2025 Quarterly Reporting Item – Principles-Based Bond Project

Summary 

There are significant changes coming for 2025 Quarterly reporting due to the NAIC Statutory Accounting Principles (E) Working Group’s (SAPWG) “Principles-Based Bond Project” (Bond Project) and corresponding Blanks (E) Working Group (BWG) adoptions. While the original goal of the Bond Project was to establish principle concepts for determining whether a debt security qualifies for reporting as a bond under SSAP No. 26R – Bonds or SSAP No. 43R – Asset-Backed Securities (previously known as Loan-Backed and Structured Securities), revisions have also been made to various other SSAPs to update guidance and references to the bond guidance. All of the revisions discussed in this document have a January 1, 2025 effective date.

Note: This post covers the detailed changes for Q1 2025 reporting. We anticipate completing a separate blog post early in 2025 detailing the impacts to the 2025 Annual and RBC Schedules with subsequent posts throughout 2025 as more information becomes available.

What does this mean?

Prior to Q1 2025 reporting, insurance entities will need to make their best effort to assess investments to determine whether they qualify within the bond definition for reporting on Schedule D-1.

  • Assessments are required to be at the time of acquisition (as of the origination date)
  • If historical assessment information is not available, reporting entities may utilize current or acquisition information to conclude whether or not that security qualifies for reporting as a bond as either an issuer obligation or asset-backed security
  • Issuer obligations follow SSAP No. 26R and should be reported on Schedule D, Part 1, Section 1 of the Annual Statement
  • Asset-backed securities that qualify as bonds under SSAP No. 26R should follow the accounting and reporting guidance in SSAP No. 43R and should be reported on Schedule D, Part 1, Section 2 of the Annual Statement
  • Debt securities that do not qualify as bonds under SSAP No. 26R should follow the reporting guidance in SSAP No. 21R – Other Admitted Assets and be reclassified to the appropriate schedule (for example, Schedule BA)

For additional information on the BWG adoptions, our initial thoughts on how Gain Compliance can help support a successful transition, and a detailed explanation of the changes to the schedules, please continue reading.

Relevant BWG Adoptions effective January 1, 2025

  • 2023-06BWG Modified – This is the main item adopted for all of the schedules that have detailed bond categories or reference the detailed bond schedules. See the attached BWG item or the “Details of the Changes” section below for additional information.
  • 2023-07BWG Modified – This item was adopted to make all of the investment schedules consistent with the changes to Schedule D. It renames the code column “Restricted Asset Code” and deletes the LEI column on the following schedules:
    • Schedule A
    • Schedule B
    • Schedule BA
    • Schedule D, Part 2
    • Schedule D, Part 6
    • Schedule E, Part 1
  • 2023-12BWG Modified – This item updates the Schedule BA categories per the Bond Project and clarifies/streamlines reporting on Schedule BA for those assets that are captured in the scope of SSAP No. 21R.
  • 2024-02BWG Modified – Removes categories from Schedule DA and Schedule E, Part 2 that should be reported on Schedule BA. Adds clarifying instructions on what should be included in the Other Short-Term and Other Cash Equivalent categories.
  • 2024-12BWG – Updates the quarterly investment schedules for editorial items to the Bond Project. This item was exposed on May 23, 2024 and will be discussed in the August 7, 2024 BWG meeting.

How is Gain Compliance planning to support our customers with this transition?

  • We will provide updated Excel workpapers for Schedule B, Schedule BA, Schedule D, Parts 3 and 4, and Schedule E, Parts 1 and 2.
  • We will add updated badges and right-hand panel content to the application, explaining the changes for each of the schedules impacted.
  • We will frequently communicate and share information – we can provide PDFs out of the application, links to the Quarterly Statement instructions and the new workpapers once they become available.
  • Note: the NAIC will not release the first set of blanks and instructions for the 2025 Quarterly statement until early October of 2024. The details of the changes shared below were developed through our review of the BWG adoptions and attendance at the BWG and SAPWG meetings throughout 2023 and 2024, as well as the IASA Exchange event earlier this year.
  • Important disclaimer: Depending on complexity, companies should be reviewing their investments and determining impact throughout 2024 in preparation for the changes to Q1 2025 reporting. Gain Compliance will not be able to assist with the assessment, classification and documentation of investments. 
  • If you have any questions around the areas Gain Compliance can help support you, please contact our Customer Support team by emailing support@gaincompliance.com

Helpful Resources

The information in this document is high level and meant to capture the more significant changes and transition dates of the Bond Project. Please refer to the additional resources below to gain an in-depth understanding of the impacts and regulator expectations.

  • SSAP No. 26R
    • Paragraphs 5 through 14 detail the Principles-Based Bond Definition
    • Paragraphs 43 through 47 discuss the effective date and transition
  • SSAP No. 43R
    • Paragraph 3 describes the omission of ABS from short-term or cash equivalent reporting
    • Paragraph 5 contains the Principles-Based Bond Definition for ABS
    • Paragraphs 47 through 52 discuss the effective date and transition
  • SSAP No. 21R
    • Paragraphs 20-27 contain guidance for debt securities that do not qualify as bonds
  • Ref #2019-21: NAIC Statutory Issue Paper 1XX – Principles-Based Bond Definition – Exposure Draft, May 15, 2024
    • Click on the link above and then on the Exposure Drafts tab on the SAPWG website

Details of the changes

  • Schedule D, Parts 3 and 4 – the line numbers and category descriptions will change to separate bonds into issuer credit obligations versus asset-backed securities and the columns will be modified to move the Foreign column to electronic only, delete the LEI column and move the Investments Involving Related Parties column:
Changes to Rows
2024Q2025Q
Line NumberCategoryLine NumberCategory
0109999999Bonds: U.S. Governments0019999999Issuer Credit Obligations: U.S. Government Obligations
0309999999Bonds: All Other Governments0029999999Issuer Credit Obligations: Other U.S. Government Obligations
0509999999Bonds: U.S. States, Territories and Possessions0039999999Issuer Credit Obligations: Non-U.S. Sovereign Jurisdiction Securities
0709999999Bonds: U.S. Political Subdivisions of States, Territories and Possessions0049999999Issuer Credit Obligations: Municipal Bonds – General Obligations (Direct and Guaranteed)
0909999999Bonds: U.S. Special Revenue and Special Assessment and all Non-Guaranteed Obligations of Agencies and Authorities of Governments and Their Political Subdivisions0059999999Issuer Credit Obligations: Municipal Bonds – Special Revenues
1109999999Bonds: Industrial and Miscellaneous (Unaffiliated)0069999999Issuer Credit Obligations: Project Finance Bonds Issued by Operating Entities (Unaffiliated)
1309999999Bonds: Hybrid Securities0079999999Issuer Credit Obligations: Project Finance Bonds Issued by Operating Entities (Affiliated)
1509999999Bonds: Parent, Subsidiaries and Affiliates0089999999Issuer Credit Obligations: Corporate Bonds (Unaffiliated)
1619999999Bonds: SVO Identified Funds0099999999Issuer Credit Obligations: Corporate Bonds (Affiliated)
1909999999Bonds: Unaffiliated Bank Loans0109999999Issuer Credit Obligations: Mandatory Convertible Bonds (Unaffiliated)
2019999999Bonds: Unaffiliated Certificates of Deposit0119999999Issuer Credit Obligations: Mandatory Convertible Bonds (Affiliated)
2509999997Subtotals – Bonds – Part 30129999999Issuer Credit Obligations: Single Entity Backed Obligations (Unaffiliated)
2509999998Summary Item from Part 5 for Bonds (N/A to Quarterly)0139999999Issuer Credit Obligations: Single Entity Backed Obligations (Affiliated)
2509999999Subtotals – Bonds0149999999Issuer Credit Obligations: SVO-Identified Bond Exchange Traded Funds – Fair Value
0159999999Issuer Credit Obligations: SVO-Identified Bond Exchange Traded Funds – Systematic Value
