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 below document is exposed for comments until COB January 18, 2024 by the Solvency Workstream of the Climate & Resiliency (EX) Task Force. Please submit comments to Dan Daveline.
LIFE WORKSTREAM
Feedback requested on Barriers to Access to Life Insurance -- ACLI Letter
Draft Finanical Literacy Course Endorsement - Comments due April 1, 2024
Draft Financial Wellness Resource Guide - Comments due April 1, 2024
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 re-exposed for a 14-day public comment period ending Wednesday, May 22, 2024:
Please send comments to Scott O'Neal by close of business on May 22nd, 2024.
The following documents are being exposed for a 21-day public comment period ending Wednesday, May 29, 2024:
Please send comments to Scott O'Neal by close of business on May 29th, 2024.
The following document is being exposed for a 21-day public comment period ending Wednesday, May 22, 2024:
Please send comments to Scott O'Neal by close of business on May 22nd, 2024.
The following document is being re-exposed for a 21-day public comment period ending Wednesday, May 15, 2024:
Please send comments to Scott O'Neal by close of business on May 15th, 2024.
The following document is being exposed for a 30-day public comment period ending Friday, May 3rd, 2024:
Note: Please provide comments on the language in the APF and the exposure questions provided in the cover letter.
Please send comments to Scott O'Neal by close of business on May 3rd, 2024.
The following document is being exposed for a 60-day public comment period ending Friday, May 17th, 2024:
Please send comments to Scott O'Neal by close of business on May 17th, 2024.
There are no exposure drafts at this time.
There are no Exposure Drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The following document is being exposed for a 30-day public comment period ending Thursday, May 9th, 2024:
Additionally, commenters are asked to consider whether more expedient changes to only the mortality and expense assumptions would be desirable (potentially for the 2025 Valuation Manual) or if the entire package (including updated surrender assumptions) should be considered for adoption as it is ready.
Please send comments to Scott O'Neal by close of business on May 9th, 2024.
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.
The attached Amendment Proposal Form to modify Valuation Manual, section VM-26, Section 3.B. Contract Reserves for Credit Disability Insurance proposes to remove the 12% addition to the 1985 CIDA incidence rates for newly issued contracts, since the addition of the 12% constitutes a margin that is no longer needed or justified by experience.
- committees_a_latf_b_hatf_amend_proposal_form VM-26 Amendment Proposal.doc
- 2023 Credit Disability Study Report_final_clean_0.pdf
- Credit Disability Reserve Standards-Proposal-Redline.docx
Please provide comments to eking@naic.org by Friday, March 22.
The Working Group requests comments on the Minnesota Approach with any suggested adjustments as a candidate for a Single LTCI Multistate Rate Review Approach. The Minnesota Approach is described here: https://content.naic.org/sites/default/files/documents/ltci-msa-framework.pdf
Suggested adjustments should be related to the concepts contained in the attached link: Recommendation on a single MSA actuarial approach after regulator feedback Document.
Please provide comments to eking@naic.org by Friday, May 3.
_______________________________________________________
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?
Task Force Proposed Revised PBM Subgroup 2024 Charges (May 10, 2024)
Proposed Revisions to Model #171 (Tracked Version) (May 3, 2024)
Proposed Revisions to Model #171 (Clean Version) (May 3, 2024)
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
RFTF Proposed Revised PBM Subgroup 2024 Charges (Draft May 10, 2024)
There are no exposure drafts at this time.
There are no exposure drafts at this time.
FINAL DRAFT VERSION OF DISCLOSURE NOTICE EXPOSED_0.pdf
The Working Group's proposed Disclosure Notice of Premium Increase Guidance documents are exposed for comment until Feb. 1, 2024. Please send comments to NAIC staff person Sara Robben at srobben@naic.org.
There are no exposure drafts at this time.
There are no Exposure Drafts at this time.
The following document is being exposed for a 30-day comment period ending May 31, 2024.
Please have comments submitted to Bree Wilson by close of business on Friday May 31, 2024.
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.
The Adjuster Licensing (D) Working Group has been given the task of reviewing the NAIC State Licensing Handbook, specifically Chapter 18 Adjuster Licensing.
