The Blanks Working Group (“BWG”) held a conference call on October 22, 2019, to review and consider the adoption of four previously exposed positions outlined below, as well as consider and expose three new items.
Each of the items below were adopted as proposed or modified with friendly amendments (2019-23BWG Modified), with no additional comments from the BWG, regulators, or other interested parties.
- 2019-21BWG: This adoption only impacts the Life/Fraternal blank, specifically Note 33 – Premiums and Annuity Considerations Deferred and Uncollected. The modification breaks apart the data-captured table in Note 33 in order individually capture Separate Account with Guarantees products and Separate Account Nonguaranteed products, beginning with the 2020 Annual Statement.
- 2019-22BWG: This modification impacts the Life/Fraternal blank by adding a question to the Supplemental Exhibits and Schedules Interrogatories regarding the Executive Summary of the PBR Actuarial Opinion, which will enable regulators to see if the reporting entity has filed it with their state of domicile. The adoption is effective for the 2020 Annual Statement.
- 2019-23BWG Modified: This item 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 8A(8), previously Note 8H, remains required as well.
- 2019-24BWG: This adoption adds a Life Experience Data Contact to the Electronic Jurat page for Life/Fraternal companies only. Health, Property, and Title are included in the proposal due to the Jurat instructions being uniform for all statement types. The basis for the adoption is to provide NAIC staff with a contact person from each legal entity life insurance company to facilitate communication regarding various data studies and submission of data. This adoption is also effective for the first quarter of 2020.
Lastly, the BWG exposed three new items for public comment:
- 2019-25BWG: This exposure modifies the instructions in both Schedule F, Part 3 – Property and Schedule F, Part 2 – Life/Fraternal Workers’ Compensation Carve-out supplement, to remove instructions to exclude adjusting other reserves from Column 10. The exposure also adds instructions to include those with defense and cost containment reserves in both Columns 10 and 12 in the aforementioned schedules. Lastly, crosschecks are proposed to be added to Schedule P, Part 1.
- 2019-26BWG: The exposure adds instruction and a crosscheck for Line 34 on the Analysis of Operations by Lines of Business – Summary for the Life/Fraternal blank. Further, it adds instructions for Column 5 – Indexed Life on the Analysis of Operations by Lines of Business – Individual Life and clarifying instructions to the Analysis of Operations by Lines of Business for Individual Life and Group Life regarding reporting consistent with policy type language in the contract and reporting of policies issued with secondary guarantees that have expired.
- 2019-27BWG: This exposure simply removes the alphabetic index from inclusion at the back of all annual statement blanks, instructions, and BWG web page.
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.