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          naic exposure document index

          The following is a list of documents exposed by various work groups of the naic to the public. For additional information regarding these and other documents, their comment periods and pending actions – please visit the appropriate committees & Activities page.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          see financial stability (ex) task force page for liquidity stress test framework draft exposure document

          Draft revised utpa amended language addressing rebating 10/30/20
          comments regarding the revised proposed amendments should be submitted to denise matthews by wed., nov. 18, 2020.


          Draft revised utpa amended language addressing rebating 8/10/20
          comments regarding the revised proposed amendments should be submitted to denise matthews by aug. 28, 2020.

          ai principles as adopted by aiwg 7/1/20
          comments due to denise matthews by july 20, 2020.

          draft utpa amended language addressing rebating 6/23/20
          comments regarding the proposed amendments should be submitted to denise matthews by july 15, 2020

          nd draft anti-rebating bulletin 11/25/19

          nd draft anti-rebating bulletin 10/4/19

          nd anti-rebating guideline 7/23/19

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          draft model #275 revisions faq implementation document, draft dated sept. 4 draft faq

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

          please send comments to reggie mazyck by close of business on feb 4, 2021.

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

          please send comments to reggie mazyck by close of business on dec. 11, 2020.

          the following document is being exposed for a 7-day public comment period.

          please send comments to reggie mazyck by close of business on oct. 28, 2020.

          the following documents are being exposed for a 10-day public comment period.

          please send comments to reggie mazyck by close of business on nov. 2, 2020.

           

          these documents are being exposed for a 30-day public comment period. 

          please send comments to reggie mazyck by close of business on nov. 10, 2020.

          past exposures: 

          apf 2019-33

          please send comments to reggie mazyck by close of business on oct. 5, 2020.

           

          apf 2019-34
          please send comments to reggie mazyck by close of business on sept. 18, 2020.

           

          amendment proposal 2019-56 revisions to vm-51 data elements for auw – comments due to reggie mazyck by october 7, 2019.
          apf 2019-56 revised data elements vm51 (word)
          appendix- vm51 data elements markup simple (word)
          please note that a version of 2019-56 reflecting the potential adoption of edits to amendment 2018-59 will be posted when it becomes available.

          there are no exposure drafts at this time.

          comments received on jan. 28 exposure of revisions to ag49:
          academy comments
          acli comments
          allianz comments
          global atlantic ag49 draft
          global atlantic comments
          independent proposal comments
          iul coalition comments
          iul coalition ag49 redline
          securian/nationwide/penn mutual/prudential/mutual of omaha comments
          vincent tsang comments

          please provide comment on the options presented on the january 28, 2020 subgroup call (and included in the call materials) related to the supplemental option budget. comments which provide pros and cons of either option, provide an additional option, or include proposed draft revisions to actuarial guideline 49 would be appreciated.

          submit comments to reggie mazyck by feb. 14.

          the vm-22 (a) subgroup is exposing the academy annuity reserves work group (arwg) presentation on the preliminary framework elements for fixed annuity pbr for a 45-day public comment period ending dec. 14.

          please submit comments to reggie mazyck (rmazyck@naic.org) by close of business dec.14.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          qtl template.xlsx pennsylvania revised draft qtl template draft may 28, 2020

          qtl template instructions.docx revised draft qtl template instructions may 28, 2020

          mhpaea assumptions exposure.docx mhpaea draft assumptions march 10, 2020

          there are no exposure drafts at this time.

          pbm model draft pbm model act draft date oct. 29, 2020

          hmo model draft adopted by the subgroup, july 13, 2020

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no current exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          new draft chapter 24-conducting the health examination for inclusion in the market regulation handbook (revised guidance regarding supplementary and short-term health insurance)

          the posted revisions to the conducting the health examination chapter were adopted by the working group on its november 19, 2020 call. 

          new draft long-term care standardized data requests for inclusion in the reference documents of the market regulation handbook

          the long-term care in force and long-term care claims sdrs were adopted by the working group on its november 19, 2020 call.