The State Licensing Handbook was last updated and made available in 2021. The Producer Licensing Uniformity (D) Working Group has been given the charge to review the full handbook for any potential updates. To assist with this, the Adjuster Licensing (D) Working Group will review Chapter 18 and discuss necessary updates which will be presented to the Producer Licensing Uniformity (D) Working Group.
To complete this review, the Working Group is exposing Chapter 18 for review and soliciting suggestions/comments with a deadline of Wednesday, May 1, 2024. *Please submit all suggestions in red-lined format.
The Word and PDF version of Chapter 18 Adjuster Licensing can be found below.
The Working Group will hold open monthly Webex conference calls to review comments received and finalize potential revisions.
Monthly Calls Through July:
- Wednesday, May 15th (Call information included and calendar notice will be sent separately)
- Wednesday, June 12th (Notice will be sent separately)
- Wednesday, July 10th (Notice will be sent separately)
State Licensing Handbook: Chapter 18 Adjuster Licensing - WORD / PDF
Comments Received:
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 October 4, 2023 Draft (The Oct. 4, 2023 draft contains changes from the previous version, dated June 6, 2023. The October 4, 2023 updates in the draft are highlighted in green, they occur on pages 14, 17, 29, 31, 32, 33, 38, 40, 45, 52, 55 and 56.)
NOTE: The Oct. 4, 2023 draft Chapter 23 was adopted by the Working Group at its Nov. 8, 2023 Webex meeting, the chapter underwent additional revisions during that meeting, as part of that adoption.
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.)
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 (Revised October 2023 by the Travel Insurance regulator-only SMEs, taking the comments received from Virginia Oct. 28, 2022, Missouri Sept. 16, 2022 and the CEJ Sept. 16, 2022 into consideration)
- Revised Travel In Force SDR, October 25, 2023 Draft Redline
- Revised Travel In Force SDR, October 25, 2023 Draft Redline Accepted
- Revised Travel Claims SDR, October 25, 2023 Draft Redline
- Revised Travel Claims SDR, October 25, 2023 Draft Redline Accepted
NOTE: The Oct. 25, 2023 new draft Travel Insurance In-Force SDR and the Oct. 25, 2023 new Travel Insurance Claims SDR were adopted by this Working Group at its Nov. 8, 2023 Webex Meeting
- 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))
NOTE: 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)
NOTE: 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)
NOTE: 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)
NOTE: 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)
NOTE: 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)
NOTE: 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
NOTE: 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.
NOTE: 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
NOTE: 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
NOTE: The Inland Marine In Force and Inland Marine Claims SDRs were adopted by the Working Group on its July 23, 2020 call.
NOTE: 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
NOTE: 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 Scorecard Ratios v1.9 2/21/2024
Charge to Assess Currently Available Market Analysis Data
- Market Analysis Data Sources 6/23/2023
Draft FAQ's for Accelerated Underwriting
- Draft FAQ's - Updated 05/07/24
- Draft Definitions
MCAS Proposals
MCAS Other Health
MCAS Short-Term, Limited Duration
MCAS Homeowners and Private Passenger Auto
MCAS Life
MCAS Life and Annuity
Market Regulation Certification Program v2.44 clean 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 (8.14.23).
The Task Force opened the adopted draft (8.14.23) for comment through Monday, October 16, 2023.
The Task Force met by conference call on October 20th to review comments received on draft amendments for the Unfair Trade Practices Act (Model #880).
During the conference call the Task Force agreed to accept additional revisions from the comments received. The additional revisions have been applied to Draft #6 (10.20.23).
The Draft #6 (10.20.23) was open for comment until Friday, November 10, 2023.
The Task Force will review the updated draft (10.20.23) for potential adoption.
Draft #6 (10.20.23):
Comments Received on Draft #6 (10.20.23):
-----------------------------------------------------------------
Draft #5 (8.14.23):
Comments Received on Draft #5 (8.14.23):
- Missouri DOI Comments
- Missouri DOI Comments (within Model)
- Virginia DOI Comments
- Coalition Against Insurance Fraud and NAIC Consumer Representatives Comments
- Coalition Against Insurance Fraud and NAIC Consumer Representatives Comment Letter
---------------------------
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.
