SSAP and Blank Updates to the Statutory Financial Statements – 2018 NAIC Fall National Meeting

In our last post on SSAP and blank updates, we updated our readers on the changes the NAIC made during its Fall National Meeting regarding the Notes. This post will cover the balance of the modifications, with a short summary of each of the changes.

During the Fall National Meeting, the Blanks Working Group (“BWG”) adopted two items that will impact the 2019 Annual Statement:

  • 2018-22BWG Modified – Instructions were added for the Life and Fraternal Analysis of Operations and Analysis of Reserves for types of life insurance, which supports a previous modification that is also effective for the 2019 Annual Statement (2018-22BWG).
  • 2018-26BWG Modified – This modification adds the Analysis of Operations by Lines of Business – Summary blank page and instructions for general and separate accounts.

There were also items that were exposed for comment by the BWG during the Fall National Meeting that will impact future filings (beyond the Notes). If adopted, each of these Updates would be effective for either the 2019 Annual Statements (unless otherwise indicated).

  • 2018-23BWG – Questions 34.1 and 34.2 would be added to the General Interrogatories Part 2 for fraternal benefit societies (along with the instructions for Question 34.2).
  • 2018-24BWG – Risk-based capital (“RBC”) factors were updated as a result of the adoption of the federal Tax Cuts and Jobs Act, which leads to adjustments to asset valuation reserve (“AVR”) factors in the life, accident, and health/fraternal blanks.
  • 2018-25BWG – The purpose of this proposal is to update the reinsurance ceded codes in the Quarterly Schedule S to conform to the list used for annual statement reporting, along with adding an additional column and instructions to indicate the type of business ceded. This would not be effective until the first quarter of 2020.
  • 2018-29BWG – This proposal clarifies that all policy loans should be reported in the general account, which will reduce inconsistencies in reporting.
  • 2018-31BWG – The terms “Unit Investment Trusts” and “Closed-end Funds” would be added to the instructions as a result of this proposal. The addition of these terms would allow for new categories using those terms to be added throughout the investment schedules (Schedule D, Summary Investment Schedule, Schedule DL parts 1 and 2).

There were nine items adopted by the Statutory Accounting Principles (E) Working Group (“SAPWG”) at the Fall National Meeting that are in effect for year-end 2018 reporting:

  • 2018-17: Structured Settlements – Periodic-certain structured settlements are admitted assets if acquired in accordance with all state and federal laws. Life-contingent structured settlements and periodic-certain structured settlements not acquired pursuant to state and federal laws are nonadmitted assets.
  • 2018-20: Debt Forgiveness Between Related Parties – Existing guidance was referenced in SSAP No. 72 – Surplus and Quasi-Reorganization to answer specific questions for when there has been a forgiveness of a debt owed by a related party.
  • 2018-21: SSAP No. 72 Distributions – Revisions to accounting guidance were made to incorporate when an entity provides a distribution that is a return of capital.
  • 2018-23: SSAP No. 68 Mergers – Per the revisions, scenarios in which the stock of an owned entity is cancelled, with a parent entity reporting the assumed assets and liabilities, are now clearly classified as statutory mergers.
  • 2018-24EP: Editorial and Maintenance Update – Editorial changes were reflected in SSAP Nos. 86 and 97 and Appendix A – 010.
  • 2018-25: ASU 2018-01, Leases – Land Easement Practical Expedient – Revisions reject ASU 2018-01 for statutory accounting.
  • 2018-27: SSAP No. 48 Entities’ Loss Tracking – Loss tracking disclosures are now required in situations where a reporting entity’s share of losses in a SSAP No. 48 entity exceeds its investment in the entity.
  • 2018-29: Consistency Revisions to A-820 – The phrase “good and sufficient reserve” was removed from Appendix A due to inconsistencies with the related NAIC Standard Valuation Law Model 820.
  • 2018-31: Extension of Ninety-Day Rule for Impact of Hurricane Florence and Hurricane Michael – For policies impacted by the named storms a temporary sixty-day extension was added to the ninety-day rule under SSAP No. 6 – Uncollected Premium Balances, Bills Receivable for Premiums, and Amounts Due from Agents and Brokers.

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.

Detailed information on adopted and exposed modifications can be found at the following locations: