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 proposed 2024 charges for the Long-Term Care Insurance (EX) Task Force are being exposed for public comment. The proposed charges include reorganization to move the Task Force under the Health Insurance and Managed Care (B) Committee and also to move the Long-Term Care Actuarial (B) Working Group under the LTCI Task Force. The Working Group charges include a charge specific to continuing the work on rate review methodologies. Note that the Health Actuarial (B) Task Force (HATF) will coordinate with the LTCI Task Force as necessary on actuarial items, which will be noted in HATF’s proposed charges.
Please submit any comments to jkoenigsman@naic.org by Tuesday, September 26, 2023.
Enhanced Cash Surrender Value Offer Survey
Annuity Suitability (A) Working Group Adopted FAQ Guidance Document Adopted FAQ Guidance Document
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 document is being exposed for a 7-day public comment period ending Wednesday, October 4th, 2023:
Please send comments to Scott O'Neal by close of business on Wednesday, October 4th, 2023.
The following document is being exposed for a 47-day public comment period ending Monday, November 13th, 2023:
Please send comments to Scott O'Neal by close of business on Monday, November 13th, 2023.
The following document isbeing exposed for a 7-Day public comment period ending September 13th, 2023.
Please send comments to Scott O'Neal by close of business on September 13th, 2023.
The following documents are being exposed for a 30-Day public comment period ending September 12th, 2023.
Please send comments to Scott O'Neal by close of business on September 12th, 2023.
The following document is being exposed for a 45-Day public comment period ending September 27th, 2023.
Please send comments to Scott O'Neal by close of business on September 27th, 2023.
The following documents are being exposed for a 30-day public comment period ending Wednesday, August 23rd, 2023:
- Proposed 2023 HMI and FMI Rates
- Note: The proposed male FMI rates over 61 were corrected from the file distributed for the 7/20 LATF call.
- 2023 HMI and FMI Presentation
Please send comments to Scott O'Neal by close of business on Wednesday, August 23rd, 2023.
Note: While the written comment due date is August 23rd, the VM-20 historical and future mortality improvement rates will be discussed at the Life Actuarial (A) Task Force session (8/11-8/12) of the NAIC Summer National Meeting. Therefore, it would be appreciated if interested parties could review and provide verbal comments at the NAIC Summer National Meeting.
Response to Craig Chupp’s Question on the why not all of the attained ages show deterioration that grades to zero in the first three projection years of the future mortality improvement rates:
In response to the question from Craig Chupp about the 2026 FMI year scale factors being non zero for some ages, there are some ages (under 21 and over 61) where the application of the full impact of COVID to develop the COVID adjustment (for 2024 and 2025 FMI) results in not deterioration but slight improvement at these ages. This occurs because of the application of the new smoothing method - which produces MI scales and COVID impact adjustments that are more refined by age group.
Therefore, for ages under 21 and over 61, the standard methodology for FMI is applied – i.e., the scales grade from the HMI level at 2023 to the overall long-term MI rate at year 10 of the reserve projection.
The following documents are being exposed for a 44-day public comment period ending Friday, July 28th, 2023:
Please send comments to Scott O'Neal by close of business on Friday, July 28th, 2023.
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.
There are no exposure drafts at this time.
There are no Exposure Drafts at this time.
The following document is being exposed for a 90-day public comment period ending Tuesday, October 24th, 2023:
Please send comments to Scott O'Neal by close of business on Tuesday, October 24th, 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.
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.
To: Long-Term Care Actuarial (B) Working Group Members, Interested Regulators, and Interested Parties
Potential upcoming focus points for discussion on a single actuarial approach to multi-state long-term care rate increase reviews include:
- Can adjustments to the Minnesota cost-sharing formula result, generally, in older age / higher duration / higher past rate increase policyholders having their future rate increases be more limited than under the current approach?
- Would such an adjusted Minnesota approach align with key principles (either developed by ACLI / AHIP or others that may be important to regulators and interested parties) such that it could be considered a candidate for the single actuarial approach?