Source: NAIC 2024 Quarterly Statement Instructions0169999999Issuer Credit Obligations: Bonds Issued from SEC-Registered Business Development Corps, Closed End Funds & REITS (Unaffiliated)
0179999999Issuer Credit Obligations: Bonds Issued from SEC-Registered Business Development Corps, Closed End Funds & REITS (Affiliated)
0189999999Issuer Credit Obligations: Bank Loans – Issued (Unaffiliated)
0199999999Issuer Credit Obligations: Bank Loans – Issued (Affiliated)
0209999999Issuer Credit Obligations: Bank Loans – Acquired (Unaffiliated)
0219999999Issuer Credit Obligations: Bank Loans – Acquired (Affiliated)
0229999999Issuer Credit Obligations: Mortgage Loans that Qualify as SVO-Identified Credit Tenant Loans (Unaffiliated)
0239999999Issuer Credit Obligations: Mortgage Loans that Qualify as SVO-Identified Credit Tenant Loans (Affiliated)
0249999999Issuer Credit Obligations: Certificates of Deposit (Unaffiliated)
0259999999Issuer Credit Obligations: Certificates of Deposit (Affiliated)
0269999999Issuer Credit Obligations: Other Issuer Credit Obligations (Unaffiliated)
0279999999Issuer Credit Obligations: Other Issuer Credit Obligations (Affiliated)
0489999999Subtotal – Issuer Obligations (Unaffiliated) (Sum of Lines: 0019999999, 0029999999, 0039999999, 0049999999, 0059999999, 0069999999, 0089999999, 0109999999, 0129999999, 0149999999, 0159999999, 0169999999, 0189999999, 0209999999, 0229999999, 0249999999 and 0269999999)
0499999999Subtotal – Issuer Obligations (Affiliated) (Sum of Lines: 0079999999, 0099999999, 0119999999, 0139999999, 0179999999, 0199999999, 0219999999, 0239999999, 0259999999 and 0279999999)
0509999997Subtotals – Issuer Credit Obligations – Part 3
0509999998Summary Item from Part 5 for Issuer Credit Obligations (N/A to Quarterly)
0509999999Subtotals – Issuer Credit Obligations
1019999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Agency Residential Mortgage-Backed Securities – Guaranteed (Exempt from RBC)
1029999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Agency Commercial Mortgage-Backed Securities – Guaranteed (Exempt from RBC)
1039999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Agency Residential Mortgage-Backed Securities – Not/Partially Guaranteed (Not Exempt from RBC)
1049999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Agency Commercial Mortgage-Backed Securities – Not/Partially Guaranteed (Not Exempt from RBC)
1059999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Non-Agency Residential Mortgage-Backed Securities (Unaffiliated)
1069999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Non-Agency Residential Mortgage-Backed Securities (Affiliated)
1079999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Non-Agency Commercial Mortgage-Backed Securities (Unaffiliated)
1089999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Non-Agency Commercial Mortgage-Backed Securities (Affiliated)
1099999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Non-Agency – CLOs/CBOs/CDOs (Unaffiliated)
1109999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Non-Agency – CLOs/CBOs/CDOs (Affiliated)
1119999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Other Financial Asset-Backed Securities – Self-Liquidating (Unaffiliated)
