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Statement Modifications Effective as of the 2020 Notes

(Schedule modifications are recorded separately in Gain’s resource library)

Reference

Line of Business

Impacted Notes

Description

Life/Fraternal

 

Note 2:

Accounting Changes and Corrections of Errors

Updated: This modification updates the instructions for Note 2 – Accounting Changes and Corrections of Errors, to reflect the disclosure modifications made to SSAP No. 3 – Accounting Changes and Corrections of Errors and SSAP No. 51R – Life Contracts related to the SAPWG adoption of AP&P Ref #2019-47.

Effective Annual 2020

References: SSAP No. 3; SSAP No. 51R; AP&P Ref #2019-47; 2020-05BWG Modified

Life/Fraternal, Property, Health, Title

Notes 8, 8.A:

Derivative Instruments

Updated: This adoption modifies both the quarterly instructions and illustration for Note 8 – Derivatives for disclosures adopted by SSAP No. 108 – Derivative Hedging Variable Annuity Guarantees. In addition, the adoption adds Quarterly Schedule DB, Part E and related instructions to the quarterly statement. The quarterly version of the schedules and Notes disclosures were inadvertently omitted from 2019-14BWG adopted on June 24, 2019. To meet the requirements of SSAP No. 108, this adoption is effective beginning in the first quarter of 2020 for Life/Fraternal, Property, Health, and Title companies. Lastly, this does add Notes 8B(2)a, 8B(2)b, and 8B(2)c to the list of required quarterly disclosures. Note 8.A(8), previously Note 8.H, remains required as well.

Effective 1st Quarter 2020

References: SSAP No. 86 – Derivatives; SSAP No. 108 – Derivatives Hedging Variable Annuity Guarantees; AP&P Ref #2016-03; 2019-23BWG Modified

Life/Fraternal, Property, Health, Title

Note 8.B:

Derivative Instruments

New: This adoption modifies both the quarterly instructions and illustration for Note 8 – Derivatives for disclosures adopted by SSAP No. 108 – Derivative Hedging Variable Annuity Guarantees. In addition, the adoption adds Quarterly Schedule DB, Part E and related instructions to the quarterly statement. The quarterly version of the schedules and Notes disclosures were inadvertently omitted from 2019-14BWG adopted on June 24, 2019.

To meet the requirements of SSAP No. 108, this adoption is effective beginning in the first quarter of 2020 for Life/Fraternal, Property, Health, and Title companies. Lastly, this does add Notes 8B(2)a, 8B(2)b, and 8B(2)c to the list of required quarterly disclosures. Note 8.A(8), previously Note 8.H, remains required as well.

Effective 1st Quarter 2020

References: SSAP No. 86 – Derivatives; SSAP No. 108 – Derivatives Hedging Variable Annuity Guarantees; AP&P Ref #2016-03; 2019-23BWG Modified

Life/Fraternal, Property, Health, Title

Note 10.C:

Transactions with Related Parties Who Are Note Reported on Schedule Y

New: This adoption adds a disclosure instruction for Note 10.C – Transactions with Related Parties Not Reported on Schedule Y and combines the existing Note 10.C into the10.B instructions and illustration narrative. This coincides with the disclosure addition to SSAP No. 25 – Affiliates and Other Related Parties that was made related to the SAPWG adoption of AP&P Ref #2019-33 on March 18, 2020.

AP&P Ref #2019-33 was adopted to data-capture disclosures from SSAP No. 25 – Affiliates and Other Related Parties in the annual statement blanks that are currently completed in a narrative (PDF) format. The revisions allow regulators to better aggregate and query related party relationships to the list of required quarterly disclosures. Note 8A(8), previously Note 8.H, remains required as well.

Effective Annual 2020

References: SSAP No. 25; AP&P Ref #2019-33; 2020-08BWG Modified

AP&P Ref #2019-32

Life/Fraternal, Property, Health, Title

Note 10.L

Downstream Holding Company Value Using Look-Through Method

Updated: This adoption revises SSAP No. 97 – Investments in Subsidiary, Controlled and Affiliated Entities and emphasizes existing guidance stating that a look-through is permitted through more than one downstream holding company as long as each look-through entity complies with the requirements as directed in SSAP No. 97.

In accordance with this adoption, a concurrent BWG exposure, 2020-02BWG, was adopted on March 26, 2020, as effective for the 2020 Annual Statement.

Effective 1st Quarter 2020

References: SSAP No. 97; AP&P Ref #2019-32; 2020-02BWG

AP&P Ref #2018-26

Life/Fraternal, Property, Health, Title

Note 10.O:

SCA and SSAP No. 48 Entity Loss Tracking

Updated: This adoption revises SSAP No. 97 – Investments in Subsidiary, Controlled and Affiliated Entities to update the previous requirements for when a reporting entity has a negative equity value in a SCA investment and has provided a financial guarantee or commitment.