- Should interest rate history and expectations be a part of a single actuarial approach like it is with the Minnesota approach?
_____________________________________________________________________________________________________________________
Please provide comments on the following by Monday, July 10, 2023:
- The Minnesota and Texas approaches, as described in the Long-Term Care Insurance Multistate Rate Review Framework MSA Framework Final Adopted 2022.
- The Utah Proposal for an Alternative Approach to LTCI Rate Increase Reviews LTC Increase - Utah.
Among the options for the form of comments being sought are:
- A scorecard assessing the approaches’ success in meeting key principles. These principles can be from the list provided on June 2, 2023 by ACLI / AHIP Final ACLI-AHIP Comment Letter June 2, 2023, or as developed or thought of by the commenter.
- Assessment of the rate increase amounts resulting from the approaches, including for various types of situations, e.g., older and newer business, blocks with short or lengthy rate increase histories.
Comments should be submitted to Eric King by Monday, July 10, 2023.
_____________________________________________________________________________________________________________________
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
PBM White Paper Draft (Adopted by the PBM Regulatory Issues Subgroup, July 27, 2023 with Sept. 21, 2023, Proposed Revisions)
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
PBM White Paper Draft (Adopted by the PBM Regulatory Issues (B) Subgroup, July 27, 2023)
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. The comment period has been extended to Friday, July 7. Please send comments to NAIC staff Anne Obersteadt at aobersteadt@naic.org.Cannabis Insurance White Paper Exposure Draft.pdf
There are no exposure drafts at this time.
To CASTF, interested regulators, and interested parties:
CASTF held an optional, regulator-only meeting on June 22 to discuss a proposed new actuarial standard of practice on enterprise risk management (http://www.actuarialstandardsboard.org/asops/enterprise_risk_management_exposure_draft/).
Following that meeting, Julie Lederer considered the discussion and drafted the attached comments. The plan would be for CASTF to discuss and consider adoption at the Summer National Meeting. The adopted comments would then be sent to the Actuarial Standards Board.
Please review the proposed comments and send feedback to Kris DeFrain (kdefrain@naic.org) by Friday, July 21.
The 2023 Regulatory Guidance document is exposed for public comment.
Please send comments to Kris DeFrain kdefrain@naic.org by Friday, September 1, 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.
MCAS Data Call (post 6/5/2023)
New Public Adjuster Licensing Charge
Adopted by the Producer Licensing (D) Task Force: May 31, 2023
Adopted by the Market Regulation and Consumer Affairs (D) Committee: July 27, 2023
Review and amend, as needed, the Public Adjuster Licensing Model Act (#228) to enhance consumer protections in the property and casualty claims process.
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
Draft #3:
Model 880 - Amendments Draft #3 6.29.23
New Comments Received:
- MO DOI Comments (7.21.23)
- NAIC Consumer Reps Comments (7.25.23)
- AHIP Comments (7.21.23)
State Comments:
- HI DOI Comments (3.29.23)
- ME DOI Comments (11.18.23)
- MO DOI Comments (3.13.23)
- OH DOI Comments - PLMA (Model 218)
- OH DOI Comment Letter 11.15.22
- OH DOI Comment Letter 11.18.22
- OK DOI Comments (9.30.22)
- RI DOI Comments (8.1.22)
Industry Comments:
- ACLI Comments (9.30.22)
- AHIP Comment (9.30.22)
- AHIP Comment (11.18.22)
- AHIP Updated Comments (11.2.22)
- Health Benefits Institute Comments (9.30.22)
- NAIC Consumer Representatives Comments (9.30.22)
- NAHU Comments (9.30.22)
Draft Chapter 23-Conducting the Life and Annuity Examination June 6, 2023 Draft (The June 6, 2023 draft contains changes from the previous version, dated Aug. 22, 2022. The June 6, 2023 updates in the draft are highlighted in blue, they occur on pages 30 and 34 (in Marketing and Sales Standards 9 and 10.)