1129999999Asset-Backed Securities: Financial Asset-Backed – Self-Liquidating, Other Financial Asset-Backed Securities – Self-Liquidating (Affiliated)
1319999999Asset-Backed Securities: Financial Asset-Backed – Not Self-Liquidating, Equity Backed Securities (Unaffiliated)
1329999999Asset-Backed Securities: Financial Asset-Backed – Not Self-Liquidating, Equity Backed Securities (Affiliated)
1339999999Asset-Backed Securities: Financial Asset-Backed – Not Self-Liquidating, Other Financial Asset-Backed Securities – Not Self-Liquidating (Unaffiliated)
1349999999Asset-Backed Securities: Financial Asset-Backed – Not Self-Liquidating, Other Financial Asset-Backed Securities – Not Self-Liquidating (Affiliated)
1519999999Asset-Backed Securities: Non-Financial Asset-Backed Securities – Practical Expedient, Lease-Backed Securities – Practical Expedient (Unaffiliated)
1529999999Asset-Backed Securities: Non-Financial Asset-Backed Securities – Practical Expedient, Lease-Backed Securities – Practical Expedient (Affiliated)
1539999999Asset-Backed Securities: Non-Financial Asset-Backed Securities – Practical Expedient, Other Financial Asset-Backed Securities – Practical Expedient (Unaffiliated)
1549999999Asset-Backed Securities: Non-Financial Asset-Backed Securities – Practical Expedient, Other Financial Asset-Backed Securities – Practical Expedient (Affiliated)
1719999999Asset-Backed Securities: Non-Financial Asset-Backed Securities – Full Analysis, Lease-Backed Securities – Full Analysis (Unaffiliated)
1729999999Asset-Backed Securities: Non-Financial Asset-Backed Securities – Full Analysis, Lease-Backed Securities – Full Analysis (Affiliated)
1739999999Asset-Backed Securities: Non-Financial Asset-Backed Securities – Full Analysis, Other Financial Asset-Backed Securities – Full Analysis (Unaffiliated)
1749999999Asset-Backed Securities: Non-Financial Asset-Backed Securities – Full Analysis, Other Financial Asset-Backed Securities – Full Analysis (Affiliated)
1889999999Subtotal – Asset-Backed Securities (Unaffiliated) (Sum of Lines: 1019999999, 1029999999, 1039999999, 1049999999, 1059999999, 1079999999, 1099999999, 1119999999, 1319999999, 1339999999, 1519999999, 1539999999, 1719999999 and 1739999999)
1899999999Subtotal – Asset-Backed Securities (Affiliated) (Sum of Lines: 1069999999, 1089999999, 1109999999, 1129999999, 1329999999, 1349999999, 1529999999, 1549999999, 1729999999 and 1749999999)
1909999997Subtotals – Asset-Backed Securities – Part 3
1909999998Summary Item from Part 5 for Asset-Backed Securities (N/A to Quarterly)
1909999999Subtotals – Asset-Backed Securities
2009999999Subtotals – Issuer Credit Obligations and Asset-Backed Securities
Source: 2023-06BWG Modified and 2024-12BWG
  • Schedule E, Part 2 – the line number and categories will be modified as detailed below, the Code column will be changed to “Restricted Asset Code” and the LEI column will be deleted.
    • Securities reported under SSAP No. 43R are not permitted to be reported as cash equivalents or short-term investments even if acquired within one year or less from the maturity date. All asset-backed security categories have been removed from Schedule E, Part 2.

