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.
Proposed Innovation, Cybersecurity and Technology (H) Committee
Final H Committee 2022 Proposed Draft Charges - Clean Version 12/1/21
Final H Committee 2022 Proposed Draft Charges - Redline Version 12/1/21
Comments to the Draft Charges 11/18/21 Revised
Draft Charges 11/2/21
____________________________________________________________________________________________________________
The Task Force has released the proposed revisions to the “Checklist for Premium Increase Communications” for a 30-day public comment period upon completion of the drafting group’s review. Comments are due to Jane Koenigsman, by Friday, February 3, 2023.
Enhanced Cash Surrender Value Offer Survey
Annuity Suitability (A) Working Group Adopted FAQ Guidance Document Adopted FAQ Guidance Document
The following document is being exposed for a public comment period ending Sept. 16, 2022.
Please send comments to Jim Stinson by close of business on Sept. 16, 2022.
This document can also be found on the ILVA Subgroup Webpage.
The following document is being exposed for a public comment period ending August 23rd, 2022.
Please send comments to Reggie Mazyck by close of business on August 23rd, 2022.
Comments on Draft AG ILVA
- ACLI and CAI Comment Letter
- ACLI and CAI Redline
- IRI Comment Letter
- Academy Comment Letter
- Academy Redline
EXTENDED: The following document is being exposed for a 14-Day 28-Day public comment period ending June 20th July 5th, 2022.
Please send comments to Reggie Mazyck by close of business on June 20th July 5th, 2022.
The following document is being exposed for a 30-Day public comment period ending May 2nd, 2022.
- Proposed Actuarial Guideline 2
Comment Letters: - ACLI Comments Combined
- CompEdge Financial Comments
- Academy ILVA Comments
- IRI Comments
Please send comments to Reggie Mazyck by close of business on May 2nd, 2022, 2022.
The following document is being exposed for a 60-Day public comment period ending January 27th, 2022.
Please send comments to Reggie Mazyck by close of business on January 27th, 2022.
Comments Received on the ILVA SG Exposure
Comments are requested by March 24
AUWG Referral to Market Conduct Examination Guidelines (D) Working Group
Comments received
1. - cej_comments_naic_auwg_230324_mceg_wg_referral_0.pdf
Comments are requested by April 14
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
The following documents are being exposed for a 45-day public comment period ending Monday, July 17th, 2023:
Please send comments to Scott O'Neal by close of business on Monday, July 17th, 2023.
The following document is being exposed for a 16-day public comment period ending May 26th, 2023:
Please send comments to Scott O'Neal by close of business on May 26th, 2023.
A cover letter with additional exposure questions has been added to APF 2023-06 and the comment period has been extended to end June 12th, 2023:
Please send comments to Scott O'Neal by close of business on June 12th, 2023.
The following document is being exposed for a 21-day public comment period ending Mayor i 24th, 2023:
Please send comments to Scott O'Neal by close of business on May 24th, 2023.
The following document is being re-exposed for a 10-day public comment period ending May 8th, 2023:
Please send comments to Scott O'Neal by close of business on May 8th, 2023.
There are no exposure drafts at this time.
There are no Exposure Drafts at this time.
The following document is being exposed for a 60-day public comment period ending February 2nd, 2023.
Please send comments to Scott O'Neal by close of business on February 2nd, 2023.
The following documents are being exposed for a 90-Day public comment period ending January 2nd, 2023 (Commenters are encouraged to provide mark-ups directly in the clean version of the word document):
Please send comments to Scott O'Neal by close of business on January 2nd, 2023.
EXTENDED: The following document is being exposed for a 60-Day public comment period ending August 26th, 2022 August 12, 2022.
(This exposure propose specific treatment in the VM-22 Framework for addressing for Longevity Reinsurance. The exposure is intended to improve the Framework, and should not be viewed as a replacement.)
Please submit comments to Reggie Mazyck by close of business Aug 26th, Aug 12, 2022.
Comments on the VM-22 Framework Exposure:
- Consolidated Proposed Edits
- Bill Wilton
- Erie Family Life
- NY Department of Financial Services
- ACLI comments
- Texas Department of Insurance comments
- Equitable
- California Department of Insurance
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.
1. Please provide comments on the attached ideas for a single, improved MSA actuarial approach.
Revised Ideas- Improved MSA Actuarial Approach
Comments should be submitted to Eric King by Friday, June 2.
