Materials:

 

Webex/Conference Calls:

 

 


 

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.

Draft 2020 LST Framework

Comments due to Todd Sells by close of business April 1, 2021

 

 

 

 

The Group Capital Calculation (E) Working Group is exposing the following recommendation. Please submit comments to Dan Daveline by COB Tuesday, Feb. 9, 2021.

There are no exposure drafts at this time. 

 

There are no exposure drafts at this time. 

The following document is being exposed for public comment: 

Please send comments to Andy Daleo by end of business March 18, 2021

The National Treatment and Coordination (E) Working Group is exposing the following proposals. Please submit comments to Jane Barr by COB April 19, 2021.

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 April 7, 2021

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

Ref. No. Description Comment Deadline
2021-01BWG Add reference to health care receivables to Line 24 – Health Care and Other Amounts Receivable on the Asset Page, change description of Line 0699999 to read Other Health Care Receivables on Exhibit 3 and modify column headers for Exhibit 3A. 4/27/2021
2021-02BWG Add questions to the General Interrogatories, Part 1, regarding depository institution holding companies as it pertains to the group capital calculation. Additionally, modify the terminology in the first two questions for consistency with the new questions, which has been modified to consider that many insurers that are part of a depository institution holding company are savings and loan holding companies, which is picked up with the broader terminology compared to the more specific term of bank holding company. 4/27/2021
2021-03BWG Modify the tables for Interrogatory Questions 1.01, 1.01A, 2.5 and 4.2 in the Separate Accounts General Interrogatories by adding category lines to reflect additional granularity in the reporting on those tables (SAPWG Ref #2020-37 and Ref #2020-38). 4/27/2021
2021-04BWG Add interrogatory questions 24.1 and 24.2 to the General Interrogatories, Part 1 “Financial” section asking if the insurer utilizes third parties to pay agent commissions in which the amounts advanced by the third parties are not settled in full within 90 days. Renumber the remaining questions (SAPWG Ref #2019-24). 4/27/2021
2021-05BWG Modify the instructions for Note 17B(4)b1(a) – Sale, Transfer and Servicing of Financial Assets and Extinguishments of Liabilities and add a table to the illustrations to data capture the disclosure (SAPWG Ref #2021-03). 4/27/2021
2021-06BWG Add crosschecks for Columns 2, 3, 4, 6 and 7 of LTC Form 5 to Columns 8, 1, 2, 5 and 3 respectively. 4/27/2021
2021-07BWG Add additional line categories to the instructions for Schedule D, Part 1, Column 26 – Collateral Type to capture collateral type data for all RMBS, CMBS and LBSS securities regardless of reporting category. 4/27/2021

 

 

Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated 3/19/2021

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 APRIL 30, 2021

Note: In addition to the exposures below, the SAPWG sponsored Blanks (E) Working Group agenda item (2021-04BWG), proposing a new General Interrogatory to identify certain circumstances where an insurer utilizes a third-party to pay commission expense. The exposure can be found HERE.
2020-36 SSAP No. 108 Derivatives Hedging Fixed Indexed Products

Re-exposed this agenda to solicit comments on establishing accounting and reporting guidance for derivatives hedging the growth in interest for fixed indexed annuity products. After interested parties provide possible options for consideration, a notification of the exposure will be sent to the Life Actuarial (A) Task Force. 

2020-37

SSAP No. 56

Separate Account – Product Identifiers

Exposed this agenda item with details of a proposed blanks change, which is concurrently exposed by with the Blanks (E) Working Group (2021-03BWG). With the proposed blanks changes, there are no anticipated revisions to statutory accounting, however the blanks proposal modifies the current General Interrogatory instructions to require 1) separate product identifiers for PRT and RILA transactions, and 2) additional disaggregation in product reporting. Consideration of this item will occur during an interim call so that the blanks changes may be reflected in the statutory financials for year-end 2021.

2020-38 SSAP No. 56 Pension Risk Transfer Disclosure Exposed this agenda item with details of a proposed blanks change, which is concurrently exposed by with the Blanks (E) Working Group (2021-03BWG). With the proposed blanks changes, there are no anticipated revisions to statutory accounting, however the blanks proposal modifies the current General Interrogatory instructions to require 1) separate product identifiers for PRT and RILA transactions, and 2) additional disaggregation in product reporting. Consideration of this item will occur during an interim call so that the blanks changes may be reflected in the statutory financials for year-end 2021.
2021-01