2025Q Line Numbers and Categories:

Line NumberCategory
0019999999Issuer Credit Obligations: U.S. Government Obligations (Exempt from RBC)
0029999999Issuer Credit Obligations: Other U.S. Government Obligations (Not Exempt from RBC)
0039999999Issuer Credit Obligations: Non-U.S. Sovereign Jurisdiction Securities
0049999999Issuer Credit Obligations: Municipal Bonds – General Obligations (Direct and Guaranteed)
0059999999Issuer Credit Obligations: Municipal Bonds – Special Revenues
0069999999Issuer Credit Obligations: Project Finance Bonds Issued by Operating Entities (Unaffiliated)
0079999999Issuer Credit Obligations: Project Finance Bonds Issued by Operating Entities (Affiliated)
0089999999Issuer Credit Obligations: Corporate Bonds (Unaffiliated)
0099999999Issuer Credit Obligations: Corporate Bonds (Affiliated)
0109999999Issuer Credit Obligations: Mandatory Convertible Bonds (Unaffiliated)
0119999999Issuer Credit Obligations: Mandatory Convertible Bonds (Affiliated)
0129999999Issuer Credit Obligations: Single Entity Backed Obligations (Unaffiliated)
0139999999Issuer Credit Obligations: Single Entity Backed Obligations (Affiliated)
0169999999Issuer Credit Obligations: Bonds Issued from SEC-Registered Business Development Corps, Closed End Funds & REITS (Unaffiliated)
0179999999Issuer Credit Obligations: Bonds Issued from SEC-Registered Business Development Corps, Closed End Funds & REITS (Affiliated)
0189999999Issuer Credit Obligations: Bank Loans – Issued (Unaffiliated)
0199999999Issuer Credit Obligations: Bank Loans – Issued (Affiliated)
0209999999Issuer Credit Obligations: Bank Loans – Acquired (Unaffiliated)
0219999999Issuer Credit Obligations: Bank Loans – Acquired (Affiliated)
0229999999Issuer Credit Obligations: Mortgage Loans that Qualify as SVO-Identified Credit Tenant Loans (Unaffiliated)
0239999999Issuer Credit Obligations: Mortgage Loans that Qualify as SVO-Identified Credit Tenant Loans (Affiliated)
0269999999Issuer Credit Obligations: Other Issuer Credit Obligations (Unaffiliated)
0279999999Issuer Credit Obligations: Other Issuer Credit Obligations (Affiliated)
0489999999Total – Issuer Obligations (Unaffiliated) (Sum of Lines: 0019999999, 0029999999, 0039999999, 0049999999, 0059999999, 0069999999, 0089999999, 0109999999, 0129999999, 0169999999, 0189999999, 0209999999, 0229999999 and 0269999999)
0499999999Total – Issuer Obligations (Affiliated) (Sum of Lines: 0079999999, 0099999999, 0119999999, 0139999999, 0179999999, 0199999999, 0219999999, 0239999999 and 0279999999)
0509999999Total Issuer Credit Obligations
Source: 2023-06BWG Modified and 2024-12BWG
  • Schedule DL, Parts 1 and 2 – the line numbers and categories will be modified for the bond lines, using the same numbers and descriptions as shown above for Schedule D, Parts 3 and 4. The Code column will be changed to “Restricted Asset Code”, the LEI column will be deleted and a new “Investment Characteristics” column will be added.
    • Column 9 – Investment Characteristics: If an investment has one or more of the following characteristics, then the appropriate numbers from the list below should be included. If none of the characteristics apply, the column should be left blank
      • 1. Investment terms permit interest to be received in a form other than cash
      • 2. Investment terms permit payment of interest to be deferred without being considered past due
      • 3. Interest due and accrued has been written off as uncollectible and/or nonadmitted
      • 4. Investment has a current year or prior year recognized other-than-temporary-impairment
      • 5. Investment is an interest-only strip
      • 6. Investment is a principal-only strip
      • 7. Investment reflects a To-Be-Announced (TBA) security that will qualify as an issuer credit obligation or asset-backed security at the time the reporting entity takes possession of the issued security
  • Quarterly Notes – the following quarterly required notes will be modified due the Bond Project and BWG adoptions:
  • Schedule D, Part 1B – former bonds section will be split into two sections for Issuer Credit Obligations (ICO) and Asset-Backed Securities (ABS):
  • Schedule E, Part 1 – Cash – the Code column will be changed to Restricted Asset Code
  • Schedule BA, Parts 2 and 3 – the LEI column will be deleted and the line numbers and categories will be modified as detailed below. Notice that some categories have been deleted, new categories have been added and others have been slightly modified or moved line numbers: 
Changes to Rows
2024Q2025Q
Line NumberCategoryLine NumberCategory
0199999Oil and Gas Production – Unaffiliated0199999Debt Securities That Do Not Qualify as Bonds: Debt Securities That Do Not Reflect a Creditor Relationship in Substance, NAIC Designation Assigned by the Securities Valuation Office (SVO), Unaffiliated
0299999Oil and Gas Production – Affiliated0299999Debt Securities That Do Not Qualify as Bonds: Debt Securities That Do Not Reflect a Creditor Relationship in Substance, NAIC Designation Assigned by the Securities Valuation Office (SVO), Affiliated
0399999Transportation Equipment – Unaffiliated0399999Debt Securities That Do Not Qualify as Bonds: Debt Securities That Do Not Reflect a Creditor Relationship in Substance, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Unaffiliated