          new inland marine standardized data requests for inclusion in the reference documents of the market regulation handbook

          the inland marine in force and inland marine claims sdrs were adopted by the working group on its july 23, 2020 call.

          new limited long-term care exam standards chapter 26a december 11, 2019 draft for inclusion in the market regulation handbook

          the limited long-term care exam standards, dec. 11, 2019 draft, were adopted by the working group on its july 23, 2020 call. 

          new limited long-term care exam standards chapter 26a october 29, 2019 draft for inclusion in the market regulation handbook

          new farmowners standardized data requests for inclusion in the reference documents of the market regulation handbook

          the farmowners in force sdr and farmowners claims sdr were adopted by the working group on its dec. 18, 2019 call, and adopted by the market regulation and consumer affairs (d) committee on its july 27, 2020 call.

          cybersecurity (ex) task force referral to market conduct examination standards (d) working group

          the following items have been tabled by the working group until further notice.

          proposed market regulation handbook substantive revisions received from the market information systems research and development (d) working group 7-12-16

          draft new health reform market conduct examination standards for nondiscrimination for inclusion in the market regulation handbook
          aug. 10, 2015 draft

          draft new health reform market conduct examination standards for nondiscrimination for inclusion in the market regulation handbook
          aug. 3, 2015 draft

          section d. standards of chapter 14-sampling of the market regulation handbook 9/18/14

           

          on october 29, 2020 the antifraud technology (d) working group completed their review and adopted revisions to the naic antifraud plan guideline (#1690). the focus was to reorganize the guidelines into a more intuitive order, to eliminate repetitive requirements within the existing guidelines, and add suggestions to better meet existing requirements for nearly all states.
           

          the antifraud (d) task force is soliciting comments on the revisions with a deadline of thursday, november 12, 2020.  comments/suggestions can be sent to greg welker gwelker@naic.org  
           

          the track changes draft, and the track changes accepted draft adopted by the working group can be found below.
           

          the antifraud (d) task force will potentially adopt the revisions to the antifraud plan guideline (#1690) on its november 16, 2020 - open webex meeting.

           

          antifraud plan guideline

          the antifraud technology (d) working group has been reviewing the 2011 naic antifraud plan guideline for potential revisions. the focus has been to reorganize the guidelines into a more intuitive order, to eliminate repetitive requirements within the existing guidelines, and add suggestions to better meet existing requirements for nearly all states.

          in order to finalize the review of the naic antifraud plan guideline the working group will be holding conference calls through october. the dates for the scheduled conference calls are listed below. 

           

          conference call schedule:

          • thursday, september 17th  -  9am alaska/10am pacific/11am mountain/12pm central/1pm eastern

           

           

           

           

          comments received by january 5, 2020

           

          comments received by september 8, 2020 (draft 3 8.3.20)

           

           

          guideline drafts

          there are no exposure drafts at this time.

          state licensing handbook review

          in 2019 the producer licensing uniformity (d) working group was given the charge to review the state licensing handbook. the working group split out the review process into sections consisting of five chapters for each review period.  the comments received and the redline chapters  can be found attached below.  the handbook will be presented to the executive committee for final adoption at the summer national meeting.

          comments received:

          chapters 1 – 5

          chapters 6-10

          chapters 11-15

          chapters 16-20

          chapters 21-25

          • no comments at this time.

          chapters 26-30

          redlined chapters:

           


          naic uniform application

          the naic uniform applications were adopted by the market regulation and consumer affairs (d) committee at the 2018 naic summer national meeting. at this time the applications have not been presented to the naic executive committee pending an additional review and discussion of the revisions.

          continuing education reciprocity agreement

          in 2019 the working group reviewed the continuing education reciprocity (cer) agreement. the naic's general counsel advised the working group that a revision of the agreement would not be feasible due to the date of the cer agreement and inaccurate/dated information it contains. the decision was to create a new cer agreement. during the fall national meeting the producer licensing (d) task force adopted the 2019 cer agreement. the agreement will be presented to the executive committee during the summer national meeting for final adoption. the adopted draft is attached below.

          there are no exposure drafts at this time.