NAIC UNIFORM APPLICATION REVIEW (2024)
In 2018 the Working Group reviewed and adopted revisions to the uniform applications (Individual and Business Entity). These revisions were not fully adopted by the NAIC Membership. This year direction has been given to the Working Group to review the current revisions, finalize necessary changes and adopt. Once adopted they will be presented to the Producer Licensing (D) Task Force.
To assist with the review a check list has been created with all revisions adopted during the 2018 review. The checklist has 2 parts - "Initial" and "Renewal".
Please review the 2018 Uniform Application for Individual License Revisions Checklist document and provide your responses to either “accept” or “reject”.
The deadline for review is Friday, April 26, 2024. Please submit your responses to Gwelker@naic.org
UNIFORM APPLICATION MATERIALS
2018 NAIC Uniform Application for Individual License Revisions Checklist - Excel (Deadline 4.26.24)
2018 NAIC Uniform Applications
- Individual Initial Application w/Track Changes - Word / PDF
- Individual Renewal Application w/Track Changes - Word / PDF
- Business Entity Initial Application w/Track Changes - Word / PDF
- Business Entity Renewal Application w/Track Changes - Word / PDF
2018 NAIC Uniform Application Comments
- Individual Initial Application Comments
- Individual Renewal Application Comments
- Business Entity Initial Application Comments
- Business Entity Renewal Application Comments
Working Group Minutes (2018)
- 12.19.17 Minutes
- 3.15.18 Minutes
- 4.11.18 Minutes
- 5.2.18 Minutes
- 5.9.18 Minutes
- 6.6.18 Minutes
- 6.13.18 Minutes
- 7.10.18 Minutes
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
- 2020 Pass Rates
- 2022 Pass Rates
- 2023 Pass Rates
Exposure Drafts Still Open For Consideration with Comments Received:
Investment Framework
The following document is being exposed for a 30-Day public comment period ending on November 6th, 2023
Please submit comments to Sherry Flippo by EOD on November 6th. 2023
The Working Group has exposed the following for public comment. Please submit comments to Dave Fleming by COB May 15, 2024.
The Working Group has exposed the following for public comment. Please submit comments to Dave Fleming by COB April 8, 2024.
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.
There are no exposure drafts at this time.
The Group Capital Calculation (E) Working Group is exposing the following documents, please submit comments to Dan Daveline by COB, Wednesday, February 21, 2024.
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 National Treatment and Coordination (E) Working Group has exposed the following document with a public comment period ending April 1, 2024. Comments should be directed to NAIC staff, Jane Barr.
Comments on exposed items should be addressed to Director Elizabeth Kelleher Dwyer and Commissioner Glen Mulready, Co-Chairs of the Restructuring Mechanisms (E) Working Group, and directed to NAIC staff, Robin Marcotte and Dan Daveline.