0499999Transportation Equipment – Affiliated0499999Debt Securities That Do Not Qualify as Bonds: Debt Securities That Do Not Reflect a Creditor Relationship in Substance, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Affiliated
0599999Mineral Rights – Unaffiliated0599999Debt Securities That Do Not Qualify as Bonds: Debt Securities That Lack Substantive Credit Enhancement, NAIC Designation Assigned by the Securities Valuation Office (SVO), Unaffiliated
0699999Mineral Rights – Affiliated0699999Debt Securities That Do Not Qualify as Bonds: Debt Securities That Lack Substantive Credit Enhancement, NAIC Designation Assigned by the Securities Valuation Office (SVO), Affiliated
0799999Non-Registered Private Funds with Underlying Characteristics of: Bonds, NAIC Designation Assigned by the Securities Valuation Office (SVO), Unaffiliated0799999Debt Securities That Do Not Qualify as Bonds: Debt Securities That Lack Substantive Credit Enhancement, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Unaffiliated
0899999Non-Registered Private Funds with Underlying Characteristics of: Bonds, NAIC Designation Assigned by the Securities Valuation Office (SVO), Affiliated0899999Debt Securities That Do Not Qualify as Bonds: Debt Securities That Lack Substantive Credit Enhancement, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Affiliated
0999999Non-Registered Private Funds with Underlying Characteristics of: Bonds, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Unaffiliated0999999Debt Securities That Do Not Qualify as Bonds: Solely to a Lack of Meaningful Cash Flows, NAIC Designation Assigned by the Securities Valuation Office (SVO), Unaffiliated
1099999Non-Registered Private Funds with Underlying Characteristics of: Bonds, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Affiliated1099999Debt Securities That Do Not Qualify as Bonds: Solely to a Lack of Meaningful Cash Flows, NAIC Designation Assigned by the Securities Valuation Office (SVO), Affiliated
1199999Non-Registered Private Funds with Underlying Characteristics of: Mortgage Loans, Unaffiliated1199999Debt Securities That Do Not Qualify as Bonds: Solely to a Lack of Meaningful Cash Flows, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Unaffiliated
1299999Non-Registered Private Funds with Underlying Characteristics of: Mortgage Loans, Affiliated1299999Debt Securities That Do Not Qualify as Bonds: Solely to a Lack of Meaningful Cash Flows, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Affiliated
1399999Non-Registered Private Funds with Underlying Characteristics of: Other Fixed Income Instruments, Unaffiliated1399999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Bonds, NAIC Designation Assigned by the Securities Valuation Office (SVO), Unaffiliated
1499999Non-Registered Private Funds with Underlying Characteristics of: Other Fixed Income Instruments, Affiliated1499999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Bonds, NAIC Designation Assigned by the Securities Valuation Office (SVO), Affiliated
1599999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Fixed Income Instruments, NAIC Designation Assigned by the Securities Valuation Office (SVO), Unaffiliated1599999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Bonds, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Unaffiliated
1699999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Fixed Income Instruments, NAIC Designation Assigned by the Securities Valuation Office (SVO), Affiliated1699999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Bonds, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Affiliated
1799999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Fixed Income Instruments, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Unaffiliated1799999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Preferred Stocks, Unaffiliated
1899999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Fixed Income Instruments, NAIC Designation Not Assigned by the Securities Valuation Office (SVO), Affiliated1899999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Preferred Stocks, Affiliated
1999999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Common Stocks, Unaffiliated1999999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Common Stocks, Unaffiliated
2099999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Common Stocks, Affiliated2099999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Common Stocks, Affiliated
2199999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Real Estate, Unaffiliated2199999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Real Estate, Unaffiliated
2299999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Real Estate, Affiliated2299999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Real Estate, Affiliated
2399999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Mortgage Loans, Unaffiliated2399999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Mortgage Loans, Unaffiliated
2499999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Mortgage Loans, Affiliated2499999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Mortgage Loans, Affiliated