SSAP No. 86

INT 20-01

ASU 2021-01, Reference Rate Reform Exposed temporary (optional) expedient and exception interpretative guidance, with an expiration date of December 31, 2022. These optional expedients would expand the current exception guidance provided by INT 20-01: ASU 2020-04 – Reference Rate Reform to include derivative instruments affected by changes to interest/reference rates because of reference rate reform (regardless of whether they reference LIBOR or another rate that is expected to be is discontinued), in which are used for discounting, margining or contract price alignment.
2021-02 SSAP No. 26R ASU 2020-08 – Premium Amortization on Callable Debt Securities Revisions reject ASU 2020-08 in SSAP No. 26.
2021-03 SSAP No. 103R SSAP No. 103R – Disclosures Revisions propose new disclosure elements and a data-capture template for certain existing disclosures in SSAP No. 103R. A blanks proposal has been concurrently exposed.
2021-04 SSAP No. 97 SSAP No. 97 – Valuation of Foreign Insurance SCAs Exposed with the intent to move this agenda item to the disposal listing without statutory edits. Industry is requested to submit comments on any prevalent examples of a negative equity valuation in a foreign insurance subsidiary, controlled or affiliated (SCA) investment with detailed information for assessment.
2021-05 INT 21-01T Accounting for Cryptocurrencies Exposed interpretative guidance in INT 21-01T: Statutory Accounting Treatment for Cryptocurrencies to clarify that cryptocurrencies do not meet the definition of cash in SSAP No. 2R—Cash, Cash Equivalents, Drafts, and Short-Term Investments and are nonadmitted assets for statutory accounting. With the exposure, information from industry regarding current and anticipated acquisition of cryptocurrencies is requested.
2021-06EP

SSAP Nos. 53 and 97

SSAP Glossary

AP&P Editorial Process Exposed editorial revisions to SSAP No. 53, SSAP No. 97 and the SSAP Glossary.
2021-07 Appendix D ASU 2020-11, Financial Services – Insurance: Effective Date and Early Application Revisions reject ASU 2020-11 as not applicable for statutory accounting.
2021-08 SSAP No. 47 ASU 2021-02, Franchisors – Revenue from Contracts with Customers Revisions reject ASU 2021-02 in SSAP No. 47.
2021-09 SSAP No. 107 State ACA Reinsurance Programs Revisions include State ACA reinsurance programs in which are using Section 1332 waivers in scope of SSAP No. 107. Provided guidance directs to follow the hybrid accounting approach for the state ACA programs as they operate in a similar manner as the prior federal reinsurance program.

EXPOSURES DEFERRED for SUBSEQUENT INTERIM or NATIONAL MEETINGS

2018-07

SSAP No. 41R

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

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

2019-12

Comments

SSAP No. 68

ASU 2014-17, Business Combinations, Pushdown Accounting

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

2019-14

Comments

SSAP No. 68

SSAP No. 97

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

2019-49

Comments

SSAP No. 62R

Retroactive Reinsurance Exception

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

The Task Force is exposing the following proposal for a 30-day comment period. Please submit comments to Crystal Brown by COB April 22, 2021.

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

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


Exposure of American Academy of Actuaries’ Proposed Bond Factors

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


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

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


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


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


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:

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

The Working Group is exposing the following proposal for a 30-day comment period. Please submit comments to Eva Yeung by COB April 14, 2021.

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 has been exposed for public comment: 

  • MO440 - Section 5A(1)(g)

Please send comments electronically to Jane Koenigsman by Friday, April 9, 2021.  

 

The Receivership Financial Analysis (E) Working Group (R-FAWG) of the Receivership and Insolvency (E) Task Force (RITF) requests feedback on any recommended best practices for overcoming challenges that states, receivers, and guaranty associations have faced in the administration of a receivership due to the current pandemic and related travel/business restrictions, work-from-home, economic impact, etc.

  • Please consider including a description of the following, specific to the administration of receiverships during the pandemic:
    • Challenges or issues you’ve faced
    • Best practice(s) for overcoming and dealing with the challenge/issue
    • Circumstances to avoid or watch for
    • Critical planning steps and processes to consider
    • Identify any increased cyber security protocols or data security protocols to consider
  • Please do not include names of insurance companies, persons or entities. If any part of your feedback/best practices should be for regulators only, please label it as such.

 

The feedback received is intended to be compiled and made available to serve as a helpful aid as we navigate the receivership process in the current environment.

 

Please submit feedback to jkoenigsman@naic.org

The following document has been exposed for public comment: 

  • MO440 - Section 5A(1)(g)

Please send comments electronically to Jane Koenigsman by Friday, April 9, 2021.  

The following document is being exposed for a 30-day public comment period:

Draft Revisions to the Process for Evaluating Qualified and Reciprocal Jurisdictions

Comments should be sent electronically to Jake Stultz and Dan Schelp by COB Friday, April 23, 2021.

 

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.

RRG Analysis Guideline Referral

Salary Ranges Referral(Combined)

There are no exposure drafts at this time.

There are no exposure drafts at this time.