The following documents have been exposed with a public comment period ending Friday, June 14, 2024.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
Blanks (E) Working Group
Items Received for Comment
Last Updated April 1, 2024
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 |
2023-12BWG Modified | Categorize debt securities on Schedule BA that do not qualify as bonds under SSAP No. 26R—Bonds or SSAP No. 43R—Loan-Backed and Structured Securities and are captured in the scope of SSAP No. 21R—Other Admitted Assets. (SAPWG Ref #2023-16) | 4/23/2024 |
2024-01BWG | Update the Investment Schedules General Instructions to identify that common and preferred stock residual interests should be reported on Schedule BA. (SAPWG Ref #2023-23). | 4/23/2024 |
2024-02BWG | Remove categories from Schedule DA, Part 1, and Schedule E, Part 2, that should be reported on Schedule BA. Add clarifying instructions on what should be included in Other Short-Term and Other Cash Equivalent categories. | 4/23/2024 |
2024-03BWG | Update General Interrogatory 35 for private letter rating security reporting to clarify what should be included. | 4/23/2024 |
2024-04BWG | Add clarifying language to the VM-20, Requirements for Principle-Based Reserves for Life Products, supplement in the life blank to include separate accounts where applicable. | 4/23/2024 |
2024-05BWG | Add clarifying language to Annual General Interrogatory 29.05 (Quarterly General Interrogatory 17.5) to clarify that all investment advisors with discretion to make investment decisions, including sub-advisors, should be disclosed through the interrogatory. | 4/23/2024 |
2024-06BWG | P/C changes: Limit the requirement to send qualification documentation to the board of directors only at the initial appointment and not annually thereafter. Title changes: Update the title instructions so they are more similar to the P/C instructions. | 4/23/2024 |
2024-07BWG | Update the illustration under Note 5S(A) – Investments for Net Negative (Disallowed) Interest Maintenance Reserve (IMR) to add separate account breakout. Add a new general interrogatory for a company attestation for separate accounts. (This goes with adopted Blanks (E) Working Group proposal 2023-13BWG). | 4/23/2024 |
2024-08BWG | Update the Interest Maintenance Reserve and Asset Valuation Reserve instructions for specific allocation guidance for NAIC Designation Changes for Debt Securities (excluding LBSS), Mortgage Loans, and perpetual preferred stocks. (SAPWG Ref #2023-15 and Ref #2023-29). | 4/23/2024 |
2024-09BWG | Add a note (5T) to the Notes to Financials to be data captured to report the aggregate collateral loans by qualifying investment collateral. | 4/23/2024 |
2024-10BWG | Remove the ACA SSAP No. 107 disclosure on the transitional reinsurance program and the risk corridors program from Note 24E in the Notes to Financials (Note 24F for Property/Casualty) in the Annual Statement Instructions. | 4/23/2024 |
2024-11BWG | Update the annual and quarterly instructions and blanks for the New Market Tax Credit changes. Changes will be made to: Annual – Assets, Notes to Financial Statements 5K, 14A, and 21E, AVR, and Schedule BA, Part 1, 3, and Verification Between Years. Quarterly changes – Assets and Schedule BA, Part 3 and Verification Between Years. | 4/23/2024 |
Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated March 16, 2024
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. (updated March 16, 2024)
EXPOSURES with PUBLIC COMMENT PERIOD ending APRIL 19, 2024 | ||||
---|---|---|---|---|
2023-16 | Schedule BA | Schedule BA Reporting | Exposure summarizes key revisions in the SAPWG-sponsored modified blanks proposal 2023-12BWG. | |
2023-28 | SSAP No. 21R | Collateral Loan Reporting | Exposure details proposed collateral loan reporting lines for Schedule BA and requests comments on whether certain collateral loans backed by certain types of collateral should flow through AVR for RBC impact. | |
2024-13 | SSAP No. 107 | Update SSAP No. 107 Disclosures | Revisions to SSAP No. 107 remove the transitional reinsurance program disclosures and the risk corridor disclosures as both programs have expired. In addition, the rollforward illustration in Exhibit B is also proposed to be updated to remove the portion for the transitional reinsurance program and the risk corridors program. | |
EXPOSURES with PUBLIC COMMENT PERIOD ending MAY 31, 2024 | ||||
INT 03-02 SSAP No. 25 SSAP No. 63 |
Review of INT 03-02 |
Revisions nullify INT 03-02 and update SSAP No. 63 and SSAP No. 25 to address transfers of assets when modifying intercompany pooling agreements. | ||
2023-26 |
SSAP No. 15 SSAP No. 103R |
ASU 2023-06, Disclosure Improvements | Revisions adopt, with modification, certain disclosures from ASU 2023-06 on unused commitments and lines of credit and disclosures for securities lending, repurchase agreements (repos), and reverse repos. | |