___________________________________________________________________________________________________________________
1. Please provide comments by April 24 on suggested improvements, including additions or streamlining of the Health Actuarial Task Force-adopted Consolidated, Most Commonly Asked Questions – States’ LTC Rate Increase Reviews checklist and MSA Supplemental information checklist.
These checklists are contained in the Information Checklist section of the NAIC Long-Term Care Insurance Multistate Rate Review Framework document, located at https://content.naic.org/sites/default/files/inline-files/MSA%20Framework_121221_TF%20Adopted.pdf
2. Please provide comments by April 24 related to the Minnesota and Texas actuarial approaches as described in the NAIC Long-Term Care Insurance Multistate Rate Review Framework document, located at https://content.naic.org/sites/default/files/inline-files/MSA%20Framework_121221_TF%20Adopted.pdf
Please identify issues, including types of cases where improvements to the approaches may lead to more consistent results in line with goals, for example balancing fairness to consumers with helping to prevent further financial distress to insurers.
Comments should be submitted to Eric King by Monday, April 24
Comments are requested by close of business April 21, 2022
ERISA Handbook case summary - Rutledge
Comments received
HMO Model Draft Adopted by the Subgroup, July 13, 2020
There are no exposure drafts at this time.
The Understanding the Market for Cannabis Insurance 2.0 white paper was exposed for comment by the NAIC Cannabis Insurance (C) Working group on April 11, 2023 for 45 days. Comments are due Friday, May 26 to NAIC staff Anne Obersteadt at aobersteadt@naic.org.Cannabis Insurance White Paper Exposure Draft.pdf
There are no exposure drafts at this time.
The following document is being exposed for a 30-Day public comment period ending June 26, 2023.
Please send comments to Kris DeFrain by close of business on June 26, 2023.
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.
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
State Comments:
- HI DOI Comments
- ME DOI Comments
- MO DOI Comments
- OH DOI Comments - PLMA (Model 218)
- OH DOI Comment Letter 11.15.22
- OH DOI Comment Letter 11.18.22
Industry Comments:
- ACLI Comments
- AHIP Comment
- AHIP Updated Comments (11.2.22)
- Health Benefits Institute Comments
- NAIC Consumer Representatives Comments
- NAHU Comments
New Draft Travel Insurance-Related Standardized Data Requests
- Travel In Force SDR, August 17, 2022 Draft
- Travel Claims SDR, August 17, 2022 Draft
The comments due date on both of the Travel Insurance Standardized Data Requests is extended to December 30, 2022.
Draft Chapter 23-Conduct 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.)
The comments due date on the August 22, 2022 Chapter 23 exposure draft is extended to December 30, 2022.
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))
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.
Revised Draft Chapter 24B-Conducting the MHPAEA-Related Examination July 11, 2022 Draft (This draft will be 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).
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)
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)
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)
Please note: The comments due date of May 20, 2022 was extended to May 27, 2022 on the Oct. 27, 2021 draft Chapter 20.
- 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)
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)
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)
The draft Chapter 25 was adopted by the Working Group on its November 4, 2021 conference call, the chapter underwent an additional revision as part of that adoption.
Updated Draft Title Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
New Draft Title Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
- 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
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.
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.
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.
MCAS - Other Health Scorecard Ratios
- Other Health Scorecard Ratios v1.1 5/8/2023
Charge to Assess Currently Available Market Analysis Data
- Market Analysis Data Sources 5/8/2023
MCAS Proposals
Pet MCAS Exposure Draft
Health MCAS Due Date
MCAS Other Health
- Draft MCAS Other Health Data Call and Definitions v. 2022.0.3.pdf
- Draft MCAS Other Health Data Call and Definitions v. 2022.0.1.pdf
MCAS Accelerated Underwriting: Proposal (3/18/2021)
- Draft MCAS Data Call Life and Annuity 2023-Accelerated Underwriting (5/20/2022)
- Draft MCAS Data Call Life and Annuity 2022-Accelerated Underwriting (5/25/2021)
Market Regulation Certification Program v2.43 clean 04/21/2023
Market Regulation Certification Program v2.44 clean 05/09/2023
Market Regulation Certification Program v2.43 redline 04/19/2023
Market Regulation Certification Program v2.44 redline 05/09/2023
Certification Program Scoring Matrix 04/19/2023
Market Regulation Certification Implementation Plan Adopted 12/9/2022
NAIC Antifraud Guideline Plan - Clean - Adopted by the AFTF 11.16.20
NAIC Antifraud Guideline Plan - Track Changes - Adopted by the AFTF 11.16.20
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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. The intent of the repository is to provide a centralized location so that insurers may utilize a uniform template for submission of antifraud plans, which would satisfy multiple states’ requirements.