2599999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Other, Unaffiliated2599999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Other, Unaffiliated
2699999Joint Venture, Partnership or Limited Liability Company Interests with Underlying Assets Having the Characteristics of: Other, Affiliated2699999Interests in Joint Ventures, Partnerships or Limited Liability Companies (Including non-Registered Private Funds) with Underlying Assets Having the Characteristics of: Other, Affiliated
2799999Surplus Debentures, etc. – Unaffiliated2799999Surplus Notes – Unaffiliated
2899999Surplus Debentures, etc. – Affiliated2899999Surplus Notes – Affiliated
2999999Collateral Loans – Unaffiliated2999999Capital Notes – Unaffiliated
3099999Collateral Loans – Affiliated3099999Capital Notes – Affiliated
3199999Non-collateral Loans – Unaffiliated3199999Collateral Loans – Unaffiliated
3299999Non-collateral Loans – Affiliated3299999Collateral Loans – Affiliated
3399999Capital Notes – Unaffiliated3399999Non-collateral Loans – Unaffiliated
3499999Capital Notes – Affiliated3499999Non-collateral Loans – Affiliated
3599999Guaranteed Federal Low Income Housing Tax Credit – Unaffiliated3599999Guaranteed Federal Low Income Housing Tax Credit – Unaffiliated
3699999Guaranteed Federal Low Income Housing Tax Credit – Affiliated3699999Guaranteed Federal Low Income Housing Tax Credit – Affiliated
3799999Non-Guaranteed Federal Low Income Housing Tax Credit – Unaffiliated3799999Non-Guaranteed Federal Low Income Housing Tax Credit – Unaffiliated
3899999Non-Guaranteed Federal Low Income Housing Tax Credit – Affiliated3899999Non-Guaranteed Federal Low Income Housing Tax Credit – Affiliated
3999999Guaranteed State Low Income Housing Tax Credit – Unaffiliated3999999Guaranteed State Low Income Housing Tax Credit – Unaffiliated
4099999Guaranteed State Low Income Housing Tax Credit – Affiliated4099999Guaranteed State Low Income Housing Tax Credit – Affiliated
4199999Non-Guaranteed State Low Income Housing Tax Credit – Unaffiliated4199999Non-Guaranteed State Low Income Housing Tax Credit – Unaffiliated
4299999Non-Guaranteed State Low Income Housing Tax Credit – Affiliated4299999Non-Guaranteed State Low Income Housing Tax Credit – Affiliated
4399999All Other Low Income Housing Tax Credit – Unaffiliated4399999All Other Low Income Housing Tax Credit – Unaffiliated
4499999All Other Low Income Housing Tax Credit – Affiliated4499999All Other Low Income Housing Tax Credit – Affiliated
4599999Working Capital Finance Investment – Unaffiliated4599999Working Capital Finance Investment – Unaffiliated
4699999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Fixed Income Instruments, Unaffiliated4699999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Bonds, Unaffiliated
4799999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Fixed Income Instruments, Affiliated4799999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Bonds, Affiliated
4899999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Common Stock, Unaffiliated4899999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Preferred Stock, Unaffiliated
4999999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Common Stock, Affiliated4999999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Preferred Stock, Affiliated
5099999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Preferred Stock, Unaffiliated5099999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Common Stock, Unaffiliated
5199999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Preferred Stock, Affiliated5199999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Common Stock, Affiliated
5299999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Real Estate, Unaffiliated5299999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Real Estate, Unaffiliated
5399999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Real Estate, Affiliated5399999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Real Estate, Affiliated
5499999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Mortgage Loans, Unaffiliated5499999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Mortgage Loans, Unaffiliated
5599999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Mortgage Loans, Affiliated5599999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Mortgage Loans, Affiliated
5699999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Other, Unaffiliated5699999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Other, Unaffiliated
5799999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Other, Affiliated5799999Residual Tranches or Interests with Underlying Assets Having Characteristics of: Other, Affiliated
5899999Any Other Class of Assets – Unaffiliated5899999Any Other Class of Assets – Unaffiliated
5999999Any Other Class of Assets – Affiliated5999999Any Other Class of Assets – Affiliated
6099999Subtotals – Unaffiliated6899999Subtotals – Unaffiliated
6199999Subtotals – Affiliated6999999Subtotals – Affiliated
6299999TOTALS7099999TOTALS

As always, Gain Compliance integrates the latest changes into the NAIC guidelines to streamline the reporting process. If there are any further questions or comments, please do not hesitate to reach out.

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