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Structured Securities Group (SSG)

The NAIC's Structured Securities Group (SSG), another group within the Capital Markets & Investment Analysis Office, is responsible for the analysis of Residential Mortgage Backed Securities (RMBS) and Commercial Mortgage Backed Securities (CMBS) owned by state regulated insurance companies subject to Statement of Statutory Accounting Principles No. 43 Revised - Loan-Backed and Structured Securities. Insurance companies report ownership of securities to the Capital Markets and Investment Analysis Office when such securities are eligible for filing on Schedule D or DA of the NAIC Financial Statement Blank.

The SSG group primarily support the Valuation of  Securities Task Force (VOS/TF), a subgroup of the Financial Condition (E) Committee, but also supports other Task Forces and  Working Groups that involve investments.


Please contact the SSG at  for general information. 

For specific issues or concerns please contact Eric Kolchinsky, Director, Structured Securities Group , at 212.386.1943.or

Filing Instructions & Forms:

General Information:

Special Comment:

Reporting Interface

Access the system in AVS+

View a tutorial
Learn how to use the system

User's guide
Review the system

Account Manager
View the invoice details and
pay online.

Contacts for RMBS / CMBS Initiative

The NAIC looks forward to working with insurers to provide the appropriate structured securities information to facilitate the year-end Annual Statement filing process. Please direct inquiries as follows:

Statutory accounting and/or RBC treatment: 816-783-8400, select RMBS option.

Billing or AVS+ questions:  816-783-8300, select option #5 or

Questions pertaining to modeling process, analytics & results: 212-398-9000 or


Page last updated: 3/30/2021

This website is your source for information on annual Structured Securities surveillance, including background information, updated project details as they become available, and how to file these securities in your Annual Statement filing.

Please note the information on this website may be updated frequently. Please check back regularly to ensure you have the latest information. The top right corner shows the date of when the page was last updated and the changes highlighted in yellow.

Pricing: The 2020 Structured Securities modeled data prices for CUSIPs held by insurers is $100 per CMBS CUSIP and $70 per RMBS CUSIP.

New this year

Please note that this year the Zero Loss threshold for CMBS and RMBS were lowered.

The Zero Loss threshold was lowered for 2020 from the usual Intrinsic Price* of almost 100/PAR to 99.15.


Zero Loss Intrinsic Price and Break Point Table
(Life/PC) Intrinsic Price Breakpoints
AVR_OR_NON_AVR Zero Loss threshold

 NAIC_1   NAIC_2   NAIC_3    NAIC_4    NAIC_5   ZERO_LOSS

AVR 99.15

100.00      102.17     106.96      118.75     134.90         Y

NON-AVR 99.15

 99.80       100.66     102.48      106.90     123.94         Y


Please refer to the Breakpoint Calculation Overview to better understand how the breakpoints are calculated.

*Intrinsic Price is defined as difference between Remaining Par Value and Expected Losses discounted at the coupon rate of the security (adjusted in case of original issue discount securities to book yield at original issue, and in case of floating rate securities, discounted using LIBOR curve + Origination DM)

Price Grids are CUSIP specific price matrices containing five price breakpoints; i.e., each price corresponding to a specific NAIC Designation category.
2020 Breakpoints will match to NAIC Designations with a modifier as explained in the following document, Adopted 3/22/2021

This document also discusses the adopted recommendation to the way RMBS & CMBS securities that were issued after January 2013 will be Designated starting Year-End 2021.

Amendment to the Purposes and Procedures Manual of the NAIC Investment Analysis Office (P&P Manual) to Update the Financial Modeling Instructions for RMBS/CMBS Securities and Direct IAO Staff to Produce NAIC Designation and NAIC Designations Categories for Non-Legacy Securities


For further details please visit the VOSTF webpage


Timeline for 2020 Surveillance:

October 11, 2020 will be the last day to order and purchase additional modeled results for last year's 2019 portfolio.

October 30, 2020 — Posted Macroeconomic Scenarios and Probability Weightings to be used for the Year End 2020 Annual Surveillance of Insurer Owned RMBS and CMBS.

November 2, 2020— Initial invoice notifications emailed to the designated contact. The amount of the invoice is based on the reported RMBS/CMBS holdings of the 2019 annual statement filing, adjusted for changes reported in first quarter and second quarter 2020 filings.

November 2, 2020 — To be Modeled securities will be uploaded to RMBS/CMBS Securities Listing website. These are based on 2019 annual statement filings, adjusted for changes reported in first quarter and second quarter 2020 filings.

November 2 to 15, 2020 — Companies start submitting additional securities to their portfolios to purchase or to be considered for modeling in the December file.

November 15, 2020 — 11:59 p.m. CT deadline was extended from Nov 10, for submitting securities to be considered for modeling to be included in the December file. Submissions received after this date will be considered for modeling in the January addendum file.

November 2, 2020 to January 1, 2021 — Companies can challenge a securities modeling eligibility status in AVS+ under the "Searches > Structured Securities > Challenge STS Security".

December 10, 2020 — Update the To be Modeled securities list with additional requests from the industry and upload to RMBS/CMBS Securities Listing website.

December 21, 2020 — Modeled results made available to users via AVS+.

January 1, 2021 — 11:59 p.m. CT deadline for submitting securities to be considered for modeling to be included in the January file, and to challenge the status of a security in AVS+ if they consider that a security was not appropriately evaluated for modeling eligibility.

January 20, 2021 — Addendum file modeled results made available to users via AVS+.