The Working Group adopted the draft on May 19, 2022 and it was presented to the Antifraud (D) Task Force for review. The Task Force will hold a meeting on June 30, 2022 to review any comments received and potentially adopt the draft.
Deadline for comments will be accepted on the Antifraud Plan Repository Workflow until Tuesday, June 28, 2022.
Antifraud Plan Repository Workflow
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
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.
There are no exposure drafts at this time.
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:
- Producer Licensing Standard for Pet Insurance (Draft For Discussion Document)
- PLTF Fall National Meeting Minutes
- Regulators Guide to Pet Insurance - White Paper
Comments Received:
Webex/Conference Calls:
- Wednesday, November 3, 2021 at 10:30am Alaska/11:30am Pacific/12:30pm Mountain/1:30pm Central/2:30pm Eastern.
- Webex link:
https://naic.webex.com/naic/j.php?MTID=mcae5f9e2e19ab7ff11741e610441c470
- Agenda
- Minutes 10.6.21
- Webex link:
CE Instructor Approval Guidelines
As part of the Working Group's first charge to: Update, as needed, the reciprocity guidelines, the uniform application forms for continuing education (CE) providers, and the process for state review and approval of instructors and courses. The Working Group exposed the CE Instructor Approval Guidelines - Draft created by the Working Group's Subject matter Experts (SME).
The draft and comments received can be found below. The Working Group is scheduled to meet on Tuesday, November 8, 2022 (2PM CST) to discuss the comments and finalize the review of the draft.
Guideline Draft:
- NAIC CE Instructor Approval Guidelines Draft 8.25.22 (PDF)
- NAIC CE Instructor Approval Guidelines Draft 8.25.22 (WORD)
Comments Received:
- Rhode Island Comments (WORD)
- Rhode Island Comments (PDF)
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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.
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Testing and Examination Pass Rates
There are no exposure drafts at this time.
The following document is being exposed for a public comment period ending on February 6th, 2023
Please submit comments to Sherry Flippo by EOD on February 6th. 2023
The Working Group has exposed the following for public comment. Please submit comments to Dave Fleming by COB May 12, 2023.
The referral below requires a response from the Capital Adequacy (E) Task Force and the Risk-based Capital Investment Risk and Evaluation (E) Working Group by May 15, 2023. Please submit your comments to Eva Yeung or Dave Fleming by COB March 31, 2023.
The Working Group has exposed the following for public comment. Comment is specifically requested from RBC vendors with respect to the proposed sensitivity test as it was submitted past the RBC deadline for exposure. Please submit comments to Dave Fleming by COB April 12, 2023.
The referral below is for informational purposes only and no action is required by the Capital Adequacy (E) Task Force and the Risk-based Capital Investment Risk and Evaluation (E) Working Group. Please contact Eva Yeung or Dave Fleming if you have any comments regarding this referral.
There are no exposure drafts at this time.
The following document is being exposed for a public comment period ending April 28, 2023:
NAIC - Reinsurance Comparison Worksheet Dec 5 2022
Please send comments to Tim Nauheimer and Aida Guzman by close of business on April 28, 2023.
There are no exposure drafts at this time.
The following document is being exposed for a public comment period ending April 28, 2023:
NAIC - Reinsurance Comparison Worksheet Dec 5 2022
Please send comments to Tim Nauheimer and Aida Guzman by close of business on April 28, 2023.
The following documents are being exposed for a public comment period ending July 8th, 2022.
- NAIC Financial Condition Examiners Handbook – Proposed ComFrame Revisions
- NAIC ORSA Guidance Manual – Proposed ComFrame Revisions
- NAIC Financial Analysis Handbook – Proposed ComFrame Revisions (re-exposure)
Please send comments to Bruce Jenson by close of business on July 8th, 2022.
There are no exposure drafts at this time.
The following document is being exposed for a public comment period ending May, 26th, 2023.
