The Blanks Working Group (“BWG”) held a conference call on May 29, 2025, to review and consider the adoption of sixteen previously exposed positions. All of the items were adopted and will be effective with the 2025 Annual Statement, unless otherwise noted.
Adopted Items
The items below were adopted with minor editorial updates and/or with additional comments (i.e. friendly amendments) from the BWG, regulators, or other interested parties. All adoptions are applicable to either the Life/Fraternal, Property, Health or Title blanks, as specified by “L” for Life/Fraternal, “P” for Property, “H” for Health, and “T” for Title, or some combination thereof.
- 2024-19BWG Modified: This item updates the Schedule BA line categories and instructions for the expansion of collateral loans. It adds two electronic only columns to Schedule BA, Part 1 for reporting “fair value of collateral backing the collateral loan” and “current overcollateralization percentage to the collateral loan”. The AVR Equity Component will be updated to include the new collateral loan lines, renumbering the subsequent lines. This item is associated with the SAWPG Ref #2023-28 and is effective January 1, 2026. (L/P/H/T/SA)
- 2025-01BWG Modified: This item modifies the instructions for Note 8 – Derivatives to include adopted revisions to SSAP No. 86 – Derivatives, adding a new disclosure, Note 8.A(7), requiring the reporting entity to disclose its accounting policy for where cash flows associated with derivative instruments and their related gains and losses are presented in the statement of cash flows and renumbering the remaining disclosures within Note 8.A. The instructions and illustrations for Note 11 – Debt will be modified to coincide with the adopted revisions to SSAP No. 15 – Debt and Holding Company Obligations. Note 11.C will be a new data captured disclosure for “unused commitments and lines of credit for financing arrangements”. This item is associated with the SAPWG Ref #2023-26, adopted on August 13, 2024. (L/P/H/T)
- 2025-02BWG: This item modifies the instructions for Note 9 – Income Taxes to include adopted revisions to SSAP No. 101 – Income Taxes. Specifically, Note 9.B(2) – cumulative amount of each type of temporary difference has been removed from the disclosure requirements and all other disclosures within Note 9.B have been renumbered. This item is associated with SAPWG Ref #2024-11. (L/P/H/T)
- 2025-03BWG Modified: This item modifies the Life State Page and the Health Life Supplement (State Page) to capture Accident and Health data for Direct Premiums Earned by line of business in a new footnote (f) and Direct Losses Incurred, Settled and Unpaid in Columns 13 through 15 and 20 through 22. This information was inadvertently left out of the Life State Page when it was updated in 2023. (L/H)
- 2025-04BWG Modified: This item modifies Note 28 – Health Care Receivables to include a new part C for Medicare Part D Prescription Payment Plan Receivables. The disclosure requirement modifications were adopted by the SAPWG on February 25, 2025. INT 24-02T includes accounting guidance and the new data-captured disclosures were approved through a separate agenda item, Ref #2025-08. (L/P/H)
- 2025-05BWG Modified: This item adds a new part to Schedule S (Part 8) to report reinsurance agreements with funds withheld and modified coinsurance. This item is associated with disclosure requirements adopted by SAWPG on May 22, 2025 (Ref #24-07). (L)
- 2025-06BWG Modified: This item modifies the instructions and illustrations for Note 5.L – Restricted Assets to clarify how assets held under modified coinsurance (Modco) or funds withheld (FWH) agreements should be reflected within the restricted asset disclosure. The updated disclosure has been enhanced to fully identify the extent of restricted assets reported on the balance sheet within a single disclosure and a new disclosure has been added to identify differences between the “restricted asset” disclosure and the amounts reported in the general interrogatories, which are pulled directly into the RBC formula. The changes coincide with modifications to SSAP No. 1 – Accounting Policies, Risks and Uncertainties, and Other Disclosures adopted by the SAPWG in Ref #2024-20. (L/P/H/T)
- 2025-07BWG: This item modifies the Schedule P instructions for editorial revisions made by the Casualty Actuarial and Statistical (C) Task Force. (P)
- 2025-08BWG: This item removes General Interrogatory #14 for Life/Fraternal companies that reported total dividends paid to stockholders and renumbers the remaining interrogatories. It coincides with SAPWG Ref #2025-07 which discusses that the interrogatory is not included across all annual statement blanks and is not a required disclosure in SSAP No. 72 – Surplus and Quasi-Reorganizations. (L)
- 2025-09BWG: This item updates the Life/Fraternal Note 35 for separate account transfers and adds a new general interrogatory to the Separate Account blank for transfers and repurchase agreements and reverse repurchase transactions. It coincides with SAPWG Ref #2024-10. (L/SA)
- 2025-10BWG Modified: This item updates Note 5.L – Restricted Assets to identify assets held under funds withheld agreements (including modco) that are affiliated with the reinsurer. It also updates the list of required quarterly disclosures to include Note 5.L. With this change, this disclosure will be required in all interim and annual financial statements. See SAPWG Ref #2025-05 for additional information. (L/P/H/T)
- 2025-11BWG: This item removes the capital structure code column (37) from Schedule D, Part 1, Sections 1 and 2. Prior Schedule D company reporting for this information has been found to be misleading and inconsistent across legal entities for similar investments. The code was originally established for SVO use, but the information is no longer used from the Schedule D reporting and is obtained from the SVO through other data sources. This item coincides with SAPWG Ref #2025-04. (L/P/H/T)
- 2025-12BWG: This item removes Line 8 – Unrated Multi-Class Securities Acquired by Conversion from the AVR Default Component – Basic Contribution. It relabels the line with “intentionally left blank” to prevent renumbering all lines in the AVR schedule and to be used in the future if there are other AVR updates. After review, the NAIC staff does not believe this historical line should be retained in the AVR schedule as there should be no securities reported within this line under current statutory accounting principles. See SAPWG Ref #2025-06 for additional information. (L)
- 2025-13BWG Modified: This item updates Note 13K – Surplus Notes to add clarifying guidance for reporting certain debt securities as capital notes in scope of SSAP No. 41 – Surplus Notes. See SAWPG Ref #2024-28 for further discussion. (L/P/H/T)
- 2025-14BWG: This item adds clarifying instructions as to where the Medicare Part D Prescription Payment Plan information should be reported on the Annual and Quarterly statements. Additional information can be found in the SAPWG INT 24-02 Medicare Prescription Payment Plan. (L/P/H/T)
- 2025-15BWG Modified: This item updates the annual and quarterly instructions for Note 8 – Derivatives and Schedule DB to clarify the terminology used for derivative financing premium. It coincides with SAPWG Ref #2024-23. (L/P/H/T/SA)
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.
Stay on top of changes to the NAIC guidance on Gain’s library of resources.
Make sure to check out company blog posts, and follow Gain Compliance on LinkedIn.