The comments due date on the June 6, 2023 Chapter 23 exposure draft was extended to Sept. 4, 2023 at the Working Group's July 18, 2023 Webex meeting; the comments due date was changed to Sept. 5, 2023 due to the Sept. 4 Labor Day holiday, the comments due date prior to the July 18th extension was July 6, 2023.
Draft Chapter 23-Conducting the Life and Annuity Examination August 22, 2022 Draft (The Aug. 22, 2022 draft contained updates highlighted in yellow, which took into consideration comments received on the April 19, 2022 draft; the Aug. 22 draft was discussed at the Sept. 8 and Oct. 20, 2022 meetings and at the March 28, 2023 meeting.)
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))
New Draft Travel Insurance-Related Standardized Data Requests (These SDRs are currently in the process of being revised, and updated exposure drafts will be posted when they are available, along with a comments due date.)
- Travel In Force SDR, August 17, 2022 Draft
- Travel Claims SDR, August 17, 2022 Draft
Draft Chapter 4-Collaborative Actions June 6, 2023 Draft (The purpose of the revisions is to incorporate changes into Chapter 4, providing nonregulators with transparency and insight regarding the multistate process that occurs at the Market Actions (D) Working Group (MAWG))
The June 6, 2023 draft Chapter 4 was adopted by the Working Group at its July 18, 2023 Webex meeting, the chapter underwent additional revisions during that meeting, as part of that adoption.
Revised Draft Chapter 24B-Conducting the MHPAEA-Related Examination July 11, 2022 Draft (This draft was discussed at the July 14, 2022 Webex. Changes were made to Standard 5 on pages 14-15 and Standard 6 on pages 17-18; they are shown in yellow highlight. These revisions were made to the July 6, 2022 Chapter 24B Draft).
NOTE: The Chapter 24B-Conducting the MHPAEA-Related Examination adopted by this Working Group on July 14, 2022 and by the Market Regulation and Consumer Affairs (D) Committee on August 12, 2022 at the Summer 2022 Hybrid National Meeting is provided at this link Chapter 24B-Conducting the MHPAEA-Related Examination Adopted 8-12-2022. Regulators, this document is also provided on the Market Regulation Handbook Web Page on StateNet.
New Draft Chapter 24B-Conducting the MHPAEA-Related Examination July 6, 2022 Draft (Updated with regard to the Working Group's June 9th discussion on comments received on the April 19, 2022 Chapter 24B Draft)
New Draft Chapter 24B-Conducting the MHPAEA-Related Examination April 19, 2022 Draft (Updated to correspond with updated federal guidance on Mental Health and Substance Use Disorder Parity Compliance)
- WI 05-25-22 Comments
- MO 05-27-22 Comments
- VA 05-27-22 Comments
- AHIP 05-27-22 Comments
- ABHW 05-27-22 Comments
- BCBSA 05-27-22 Comments
New Draft Chapter 1-Introduction July 6, 2022 Draft (Revisions relate to the Working Group's discussion re: the Oct. 27, 2021 Chapter 20 draft in its previous meetings on Nov. 4, 2021, March 10, 2022, April 21, 2022 and June 9, 2022)
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)
- 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 - Pet Insurance Scorecard Ratios Draft
- Pet Insurance Ratios v1 9/7/2023
Charge to Assess Currently Available Market Analysis Data
- Market Analysis Data Sources 6/23/2023
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
The Task Force's - Improper Marketing of Health Insurance (D) Working Group has been 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 began reviewing the Unfair Trade Practices Act (Model 880) in 2022. During the 2023 Summer National Meeting the Working Group adopted amendments to Model 880.
The Task Force has exposed the adopted draft (8.14.23) and is extending the comment period comments until Friday, October 12, 2023. Please review and submit any comments or suggestions to GWelker@naic.org
Comments will be posted below and discussed on conference call in October for potential adoption.
Comments:
---------------------------
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
The Committee has extended the public comment period for this exposure to end at start of business on Monday, October 9, 2023. Please submit comments to NAIC staff, Dan Daveline.
The following documents are being exposed for a public comment period ending on September 18th, 2023
Please submit comments to Sherry Flippo by EOD on September 18th. 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 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.