          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 naic/aicpa working group has exposed the following for a comment period ending dec. 4. 

          please submit comments to bruce jenson by end of business on december 4th. 

          the following proposals are exposed for a 30-day comment period ending sept. 25th. please submit comments via email to jane barr.

          • 2020-01 electronic notary -the purpose of this modification to form 11 (biographical affidavit) and form 15 (affidavit of lost certificate of authority) to accept an electronic notary in addition to a wet notary. states- comments should include whether your state has specific language that would need to be included on the notary page of either form.
          • 2020-02 inclusion of the corporate governance annual disclosure (cgad) as a requirement to the primary – redomestication application.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          the rfswg and orsa implementation subgroup agreed to expose the proposed handbook revisions for a 30-day public comment period ending on sep. 30. comments should be submitted to bruce jenson (bjenson@naic.org). 

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          blanks (e) working group
          items received for comment

          last updated october 21, 2020

          please address comment letters to jacob garn, chair of the blanks (e) working group, and direct to mary caswell and calvin ferguson.

          ref no. description comment deadline
          2020-28bwg remove the disclosure for the affordable care act section 9010 assessment from note 22 - events subsequent. the purpose of this proposal is to reflect disclosure changes adopted by the statutory accounting principles (e) working group superseding ssap no. 106—affordable care act section 9010 assessment (ref #2020-05). the affordable care act section 9010 assessment has been repealed effective jan. 1, 2021, and these revisions will remove the disclosure. 11/23/2020
          2020-29bwg remove the line category and reference to the naic bond fund list (bond list) from the investment schedule instructions and blank. the purpose of this proposal is to reflect disclosure changes adopted by the statutory accounting principles (e) working group superseding ssap no. 26r—bonds and ssap no. 30r—unaffiliated common stock (ref #2020-01) to eliminate references to the naic bond fund list (bond list). 11/23/2020
          2020-30bwg move the interrogatory question regarding communication of internal control related matters noted in audit from the annual supplemental exhibits and schedules interrogatories to the quarterly supplemental exhibits and schedules interrogatories to be answered for the 2nd quarter. for title, a new page in the quarterly statement will be added for the supplemental exhibits and schedules interrogatories. 11/23/2020
          2020-31bwg

          replace the life, health and annuity guaranty association model act assessment base reconciliation and the adjustments to the life, health and annuity guaranty association model act assessment base reconciliation exhibits with modernized exhibits in order to promote consistent reporting of assessable premiums among industry members and to reflect changes in guaranty association laws adopted over the past two decades.

          drafting note life, health and property annual statement blank and instructions

          edit the blank and instructions for the life, health and annuity guaranty association assessable premium exhibits part 1 and part 2. the exhibits are to continue to be filed as stand-alone supplemental exhibits in each of the life, health and property blanks due april 1.

          11/23/2020
          aca guidance

          memo from statutory accounting principles (e) working group providing guidance for the aca disclosure in note 22. because the federal aca insurer fee, which is also known as the health insurance tax, has been repealed effective jan. 1, 2021, proposal 2020-28bwg proposes to officially remove the disclosure from the annual statement when adopted.

          11/23/2020
          health care receivables guidance (updated 11/18/2020)

          provides guidance on reporting collection and offset amounts on exhibit 3a, which the health risk-based capital (e) working group is requesting to be posted to the bwg web page.

          note: this document has not yet been approved by health risk-based capital (e) working group and is pending final approval on 10/29.

          11/23/2020

          2020-02bwg

           

          modify the instructions and illustration for note 10l to reflect the disclosure changes for ssap no. 97—investments in subsidiary, controlled, and affiliated entities adopted by the statutory accounting principles (e) working group. 7/28/2020

           

           

          exposure drafts outstanding
          statutory accounting principles (e) working group
          last updated 11/12/2020

          please address comment letters to dale bruggeman, chair of the statutory accounting principles (e) working group, and direct to julie gannrobin marcotte, jim pinegarfatima sediqzad and jake stultz.

          for the status of all sapwg agenda items, please refer to the maintenance agenda.
           