Please send comments to Andy Daleo by close of business on May 26th, 2023.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
Comments on exposed items should be addressed to Superintendent Elizabeth Kelleher Dwyer, Chair of the Restructuring Mechanisms (E) Working Group, and directed to NAIC staff, Robin Marcotte and Dan Daveline.
The following document has been exposed with a public comment period ending Wednesday, April 26, 2023.
The following exposure document and comments are being shared for review. We are no longer accepting comments for this document as the comment period has ended.
Affiliated Services Exposure Document
Comments Received:
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 May 31, 2023
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.
| Ref. No. | Description | Comment Deadline |
| 2023-05BWG Modified | Changes to the Cybersecurity supplement to remove the reference to Identity Theft Insurance from the General Instructions; remove the interrogatory questions from Part 1 that pertain to Identity Theft Insurance; and remove the column for Identity Theft Insurance from Parts 2 and 3. Remove claims-made and occurrence breakdown, as well as first-party and third-party breakdowns from data collection and remove the question in the interrogatories regarding tail policies. | 06/30/2023 |
| 2023-06BWG | Split the Schedule D, Part 1, into two sections: one for Issuer Credit Obligations and the other for Asset-Backed Securities (ABS). Update the other parts of the annual statement that reference the bond lines of business. | 06/30/2023 |
| 2023-07BWG | Update the code column and delete the Legal Entity Identifier (LEI) column for the following investment schedules: Schedules A, B, BA, D Part 2, D Part 6, and E Part 1. | 06/30/2023 |
| 2023-09BWG | Add a new financial statement Note 37 – Life Insurance Net Amount at Risk by Product Characteristics to the life and accident and health/fraternal blank for the updates to the life C-2 mortality risk charges for Life Risk-Based Capital (RBC). | 06/30/2023 |
Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated May 16, 2023
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.
| EXPOSURES with PUBLIC COMMENT PERIOD ending JUNE 9, 2023 (*unless noted otherwise) | |||
|---|---|---|---|
| 2022-19 | INT 23-01T | Net Negative (Disallowed) IMR | Exposure proposes a limited-time, optional, INT to allow admittance of net negative (disallowed) IMR in the general account up to 5% of adjusted capital and surplus. The INT has restrictions on what is permitted to be captured in the net negative IMR balance eligible for admittance as well as reporting and disclosure requirements. |
| SSAP No. 21R SSAP No. 26R SSAP No. 43R |
Principles-Based Bond Definition |
Exposure proposes statutory accounting changes under the principles-based bond project. *Comments on the SSAP revisions are due June 9. The exposure also proposes changes to Schedule BA to encompass debt securities that do not qualify as bonds and consolidate existing reporting lines. *Comments on this reporting concept change are due June 30. |
|
| SSAP No. 5R | Definition of Asset and Liability | Exposure adds modifications deferring to topic specific liabilities guidance to SSAP No. 5R. | |
| 2022-11 | SSAP No. 20 SSAP No. 21R |
Collateral for Loans | Exposure proposes changes to require audits of SSAP No. 48 and SSAP No. 97 investments pledged as collateral and to ensure that the comparison for admittance is between the net audited equity value and the collateral loan. |
| INT 03-02 | Nullification of INT 03-02 | Re-exposure to nullify INT 03-02, as of Dec. 31, 2023, as it is inconsistent with SSAP No. 25 guidance regarding economic and non-economic transactions between related parties. | |
| 2023-01 | Annual Statement | Annual Statement Instructions | Exposure requests regulator and industry input on situations in which guidance in the annual statement instructions should be captured within a SSAP. |
| 2023-02 | SSAP No. 43R | CLO Financing Model | Exposure proposes revisions to SSAP No. 43R to add CLOs to the financial modeling guidance and to clarify that CLOs are not captured as legacy securities. |
| INT 20-01 | ASU 2022-06, Reference Rate Reform |
Exposure to revise the expiration date of the guidance detailed in INT 20-01 to Dec. 31, 2024. | |
| 2023-06 | SSAP No. 24 | Government Assistance | Exposed revisions to clarify rejection of ASU 2021-10, Government Assistance, and the inclusion of general disclosure for government assistance received. |
| 2023-07 | SSAP No. 104R | Share-Based Payments to Customers | Exposure proposes to adopt ASU 2019-08, Codification Improvements to Topic 718 and Topic 606 with modification. |