2024-01 | SSAP No. 26R | Bond Definition - Debt Securities Issued by Funds | Re-exposed revisions clarify the guidance for debt securities issued by funds with a specific request for regulator and industry comments on the proposed language that assists with clarifying the scope of guidance and to the types of debt securities issued by funds that should be considered as operating entities, and the proposed language to better define the extent of debt that may be issued to fund operations. | |
2024-02 |
SSAP No. 19 SSAP No. 73 |
ASU 2023-01, Leases (Topic 842), Common Control Arrangements | Revisions adopt, with modification, the leasehold improvement guidance from ASU 2023-01 into SSAP No. 19 and SSAP No. 73. | |
2024-03 |
INT 21-01 SSAP No. 20 |
ASU 2023-08, Accounting for and Disclosure of Crypto Assets | Revisions adopt with modification the definition of crypto assets from ASU 2023-08 into SSAP No. 20 and clarify that directly held crypto assets are nonadmitted assets for statutory accounting. INT 21-01, Accounting for Cryptocurrencies would be nullified upon the adoption of this agenda item. | |
2024-04 | SSAP No. 103R | Conforming Repurchase Agreements | Exposed agenda item details initial statutory differences between securities lending and repurchase agreements as well as other items that should be reviewed for potential clarification on the “conforming agreement” securities lending concept currently captured in the general interrogatories. | |
2024-05 | Appendix A-791 | A-791, Paragraph 2.c. | Revisions remove the first sentence of the Appendix A-791 Life and Health Reinsurance Agreements (A-791), paragraph 2.c. Question and Answer. | |
2024-06 | SSAP No. 61R | Risk Transfer Analysis on Combination Reinsurance Contracts | Revisions to SSAP No. 61R incorporate guidance from SSAP No. 62R, Exhibit A, Implementation Questions and Answers, question 10, which requires risk transfer to be evaluated in aggregate for contracts with interrelated contract features such as experience rating refunds. Additionally, a reference is added to A-791, paragraph 6, regarding the entirety of the contract. | |
2024-07 | Annual Statement | Reporting of Funds Withheld and Modco Assets | Exposed project proposes to add a new part to the Schedule S in the Life/Fraternal, and Health annual statement blanks and Schedule F in the Property/Casualty (P/C) and Title annual statement blanks, which is similar in structure to Schedule DL and would require disclosure of all assets held under a funds withheld arrangement and would include a separate signifier for modco assets. | |
2024-08 |
SSAP No. 21R SSAP No. 26R SSAP No. 30R SSAP No. 32R SSAP No. 43R SSAP No. 48 |
Consistency Revisions for Residuals | Revisions incorporate clarifying edits for residuals so that all applicable SSAPs refer to SSAP No. 21R for the formal definition and accounting and reporting guidance. | |
2024-09 | SSAP No. 2R | SSAP No. 2R - Clarification | Revisions eliminate lingering references in SSAP No. 2R that imply that asset-backed securities, mortgage loans, or other Schedule BA items are permitted to be reported as cash equivalents or short-term investments. | |
2024-10 | SSAP No. 56 | SSAP No. 56 - Book Value Separate Accounts | Agenda item directs NAIC staff to work with industry in determining current applications and differences in interpretations for the reporting of book value assets and to propose revisions to incorporate a consistent statutory accounting approach. | |
2024-11 | SSAP No. 101 | ASU 2023-09, Improvements to Income Tax Disclosures | Revisions adopt, with modification, certain disclosures from ASU 2023-09 and removes SSAP No. 101 disclosure, paragraph 23.b. | |
2024-12 |
SSAP No. 27 Annual Statement |
Updates to SSAP No. 27 | Revisions to SSAP No. 27 remove reference to FAS 105 and specifically note the financial instruments excluded from the scope of the SSAP. Revisions also update annual statement Note 16 to provide additional disclosures and instructions for derivatives and non-derivative financial instruments. | |
2024-14EP | Various SSAPs | Accounting Practices and Procedures Manual Editorial | Editorial revisions remove the “Revised” and “R,” previously intended to identify a substantively revised SSAP, from SSAP titles and SSAP references within the Manual. | |
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. | ||
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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2023-31 | SSAP No. 58 | Updates from Model 630 Mortgage Guaranty Insurance | Exposed intent to review the revisions to the Mortgage Guaranty Insurance Model Act (#630) for incorporation into SSAP No. 58—Mortgage Guaranty Insurance and Appendix A-630 as applicable. The exposure requests input on an effective date. |
The Capital Adequacy (E) Task Force is exposing the following for a 30-day public comment period ending May 30, 2024, please submit comments to Eva Yeung.
