Statement Modifications Effective as of the 2025 Notes

(Schedule-related modifications are recorded separately in Gain’s Resource Library).

Reference

Line of Business

Impacted Notes

Description

Life/Fraternal, Property, Health, Title

Note 5: Investments
Note 14: Liabilities, Contingencies and Assessments
Note 21: Other Items

 

 

Updated: This item is associated with the SAPWG changes to SSAP No. 93 – Investments in Tax Credit Structures and SSAP No. 94 -State and Federal Tax Credits in Ref #2022-14 related to the Tax Credits Project. The Note 5.K and Note 21.E disclosures have been significantly modified when compared to the 2024 Annual Statement and there are several new disclosure requirements.

Effective Q1 2025

References: 2024-11BWG Modified, AP&P Ref #2022-14, SSAP No. 93, SSAP No. 94

Life/Fraternal, Property, Health, Title

Note 1: Summary of Significant Accounting Policies
Note 5: Investments
Note 20: Fair Value Measurements

Updated: This item modifies the instructions and illustrations for several of the quarterly required and annual notes. In Notes 1.C(6), 5.D and 5.F through 5.I, references to Loan-Backed Securities have been changed to Asset-Backed Securities to conform with the Principle-Based Bond Definition adoption. Notes 20.A, 20.C and 20.D were modified to reflect the new split of bonds into Issuer Credit Obligations and Asset-Backed Securities.

Effective Q1 2025

References: 2024-12BWG Modified

Life/Fraternal, Property, Health, Title

Note 5: Investments

 

Updated: This item modifies the instructions and illustrations for Note 5.L – Restricted Assets to clarify how assets held under modified coinsurance (Modco) or funds withheld (FWH) agreements should be reflected within the restricted asset disclosure. The updated disclosure has been enhanced to fully identify the extent of restricted assets reported on the balance sheet within a single disclosure and a new disclosure has been added to identify differences between the “restricted asset” disclosure and the amounts reported in the general interrogatories, which are pulled directly into the RBC formula. The changes coincide with modifications to SSAP No. 1 – Accounting Policies, Risks and Uncertainties, and Other Disclosures adopted by the SAPWG in Ref #2024-20.

Effective Annual 2025

References: 2025-06BWG Modified, AP&P Ref #2024-20, SSAP No. 1

Life/Fraternal, Property, Health, Title

Note 5: Investments

Updated: This item modifies the instructions and illustrations for Note 5.L – Restricted Assets to identify assets held under funds withheld agreements (including Modco) that are affiliated with the reinsurer. It also updates the list of required quarterly disclosures to include Note 5.L. With this change, this disclosure will be required in all interim and annual financial statements. See SAPWG Ref #2025-05 for additional information.

Effective Annual 2025

References: 2025-10BWG Modified, AP&P Ref #2025-05

Life/Fraternal, Property, Health, Title

Note 7: Investment Income

 

Updated: The instructions for Note 7.C were updated to indicate only interest income due and accrued amounts on a gross, nonadmitted and admitted basis should be included in the disclosure. With this change, values will no lnger pull from Line 14 of the Assets page.

Effective Annual 2025

References: NAIC Editorial Revisions

Life/Fraternal, Property, Health, Title

Note 8: Derivatives
Note 11: Debt

Updated: This item modifies the instructions for Note 8 – Derivatives to include adopted revisions to SSAP No. 86 – Derivatives, adding a new disclosure, Note 8.A(7), requiring the reporting entity to disclose its accounting policy for where cash flows associated with derivative instruments and their related gains and losses are presented in the statement of cash flows and renumbering the remaining disclosures within Note 8.A. The instructions and illustrations for Note 11 – Debt were modified to coincide with the adopted revisions to SSAP No. 15 – Debt and Holding Company Obligations. Note 11.C will be a new data captured disclosure for “unused commitments and lines of credit for financing arrangements”. This item is associated with the SAPWG Ref #2023-26.

Effective Annual 2025

References: 2025-01BWG Modified, AP&P Ref #2023-26, SSAP No. 86, SSAP No. 15

Life/Fraternal, Property, Health, Title

Note 8: Derivatives

 

Updated: This item updates the annual and quarterly instructions for Note 8 – Derivatives and Schedule DB to clarify the terminology used for derivative financing premiums. It coincides with SAPWG Ref #2024-23.

Effective Annual 2025

References: 2025-15BWG Modified, AP&P Ref #2024-23

Life/Fraternal, Property, Health, Title

Note 9: Income Taxes

Updated: This item modifies the instructions for Note 9 to include adopted revisions to SSAP No. 101 – Income Taxes. Specifically, Note 9.B(2) – cumulative amount of each type of temporary difference, has been removed from the disclosure requirements and all other disclosures within Note 9.B have been renumbered. This item is associated with SAPWG Ref #2024-11.

Effective Annual 2025

References: 2025-02BWG, AP&P Ref #2024-11, SSAP No. 101

Life/Fraternal, Property, Health, Title

Note 11: Debt

 

Updated: The illustrations for Note 11.B(3)A and 11.B(3)B have been updated to remove the crosschecks for Column 1 – Fair Value and Column 3 – Aggregate Borrowing since the maximum collateral crosscheck will only work for Column 2 – Carrying Value.

Effective Annual 2025

References: NAIC Editorial Revisions

Life/Fraternal, Property, Health, Title

Note 13: Capital and Surplus, Dividend Restrictions and Quasi-Reorganizations

Updated: This item updates Note 13K – Surplus Notes to add clarifying guidance for reporting certain debt securities as capital notes in scope of SSAP No. 41 – Surplus Notes. See SAWPG Ref #2024-28 for further discussion.

Effective Annual 2025

References: 2025-13BWG Modified, AP&P Ref #2024-28, SSAP No. 41

Life/Fraternal

Note 21.J – Reporting Net Negative (Disallowed) Interest Maintenance Reserve (IMR)

 

New: The SAPWG adopted revisions to INT 23-01 through AP&P Ref #2022-19 at the 2025 Summer National Meeting. The revisions extend the effective date of the INT to December 31, 2026 and add additional requirements and clarifications to the guidance within the INT.

Effective Annual 2025

References: INT 23-01, AP&P Ref #2022-19

Life/Fraternal, Property, Health, Title

Note 28: Health Care Receivables

Updated: This item modifies Note 28 – Health Care Receivables to include a new part C for Medicare Part D Prescription Payment Plan Receivables. INT 24-02T includes accounting guidance and the new data-captured disclosures were approved through a separate agenda item, AP&P Ref #2025-08.

Effective Annual 2025

References: 2025-04BWG Modified, AP&P Ref #2025-08, INT 24-02T

Life/Fraternal

Note 35: Separate Accounts

 

Updated: This item updates the Life/Fraternal Note 35 for separate account transfers and adds a new general interrogatory (#6.8) to the Separate Account blank for transfers and repurchase agreements and reverse repurchase transactions. It coincides with SAPWG Ref #2024-10.

Effective Annual 2025

References: 2025-09BWG, AP&P Ref #2024-10

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

SAPWG Modifications: https://content.naic.org/sites/default/files/inline-files/14%20Adoptions%20posted%2011.17.2024_0.pdf

Exposures:

SAPWG Exposures: https://content.naic.org/committees/e/statutory-accounting-principles-wg

BWG Exposures: https://content.naic.org/committees/e/blanks-wg

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