| 2023-08 | Appendix D | ASU 2019-07, SEC Updates |
Exposure proposes rejection of ASU 2019-07, Codification Updates to SEC Sections updates as not applicable to statutory accounting. |
| 2023-09 | Appendix D | ASU 2020-09, SEC Updates |
Exposure proposes rejection of ASU 2020-09, Amendments to SEC Paragraphs as not applicable to statutory accounting. |
| 2023-10 | SSAP No. 50 SSAP No. 51R SSAP No. 52 SSAP No. 56 SSAP No. 71 SSAP No. 86 |
ASU 2022-05, Long-Durations Contracts |
Exposed revisions propose to reject ASU 2022-05, Transition for Sold Contracts for statutory accounting as 2022-05 amends a previously rejected ASU. |
| EXPOSURES with PUBLIC COMMENT PERIOD ending JUNE 30, 2023 | |||
|
SSAP No 93 SSAP No. 94R |
New Market Tax Credits | Exposure recommends amendments of both SSAPs to create new SSAP concepts for the accounting of state and federal tax credits within SSAP No. 94R and qualifying tax investment structures of any type or program within SSAP No. 93. | |
| 2023-12 | SSAP No. 48 | Residuals | Exposure recommends clarifications to SSAP No. 48 noting that investment structures captured in scope of the SSAP that represent residual interests or that predominantly hold residual interests, shall be reported on the dedicated residual reporting line on Schedule BA. |
| 2023-13 | SSAP No. 34 | PIK Interest Disclosure Clarification | Exposure proposes the addition of a practical expedient to the paid-in-kind (PIK) interest aggregate disclosure noted within SSAP No. 34. |
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EXPOSURES DEFERRED for SUBSEQUENT INTERIM or NATIONAL MEETINGS |
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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 | The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent call or meeting. | |
|
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 has re-exposed the following proposal for a 14-day public comment period ending June 14, 2023. Please submit comments to Eva Yeung.
The Task Force has exposed the following proposal for a 30-day public comment period ending May 27, 2023. Please submit comments to Eva Yeung (Task Force support staff) and Crystal Brown (Health Risk-Based Capital (E) Working Group support staff).
The following referral is for informational purposes only and no action is required by the Capital Adequacy (E) Task Force and the Risk-Based Capital Investment Risk and Evaluation (E) Working Group. Please contact Eva Yeung or Dave Fleming if you have any comments regarding this referral.
The following referral 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 comments to Eva Yeung or Dave Fleming by COB March 31, 2023.
The Health Test Proposal is being exposed for a 45-day comment period. Please submit comments to Crystal Brown by COB June 30, 2023.
Exposure of the 2023-08-L Comfort Trusts Proposal
Comments should be sent electronically to Dave Fleming by COB Friday, June 2, 2023
Exposure of the Proposed Charges of the Economic Scenarios (E/A) Subgroup
Comments should be sent electronically to Scott O’Neal by COB Thursday, March 15, 2023
Exposure of the proposed revisions to CM6 and CM7 mortgages.
Comments should be sent electronically to Dave Fleming by COB Thursday, March 16, 2023
Exposure of the American Academy of Actuaries’ (Academy) C2 Mortality Risk Work Group proposed changes.
Comments should be sent electronically to Dave Fleming by COB Wednesday, March 1, 2023
Exposure to remove dual trend test presentation.
Comments should be sent electronically to Dave Fleming by COB Tuesday, February 14, 2023
Exposure of the American Academy of Actuaries' (Academy) C2 Work Group Proposed Instruction Supplement for Applying the Newly Adopted Life Insurance C-2 Mortality Factors
Comments should be sent electronically to Dave Fleming by COB Friday, November 11, 2022
Exposure of the Affiliated Investments Instructions and Structure
Comments should be sent electronically to Dave Fleming by COB Wednesday, July 20, 2022.
Re-Exposure of the American Academy of Actuaries’ (Academy) C2 Mortality Risk Work Group Proposed Instructions
- LR025 Instructions – Option 2 – Revised June 2022
- LR025 Instructions – Option 2 – Revised June 2022 (Alternative)
- Academy C2 Mortality Risk Work Group Report to LRBC April 2022
Comments should be sent electronically to Dave Fleming by COB Wednesday, June 15, 2022.
Exposure of the following documents.
- C-2 mortality risk LR025 instructions for the adopted 2022 yearend structural changes
- Residual tranches and interests LR008 instructional change
Comments should be sent electronically to Dave Fleming by COB Wednesday, May 25, 2022.