- 2024-09-CA Underwriting Risk Investment Income Adjustment Factors for Comprehensive Medical, Medicare Supplement, and Dental and Vision
- 2024-13-CA Routine Three-Year Update to the Receivable for Securities
- 2024-16-CA Provide Edits to the RBC Preamble
- Referral from the Statutory Accounting Principles (E) Working Group Regarding the Investment in Tax Credit Structures
The following documents are being exposed by the Working Group. Please submit comments to Maggie Chang by COB May 16, 2024.
Exposure of the BA Mortgage Proposal
Comments should be sent electronically to Dave Fleming by COB Tuesday, May 28, 2024
The Life Risk-Based Capital (E) Working Group agreed to expose the following item for a 30-day public comment period:
Comments should be sent electronically to Dave Fleming by COB Wednesday, May 22, 2024.
Exposure of the RBC Repurchase Agreement Proposal
Comments should be sent electronically to Dave Fleming by COB Monday, April 15, 2024
Exposure of the Other Long-Term Assets Proposal
Comments should be sent electronically to Dave Fleming by COB Monday, February 26, 2024
Exposure of the RBC Repurchase Agreement, TAC, and BA Mortgage Proposals
Comments should be sent electronically to Dave Fleming by COB Monday, February 26, 2024
Exposure of the Implementation of 2023 Mortality Risk Changes Memorandum
Comments should be sent electronically to Dave Fleming by COB Friday, December 29, 2023
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.
The Property and Casualty Risk-Based Capital (E) Working Group is exposing the following proposals for a 30-day public comment period ending April 16, 2024, please submit comments to Eva Yeung.
The Catastrophe Risk (E) Subgroup re-exposing the following proposal for a 22-day public comment period ending April 8, 2024, please submit comments to Eva Yeung.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no Exposure Drafts at this time.
There are no exposure drafts at this time.
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. The comment deadline for this exposure has been extended to Tuesday, Nov. 7.
On October 27, the Task Force exposed proposed draft revisons to the Uniform Checklist for Reciprocal Jurisdiction Reinsurers for a 15-day public comment period ending on November 10.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The following documents are being exposed for 30-day public comment period.
- P&P Manual Amendment to Permit NAIC Designations for Short-term ABS
- P&P Manual Amendment to add Spain to the list of jurisdictions eligible for counterparty exposure netting
- P&P Manual Amendment to Change the Effective Date for the Financial Modeling of CLOs by SSG to 2025
- P&P Manual Amendment to Clarify that an NAIC Designation 6* can be Self-assigned
- P&P Manual Amendment to Make Current the List of SVO Processes
Comments should be sent electronically to Charles Therriault and Denise Genao by June 2, 2024.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The following document is being exposed for a 30-day public comment period ending Thursday, May 9th, 2024:
Additionally, commenters are asked to consider whether more expedient changes to only the mortality and expense assumptions would be desirable (potentially for the 2025 Valuation Manual) or if the entire package (including updated surrender assumptions) should be considered for adoption as it is ready.
Please send comments to Scott O'Neal by close of business on May 9th, 2024.
Revisions to the Property and Casualty Insurance Guaranty Association Model Act (#540)
Revisions preserve guaranty fund coverage for policyholders subject to restructuring mechanisms and that clarify guaranty fund coverage of cyber security insurance. The recommendation for accreditation is that the changes are acceptable, but not required for accreditation. Comments due by Friday, April 19, 2024, to Bailey Henning (bhenning@naic.org)
F Cmte Exposure - RITF Memo to F Committee
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 Working Group is exposing the draft E-Commerce Modernization Guide until March 14, 2024.
Please submit comments to Olivea Myers by COB March 14, 2024.
There are no exposure drafts at this time.
The attached work plan for the Third-Party Data and Models (H) Task Force is exposed for a 30-day public comment period ending Monday, May 6, 2024. Comments should be emailed to kdefrain@naic.org by close of business on May 6, 2024.
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
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