SSAP and Blank Updates to the Statutory Financial Statements – August 11, 2025 SAPWG Conference Call

The Statutory Accounting Principles Working Group (“SAPWG”) met virtually and in person at the NAIC Summer National Meeting held on August 11, 2025. This post is intended to provide an informative snapshot of what was accomplished during the meeting, as well as help accelerate your determination of the impact the adoptions and modifications will have on your financial statements.

Adopted Items

The SAPWG reviewed and adopted the following items that were previously exposed for comment. The items were adopted with minor revisions recommended by interested parties or regulators during the exposure period and discussed during the meeting. The adopted items apply to all lines of business (Life/Fraternal, Property, Health and Title) and all revisions are effective immediately, unless otherwise noted.

  • Ref #2022-19: INT 23-01: Net Negative (Disallowed) Interest Maintenance Reserve – This item extends the interpretation one year until December 31, 2026, with modifications to provide clarity and to establish an additional current-period admittance limit in paragraph 9.a. The interpretation will be automatically nullified on January 1, 2027.  (Life/Fraternal)
  • Ref #2024-05: A-791, Paragraph 2.C – This item provides a clarifying edit to A-791, Life and Health Reinsurance Agreements, Section 2.c’s Question and Answer. Specifically, under “A”, the first sentence, which reads “Unlike individual life insurance where reserves held by the ceding insurer reflect a statutorily prescribed valuation premium above which reinsurance premium rates would be considered unreasonable, group term life has no such guide”, is being removed. (Life/Fraternal, Health)
  • Ref #2025-02: ASU 2024-04, Induced Conversions of Convertible Debt Instruments – This item revises SSAP No. 15 – Debt to adopt with modification ASU 2024-04, Debt – Debt with Conversion and Other Options (Subtopic 470-29), Induced Conversions of Convertible Debt Instruments for statutory accounting. This update provides clarification on induced conversions including when the inducement should be recognized as expense by the issuer, as well as the fair value measurement of that expense. 
  • Ref #2025-09: VM-22 Coordination – This item provides minor consistency revisions to SSAP No. 51 – Life Contracts to reflect updates to the Valuation Manual in VM-22 PBR: Requirements for Principle-Based Reserves for Non-Variable Annuities. (Life/Fraternal, Health)
  • Ref #2025-10: ASU 2023-07, Improvements to Reportable Segment Disclosures – This item adopts revisions to Appendix D, Nonapplicable GAAP Pronouncements, to reject ASU 2023-07 as not applicable to statutory accounting.
  • Ref #2025-11: ASU 2024-03, Disaggregation of Income Statement Expenses and ASU 2025-01, Clarifying the Effective Date of ASU 2024-03 – This item adopts revisions to Appendix D, Nonapplicable GAAP Pronouncements, to reject ASU 2024-03 and ASU 2025-01 as not applicable to statutory accounting.
  • Ref #2025-14: ASU 2017-05, Other Income – Gains and Losses from the Derecognition of Nonfinancial Assets (Subtopic 610-20), Clarifying the Scope of Asset Derecognition Guidance and Accounting for Partial Sales of Nonfinancial Assets – This item adopts revisions to Appendix D, Nonapplicable GAAP Pronouncements, to reject ASU 2017-05 as not applicable to statutory accounting.
  • Ref #2025-15: ASU 2025-02, Liabilities (Topic 405), Amendments to SEC Paragraphs Pursuant to SEC Staff Accounting Bulletin No. 122 – This item adopts revisions to Appendix D, Nonapplicable GAAP Pronouncements, to reject ASU 2025-02 as not applicable to statutory accounting.
  • Ref #2025-16: Status Section Update – This item streamlines the status section of each SSAP. The status section will no longer reference issue papers, and references to “substantively revised” will be changed to “conceptually revised” to be consistent with previously adopted policy statement language. The revisions will be reflected in the 2026 Manual as non-tracked changes.
  • Ref #2025-EP:Editorial Revisions – This item provides editorial revisions to the SSAPs listed below to update disclosures, remove a remaining credit rating provider (CRP) reference and to remove superseded terminology.
    • SSAP No. 26 – Bonds – Update Disclosure 40.f to match Schedule D, Part 1A maturity categories. 
    • SSAP No. 41 – Surplus Notes – Remove remaining reference to a “CRP” designation in paragraph 11. Whether the designation is required from a Credit Rating Provider or from the SVO is contingent on the Purposes and Procedures Manual of the NAIC Investment Analysis Office.
    • SSAP No. 56 – Separate Accounts – Delete disclosure 32.d as it is no longer applicable with the previously revised adoptions to SSAP No. 56.
    • INT 22-01 – Freddie Mac When Issued K-Deal (WI Trust) Certificates– Removed former SSAP No. 43R – Loan-Backed and Structured Security terminology as the language has become outdated with the principles-based bond project adoptions.

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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