Exposure of the Proposed Asset Valuation Reserve Factor Changes
Comments should be sent electronically to Dave Fleming by COB Friday, March 25, 2022.
Exposure of the C-2 Mortality Proposal
Comments should be sent electronically to Dave Fleming by COB Monday, March 7, 2022.
Exposure of the American Academy of Actuaries’ C-2 Mortality Work Group Recommendation on C-2 Mortality Factor Updates
- Academy C-2 Mortality Risk Work Group Report to LRBC - November 2021
- NAIC Life RBC C-2 Recommendation - November 2021
Comments should be sent electronically to Dave Fleming by COB Monday, January 10, 2022.
Exposure of American Academy of Actuaries' and American Council of Life Insurers’ Proposed Bond Factors and Instructions
- 2021-10-L RBC Proposal (Academy)
- 2021-11-L Life Bond Factors (ACLI)
- Moody's Analytics' Report on Proposed Bond Factor Revisions
Additional exposure to include explicit tax factors that are a part of the development of both sets of proposed base bond factors above.
Comments should be sent electronically to Dave Fleming by COB Thursday, May 27, 2021.
Exposure of American Council of Life Insurers’ Proposed Factors and Instructions
Additional exposure to include asset concentration factor instructions that were omitted from the original document.
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.
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.
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 documents at this time.
There are no exposure drafts at this time.
The following document is being exposed for a public comment period ending November 10th, 2022
Please send comments to Jane Koenigsman by close of business on November 10th, 2022.
There are no Exposure Drafts at this time.
The following document is being exposed for a 30-day public comment period ending June 23, 2023:
Please send comments to Jane Koenigsman by close of business on June 23, 2023.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The following documents are being exposed for a 45-day public comment period:
P&P Manual Amendment to Update the Definition of an NAIC Designation
Comments should be sent electronically to Charles Therriault and Denise Genao-Rosado by Thursday, June 29, 2023.
The following document is being exposed for a 60-day public comment period:
Comments should be sent electronically to Charles Therriault and Denise Genao-Rosado by Friday, July 14, 2023.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
Group Capital Calculation (GCC) and Liquidity Stress Test (LST) (2020 Revisions to Holding Company Models #440 and #450)
The 1-year exposure beginning January 1, 2022: Comment letters should be sent to Becky Meyer (bmeyer@naic.org) via email by December 31, 2022.
On Aug. 14, 2021, the Committee voted to recommend exposure of the GCC and LST referral with the following revision:
- GCC: The Commissioner may grant an exemption to qualifying groups meeting the standards set forth in Model #450, Section 21A and 21B, without the requirement to file at least once.
The proposed effective date is January 1, 2026.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The Working Group is exposing the State Laws Surveys/Framework until March 23, 2023.
Please submit comments to Miguel Romero and Casey McGraw by COB March 23, 2023.
In late 2021, as part of its charge to survey the states and work towards meaningful, unified recommendations, the E-Commerce (EX) Working Group prepared its State Laws Surveys, which was intended to not only survey the states on what exceptions to state law or regulation were implemented during the pandemic, but to also survey the industry, consumers and any other interested parties about what impediments may exist which impede their ability to conduct business electronically due to the fact that many of the exceptions to state law or regulation may no longer be in effect. The State Survey contained three (3) parts:
- State Law Survey – UETA Adoption/Additional E-Commerce Statutes;
- State Action Survey – COVID Exceptions; and,
- Business Impact Survey
Parts 1) and 2) were to be answered by the states while Part 3) was intended to be answered by all other interested parties. The framework is the Working Group’s summary and analysis of those survey responses.
There are no exposure drafts at this time.
Model Questions - Comments Due Feb. 13, 2023
Cover Letter for Exposure Draft of New Consumer Privacy Protections Model Law #674
Cover Page for Draft Model Law.pdf
Exposure Draft of the new Consumer Privacy Protections Model Law #674 (incorporates modernized sections from models #670 and #672) is being exposed for a 60-day public comment period from Feb. 1, 2023 to Apr. 3, 2023. All comments received will be discussed during open meetings beginning with the NAIC Spring National Meeting.
Exposure Draft Consumer Privacy Protection Model Law #674 01-31-23.pdf
2023 Workplan for Privacy Protections (H) Working Group (4/30/2023)
2023 Workplan for PPWG Rev 4-30-2023.pdf
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