          exposures with comment deadline of january 11, 2021
          2019-24 ssap no. 71 levelized and persistency commission exposed previously exposed nonsubstantive revisions with minor clarifications noting that the revisions shall apply to contracts in effect on the date of adoption. revisions distinguish traditional persistency commission from a funding agreement. the statutory accounting principles (e) working group directed naic staff to draft an issue paper documenting the discussion.
          2019-34 ssap no. 25 related parties, disclaimer of affiliation and variable interest entities revisions clarify the identification of related parties, with changes from the prior exposure to reflect discussions with interested parties. the revisions also include a new disclosure recommended by the group solvency issues (e) working group.
          2020-22 ssap no. 26r accounting for perpetual bonds revisions clarify that perpetual bonds with a call feature shall apply the yield-to-worst concept and be reported at amortized cost. fair value is required for all other perpetual bonds.
          2020-32 ssap no. 26r disclosure update revisions expand the disclosures for called bond to also include bonds terminated through a tender offer.
          2020-33 ssap no. 32r publicly traded preferred stock warrants revisions capture publicly-traded preferred stock warrants within scope of ssap no. 32r and require fair value reporting.
          2020-34 ssap no. 43r gse crt program revisions incorporate minor scope modifications allowing freddie mac structured agency credit risk (stacr) and fannie mae connecticut avenue securities (cas) issued through a real estate mortgage investment conduit (remic) structure.to remain in scope of ssap no. 43r.
          2020-35 ssap no. 97 ssap no. 97 – audit opinions exposed agenda item with a request for comments on the extent to which situations exist that hinder the admittance of paragraph 8.b.iii. entities (u.s. and foreign noninsurance u.s. gaap basis scas) due to the inability to quantify the departure from of u.s. gaap.
          2020-36

          ssap no. 86

          ssap no. 108

          derivatives hedging fixed indexed products exposed agenda item to solicit comments from state insurance regulators and industry on establishing accounting and reporting guidance for derivatives hedging the growth in interest for fixed indexed annuity products. a notification of the exposure will be sent to the life actuarial (a) task force.
          2020-37 ssap no. 56 separate account product mix exposed agenda item to solicit comments regarding the degree of product granularity that should be captured in separate account general interrogatory 1.01.
          2020-38 ssap no. 56 pension risk transfer disclosure exposed agenda item to solicit comments regarding possible modifications to specifically address pension risk transfers (prts), including items such as separate identification transactions, guarantees, reserve assumptions.
          2020-39 appendix f interpretation policy statement appendix f—policy statements: revisions clarify the issuance and adoption process of accounting interpretations in the naic policy statement on maintenance of statutory accounting principles.
          2020-40 preamble prescribed practices revisions clarify that while any state in which a company is licensed can issue prescribed practices, the prescribed practices directed by the domiciliary state shall be reflected in the financial statements filed with the naic and are the financial statements subject to independent audit requirements.
          2020-41 ssap no. 43r asu 2020-06, convertible instruments revisions reject accounting standards update (asu) 2020-06, debt—debt with conversion and other options (subtopic 470-20) and derivatives and hedging—contracts in entity’s own equity (subtopic 815-40), accounting for convertible instruments and contracts in an entity’s own equity, as this asu primarily addresses various convertible debt valuation models along with bifurcating embedded derivative components, which are not concepts supported under statutory accounting.
          2020-42 appendix d asu 2020-07, presentation and disclosures by not-for-profit entities revisions reject asu 2020-07, presentation and disclosures by not-for-profit entities as not applicable to statutory accounting.
          exposures with comment deadline of december 15, 2020
          int 20-11 ssap no. 6 int 20-11: extension of ninety-day rule for the impact of 2020 hurricanes, california wildfires and iowa windstorms

          this tentative interpretation provides a 60-day extension from the ninety-day rule for uncollected premium balances, bills receivable and amounts due from agents and for policies directly impacted by the noted 2020 hurricanes, california wildfires and iowa windstorms. this temporary relaxation of the 90-day rule, for directly impacted policies, is similar to previous extensions that have been granted for other major national storms and hurricanes. for this interpretation the 60-day extension applies to uncollected premiums more than 90 days overdue from impacted policies at year-end 2020 and expires prior to the 1st quarter 2021 financial statements. (discussion is planned at the dec. 18 meeting of the statutory accounting principles (e) working group.)