There are no exposure drafts at this time.
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 September 7, 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. | 10/12/2023 |
| 2023-06BWG Modified | 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. | 10/12/2023 |
| 2023-07BWG Modified | 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. | 10/12/2023 |
| 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). | 10/12/2023 |
| 2023-12BWG | Categorize debt securities on Schedule BA that do not qualify as bonds under SSAP No. 26—Bonds or SSAP No. 43R—Asset‐ Backed Securities and are captured in scope of SSAP No. 21R—Other Invested Assets. |
10/12/2023 |
Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated August 13, 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 SEPTEMBER 12, 2023 | ||||
|---|---|---|---|---|
|
SSAP No. 20 SSAP No. 21R |
Collateral for Loans |
Re-exposed revisions which require audits of SSAP No. 48—Joint Ventures, Partnerships and Limited Liability Companies and SSAP No. 97—Investments in Subsidiary, Controlled and Affiliated Entities investments pledged as collateral to ensure that the comparison for admittance is between the net audited equity value and the collateral loan. |
||
|
SSAP No. 43R SSAP No. 48 |
Residuals | Revisions clarify the scope and reporting for investment structures that represent residual interests within SAP. | ||
| INT 23-02T | INT 23-02T | 3rd Quarter CAMT | Interpretation recommends that for third-quarter 2023, reporting entities should disclose whatever information is available regarding the corporate alternative minimum tax and their applicable reporting entity status. | |
| INT 23-03T | CAMT Guidance | Interpretation provides guidance effective beginning year-end 2023 reporting of the corporate alternative minimum tax, which applies SSAP No. 101—Income Taxes with modification and provides disclosures. | ||
| EXPOSURES with PUBLIC COMMENT PERIOD ending SEPTEMBER 29, 2023 | ||||
|
SSAP No. 21R |
Principles-Based Bond Definition | Revisions to SSAP No. 21R for debt securities that do not qualify as bonds as well as an Issue Paper to detail historical discussions on the bond project. | ||
| 2022-12 | INT 03-02 | Nullification of INT 03-02 | Re-exposed intent to nullify INT 03-02, as of Dec. 31, 2023, as it is inconsistent with SSAP No. 25—Affiliates and Other Related Parties guidance regarding economic and non-economic transactions between related parties. | |
| 2022-14 | New Market Tax Credits | Revisions to SSAP No. 93—Low-Income Housing Tax Credit Property Investments and SSAP No. 94R—Transferable and Non-Transferable State Tax Credits and updates made in response to comments received from interested parties. | ||
| 2023-14 | SSAP No. 7 | Asset Valuation Reserve and Interest Maintenance Reserve | Proposes a long-term project to capture accounting guidance for AVR and IMR in SSAP No. 7—Asset Valuation Reserve and Interest Maintenance Reserve. | |
| 2023-15 | Annual Statement Instructions | IMR/AVR Specific Allocations | Revisions to the annual statement instructions to remove guidance that permits the specific allocation of non-interest-related losses to IMR. | |
| 2023-16 | SSAP No. 48 | Schedule BA Categories | Proposes to further define, for consistency purposes, investments captured as non-registered private funds, joint ventures, partnerships or limited liability companies, or residual interests and reported based on the underlying characteristics of assets. | |
| 2023-17 | SSAP No. 2R | Short-Term Investments | Revisions to further restrict the investments that are permitted for cash equivalent or short-term investment reporting. | |
| 2023-18 |
SSAP No. 5R SSAP No. 92 SSAP No. 102 SSAP No. 103R |
ASU 2016-19 – Technical Corrections and Improvements | Revisions adopt with modification certain aspects of ASU 2016-19–Technical Corrections and Improvements. Revisions also propose amending SSAP No. 92—Postretirement Benefits Other Than Pensions guidance on insurance contracts to use the same terminology used in SSAP No. 102—Pensions. | |
| 2023-19 | Appendix D | ASU 2018-09 – Codification Improvements | Revisions reject ASU 2018-09 in Appendix D as not applicable for statutory accounting. | |
| 2023-20 | Appendix D | ASU 2010-10 – Codification Improvements | Revisions reject ASU 2010-10 in Appendix D as not applicable for statutory accounting. | |
| 2023-21 |
SSAP No. 92 SSAP No. 102 |
Remove Transition Language | Revisions to SSAP No. 92—Postretirement Benefits Other Than Pensions and SSAP No. 102—Pensions to remove the transition guidance that was included in the initial adoption of SSAP No. 92 and SSAP No. 102, as it is past the 10-year effective period for that transition. | |
| 2023-22 | SSAP No. 54R | AG 51 and Appendix A-010 Interaction | Revisions clarify that gross premium valuation (under Appendix A-010) and cash-flow testing (under Actuarial Guideline LI—The Application of Asset Adequacy Testing to Long-Term Care Insurance Reserves [AG 51]) are both required if indicated. | |
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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. |
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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. |
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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. | ||
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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. |
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The Task Force is exposing the following for a 30-day public comment period, please submit comments to Eva Yeung by COB, Wednesday, September 13, 2023.
