In my first post, I outlined the actions taken during the June 24, 2019, Blanks Working Group (“BWG”) conference call that had implications beyond the Notes. In this writing, I address those adoptions that directly impacted the Notes.
Each of the items below were adopted on June 24, 2019, as proposed or modified with friendly amendments. There were no additional comments from the BWG, regulators, or other interested parties. All adoptions are applicable to Life/Fraternal, Property, Health, and Title blanks and are effective for the 2019 Annual Statement Notes.
- 2019-05BWG: This modification adds new instructions and data-captured illustrations to Note 21, Other Items for life policies where the reporting entity is owner and beneficiary or has otherwise obtained rights to control the policy. The new disclosure will be Note 21.I for life/fraternal and health companies and Note 21.H for property and title companies.
- 2019-07BWG Modified: This adoption modifies the instructions for Note 20 — Fair Value to address the disclosure modifications adopted for SSAP No. 100R – Fair Value, which also reflect disclosure modifications adopted from GAAP ASU 2018-13, Changes to the Disclosure Requirements for Fair Value Measurement. There were no changes to the illustrations or disclosure templates as a result of these revisions.
- 2019-08BWG: This modification updates the instructions for Note 12 — Retirement Plans, Deferred Compensation, Postemployment Benefits and Compensated Absences and Other Postretirement Benefit Plans, to reflect the disclosure modifications adopted for SSAP No. 92 – Postretirement Benefits Other Than Pensions and SSAP No. 102 – Pensions.
Starting with the 2019 Annual Statement, Notes 12.A(6), 12.A(11), and 12.A(19) will be removed from the Notes and the remaining disclosures in Note 12.A will be renumbered accordingly.
Lastly, this adoption included a friendly amendment to remove the interest crediting rates disclosure that was previously included in the modifications.
- 2019-09BWG: Among other changes to the annual and quarterly statements, this adoption deletes Note 5.O – Structured Notes, which will require an adjustment to the outline of subsequent subsections within Note 5.
- 2019-11BWG: This adoption revises SSAP No. 103R – Transfers and Servicing of Financial Assets and Extinguishments of Liabilities to reduce the disclosure requirements for repurchase and reverse repurchase transactions. The revisions modify the instructions and illustrations for Notes 5.F, 5.G, 5.H, and 5.I to eliminate both the “minimum” and “average daily balance” disclosures. “Counterparty” and “Default” information from the data-captured disclosure have also been removed.
- 2019-14BWG Modified: In addition to changes to Schedule DB, this adoption modifies the instructions and illustrations for Note 8 – Derivatives to address the reporting changes necessary to implement SSAP No. 108 – Derivatives Hedging Variable Annuity Guarantees. There were friendly amendments added to the adoption by the BWG to address comments, revisions, and necessary clarifications.
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.