Going forward, the financial guarantee or commitment will be recognized under SSAP No. 5R – Liabilities, Contingencies and Impairments of Assets and the equity losses of the SCA will be floored at zero (thus not reported as a negative value).

Effective 1st Quarter 2020

References: SSAP No. 97; SSAP No. 5R; AP&P Ref #2018-26

Life/Fraternal, Property, Health, Title

Note 13

Capital and Surplus, Dividend Restrictions and Quasi-Reorganizations

Updated: This item modifies the instructions and illustration for Note 13(11) – Surplus Notes, to reflect the disclosure addition for SSAP No. 41R – Surplus Notes being adopted by SAPWG via AP&P Ref #2019-37.

This modification also changes the numbering of Note 13 – Capital and Surplus, Dividend Restrictions and Quasi-Reorganizations to A through M rather than 1 through 13.

Effective 1st Quarter 2020

References: SSAP No. 41R; AP&P Ref #2019-37; 2020-03BWG Modified

Life/Fraternal, Property, Health, Title

Note 21.A

Unusual or Infrequent Items

Updated: On June 15, 2020, the SAPWG adopted Ref #INT 20-08T: COVID-19 Premium Refunds, Rate Reductions and Policyholder Dividends. Paragraphs 20-22 of this interpretation state the following: ‘To allow for aggregate, consistent assessment, the Working Group came to a consensus that all COVID-19 inspired premium refunds, rate reductions, and policyholder dividends shall be disclosed as unusual or infrequent items in Annual Statement Note 21.A. This disclosure is in addition to other existing disclosures on various items related to the policyholder payments’.

SSAP No. 24 – Discontinued Operations and Unusual or Infrequent Items requires disclosure of the nature and financial effects of each unusual or infrequent event or transaction. Gains or losses of a similar nature that are not individually material shall be aggregated. This disclosure shall include the line items which have been affected by the event or transaction considered to be unusual and/or infrequent. This disclosure is currently required to be reported in annual statement Note 21.A.

This INT will expire on January 1, 2021.

Effective June 15, 2020

References: SSAP No. 24; AP&P Ref #INT 20-08T

Life/Fraternal, Property, Health

Note 23

Reinsurance

Updated: This adoption includes the addition of a new disclosure for Note 23 – Reinsurance for Reinsurance Credit (23.H – Life/Fraternal, 23.E – Health, 23.K – Property) to reflect the disclosure additions to SSAP No. 61R – Life, Deposit-Type Contracts and Accident and Health Contracts Reinsurance related to the SAPWG adoption of AP&P Ref #2017-28 on December 7, 2019.

Effective Annual 2020

References: SSAP No. 61R; AP&P Ref #2017-28; 2020-07BWG

Property, Title

Note 23.A

Reinsurance

Updated: This adoption modifies the instructions for Note 23.A – Unsecured Reinsurance Recoverables on the Property blank to reflect the disclosure addition adopted by the SAPWG, AP&P Ref #2019-48, which modified SSAP No. 62R – Property and Casualty Reinsurance.

Effective Annual 2020

References: SSAP No. 62R; AP&P Ref #2019-48; 2020-04BWG

Property

Note 23.F(1)f

Retroactive Reinsurance

Updated: This modification adds a category and instructions for Reciprocal Jurisdiction Companies in Schedule S for the Life/Fraternal and Health blanks and to Schedule F for the Property and Title blanks. A list of identification numbers will be added to the instructions for Schedule Y, Part 1A, Schedule Y, Part 2 and Schedule D, Part 6, Section 1 for Reciprocal Jurisdiction Companies. A reference to Reciprocal Jurisdiction Companies will be added in the Trusteed Surplus Statement instructions for Life/Fraternal, Health and Property statements.

Lastly, this adoption adds a section to the illustrations for Reciprocal Jurisdiction Companies for Note 23.F(1)f.

Effective Annual 2020

References: SSAP No. 62R; AP&P Ref #2019-48; 2019-30BWG Modified

Life/Fraternal

Note 33

Analysis of Life Actuarial Reserves by Withdrawal Characteristics

Updated: The purpose of this adoption is to data capture individually Separate Account with Guarantees products and Separate Account Nonguaranteed products.

Effective Annual 2020

References: 2019-21BWG

For a comprehensive list of modifications and exposures, see the following resources:

Modifications:

SAPWG Modifications: See the Accounting Practices and Procedures Manual Update page (this requires a subscription and login to the NAIC AP&P Manual Updates).

BWG Modifications: https://naic-cms.org/cmte_e_app_blanks_related_adopted_mods.htm

NAIC Maintenance Agenda: https://www.naic.org/documents/committees_e_app_sapwg_Maintenance_Agenda.xlsx

Exposures:

SAPWG Exposures: https://www.naic.org/exposure_drafts.htm?cmte_e_app_sapwg.htm

BWG Exposures: https://www.naic.org/exposure_drafts.htm?cmte_e_app_blanks.htm

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