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.
Exposure of the American Council of Life Insurers (ACLI) Proposal for Repurchase Agreements
Comments should be sent electronically to Dave Fleming by COB Friday, September 29, 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.
The Financial Analysis Solvency Tools (E) Working Group has exposed the following document with a public comment period ending Monday, September 25, 2023. Comments directed to NAIC staff, Ralph Villegas.
There are no exposure drafts at this time.
The following documents are currently exposed for comment:
Risk-Focused Surveillance (E) Working Group Referral & Revisions
Climate and Resiliency (EX) Task Force Referral & Revisions
Comments should be sent to Elise Klebba at eklebba@naic.org by close of business on Monday, September 25, 2023.
There are no exposure drafts at this time.
The following document is being exposed for a public comment period ending September 15, 2023
Please send comments to Jane Koenigsman by close of business on September 15, 2023.
The following documents are being exposed for a public comment period ending September 14, 2023
- Amendments to the Property and Casualty Insurance Guaranty Association Model Act (#540)
- US Resolution Template
Please send comments to Jane Koenigsman by close of business on September 14, 2023.
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.
On September 21, the Task Force exposed proposed new disclosures for catastrophe reinsurance programs for P&C RBC, for a 30-day exposure period ending Monday, October 23.
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:
Comments should be sent electronically to Charles Therriault and Denise Genao by Friday, July 14, 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.
There are no exposure drafts at this time.
H Cmte Structure and Charge Revisions
______________________________________________________________________________________________________
Written comments will be accepted through Tuesday, September 5, 2023 and should be summited to Miguel Romero (maromero@naic.org).
In addition, the H Committee will hear comments from in-person attendees during the meeting of the Committee at the NAIC’s Summer National Meeting on Sunday, August 13, 2023 at 2:00 p.m. PT. Persons who wish to comment in person are requested to notify Miguel Romero (maromero@naic.org) by Wednesday, August 9 at 5:00 p.m. ET of their desire to speak and their affiliation, in order to properly allocate time among speakers. If time permits, individuals who did not provide prior notice of their desire to comment will be invited to do so when all other speakers have concluded their remarks.
The Working Group is exposing the draft Framework until October 9, 2023.
Please submit comments to Olivea Myers by COB October 9, 2023.
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 7-11-23.pdf
Second Public Exposure Draft of the new Insurance Consumer Privacy Protections Model Law #674 (Version 1.2 dated July 11, 2023) (incorporates revisions based on comments received prior to and after the Interim Meeting) is being exposed for a public comment period from July 11, 2023 to July 28, 2023. All comments received will be discussed during open meetings beginning with the July 25, 2023 conference call.
Exposure Draft-Consumer Privacy Protection Model Law #674 as of 7-11-23.pdf
Pending - 2023 Workplan for Privacy Protections (H) Working Group
6/23/23 Revisions to Sections 17 through 20 of the 1/31/23 Exposure Draft Model Law #674-Comments are due July 10, 2023
Exposure of Sections 17-18-19-20 REV.pdf
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