          exposures with comment deadline of december 4, 2020
          2019-21

          ssap no. 43r

          ip no. 1xx

          iowa insurance division proposal

          interested party comment letter, july 31, 2020

          exposed the iowa insurance division proposal to establish principles on what is intended to be captured on schedule d-1: long-term bonds. for further clarity, this exposure is not proposing to expand the scope of ssap no. 26r—bonds, but rather identify principles of investments that should be captured on schedule d-1, regardless if the investment is in scope of ssap no. 26r or ssap no. 43r. comments are requested by dec. 4, 2020. the iowa proposal is the exposed item. (for reference purposes, the previously exposed issue paper and july 31, 2020 comment letter are also provided as attachments.)
          2020-24 int 2020-10t nonconforming credit-tenant loans via an evote conducted on november 18, 2020, the statutory accounting principles (e) working group exposed a tentative int to clarify the accounting and reporting of nonconforming credit-tenant loans (ctls). this int intends to address questions received from the action directed during the working group's meeting on november 12 as well as specifically identify the exception to the policy Statement on Coordination of the AP&P Manual and the P&P Manual.

          exposures deferred for subsequent interim or national meeting

          2018-07

          ssap no. 41r

          surplus note accounting – referral from the reinsurance (e) task force

          the statutory accounting principles (e) working group deferred discussion of this agenda item for a subsequent call or meeting.

          2019-12

          comments

          ssap no. 68

          asu 2014-17, business combinations, pushdown accounting

          the statutory accounting principles (e) working group deferred discussion of this agenda item for a subsequent call or meeting.

          2019-14

          comments

          ssap no. 68

          ssap no. 97

          attribution of goodwill this agenda item addresses attribution and tracking of goodwill when multiple scas are purchased.

          2019-49

          comments

          ssap no. 62r

          retroactive reinsurance exception

          the statutory accounting principles (e) working group deferred discussion of this agenda item for a subsequent call or meeting.

          the task force is exposing the following proposal for a 45-day comment period. please submit comments to jane barr by cob december 11, 2020.

          health care receivable annual statement
          please send comments to crystal brown by the close of business, december 11, 2020.

           

          there are no exposure drafts at this time.

          the working group, is exposing the following proposal for a 35-day comment period. please submit comments to eva yeung by cob december 1, 2020.

          the following proposal is exposed for a 30-day comment period. please submit comments to eva yeung by cob november 18, 2020.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          the financial analysis solvency tools (e) working group has posted the following document for a 30 day exposure period ending october 23, 2020: 

          please submit all comments to rodney good (rgood@naic.org) by end of business on october 23, 2020

          there are no exposure drafts at this time.

          the following revisions are exposed for a 30 day comment period ending nov 4, 2020.

          comments can be sent to bailey henning (bhenning@naic.org) and are due by close of business nov 4, 2020

          there are no exposure drafts at this time.

          the receivership and insolvency (e) task force released for public comment a new draft model guideline for the definition of reciprocal state in receivership: 

          comments are due to jane koenigsman (naic) by dec. 31, 2020

          the receivership financial analysis (e) working group (r-fawg) of the receivership and insolvency (e) task force (ritf) requests feedback on any recommended best practices for overcoming challenges that states, receivers, and guaranty associations have faced in the administration of a receivership due to the current pandemic and related travel/business restrictions, work-from-home, economic impact, etc.

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

           

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

           

          please submit feedback to jkoenigsman@naic.org

          there is no exposure draft at this time. 

          there are no exposure drafts at this time.

           

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

          during the 2020 summer national meeting, the financial regulation standards and accreditation (f) committee exposed the following items. comment letters should be emailed to me at bmeyer@naic.org prior to friday september 11, 2020.

          rrg analysis guideline referral

          salary ranges referral(combined)

          there are no exposure drafts at this time.

          there are no exposure drafts at this time.

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