The Blanks Working Group (“BWG”) held a conference call on August 20, 2019, to review and consider the adoption of three previously exposed positions outlined below, as well as consider and expose three new items.
The following items were adopted as proposed, aside from the updated effective date noted in the first item below:
2019-18BWG Modified: This adoption adds an NAIC Designation Modifier to the “NAIC Designation” column for Schedules D, DL and BA to accommodate the NAIC Designation Category granularity framework adopted by the Valuation of Securities (E) Task Force.
The exposure presented was to be effective for the Q1 2020 Quarterly Statement, but after comments and discussion the BWG revised the effective date to the 2020 Annual Statement. Aside from the change of effective date, there were no additional comments from the BWG, regulators, or other interested parties. This item is applicable to Life/Fraternal, Property, Health, and Title blanks.
2019-20BWG: This item evolved from an e-vote conducted on July 2, 2019, after being initially proposed by the Casualty Actuarial and Statistical Task Force. This modification only impacts Property companies and requires the addition of “Qualification Documentation” so the Appointed Actuary will be required to maintain workpapers explaining how the actuary meets the definition of “Qualified Actuary”.
If ratified by the Accounting Practices and Procedures Task Force (“AP&PTF”), the Financial Condition (E) Committee, etc., the proposal will be effective for the 2019 Annual Statement and only impacts the Property blank. While all items go through this process (e.g., other committees) after adoption by the BWG, this item may be one to follow for interested parties as there was some discussion and commentary during the BWG call that does make this adoption less certain.
2019-19BWG Modified: This item intended to add a new category line for unaffiliated certificates of deposit to Schedules D, DA, DL, and E, as well as a line to the Summary Investment Schedule for unaffiliated certificates of deposit. The revisions would have required modification of the list of bonds for Lines 8 through 11 of the Summary by Country as well as adding instruction to zero fill the CUSIP and ISIN fields for unaffiliated certificates of deposit.
This item was withdrawn by the BWG. After the comment period there were material modifications to consider incorporating, as well as some opposition from interested parties seeking to most effectively and efficiently gather and present the requested data. While this particular item was withdrawn, the discussion centered around allowing the NAIC and interested parties more time to develop a unified proposal in lieu of this item. Stated differently, all parties agreed that a singular item would be preferred over adopting this item and then proposing subsequent addendums and revisions.
Lastly, the BWG exposed three new items for public comment:
- 2019-21BWG: This exposure only impacts the Life/Fraternal blank for Note 33 – Premiums and Annuity Considerations Deferred and Uncollected, specifically the illustration. The proposed modification would break apart the data-captured table in the Note in order individually capture Separate Account with Guarantees products and Separate Account Nonguaranteed products.
- 2019-22BWG: This exposure would impact the Life/Fraternal blank by adding a question regarding the Executive Summary of the PBR Actuarial Opinion to the Supplemental Exhibits and Schedules Interrogatories, which will enable regulators to see if the reporting entity has filed it.
- 2019-23BWG: This exposure would modify both the instructions and illustration for Note 8 – Derivatives for disclosures adopted by SSAP No. 108 – Derivative Hedging Variable Annuity Guarantees as well as add Quarterly Schedule DB, Part E and instructions to the quarterly statement.
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.