In November, nature reminds us that winter is approaching, we share a Thanksgiving meal with friends and family, and many of us start thinking about Christmas shopping. (Some of us even finish our Christmas shopping by then.) What more could one ask for in November? How about NAIC-related activity and the beginning of another NAIC National Meeting? Since the NAIC National Meeting begins the last day of November and continues into December, the summary of NAIC-related activity for November will not include the National Meeting. The National Meeting will be covered and published separately and any wrap-up for the year will be covered in the December summary. Let’s take a look at November.
Blanks Working Group (BWG) – November 7, 2023
Items that had previously been exposed for comment were addressed first. Those items included three proposals resulting from the Statutory Accounting Principle Working Group’s (SAPWG) bond project.
| Reference # | Subject | Disposition |
|---|---|---|
| 2023-05 | Revises the cybersecurity supplement by eliminating the reporting of identity theft insurance, removes the claims-made and occurrent breakdown as well as first-party and third-party breakdowns, and removes interrogatory regarding tail policies (Property/Casualty statement). | Re-exposed until January 1, 2024; proposed effective date is year-end 2024. |
| 2023-06 | Reformats Schedule D – Part 1 into two sections, provides new bond reporting categories, and revises investment summary schedules (all statements). | Adopted; effective January 1, 2025. |
After years of effort, the above-adopted proposal is the main product of bond reporting to arise from the bond project. Prior to adoption by the BWG, the proposal was exposed several times by the SAPWG and twice by the BWG. PLEASE NOTE: Although Schedule D – Part 1 does not appear in the quarterly statements, the new bond reporting categories will be used for the quarterly 2024 reporting in Schedule D – Parts 3, 4, and 5. Therefore, this adoption will affect 2024 quarterly reporting (as well as new reporting categories in Schedule BA provided in reference #2023-12).
| Reference # | Subject | Disposition |
|---|---|---|
| 2023-07 | Elimination of Legal Entity Identifier column and updating of Code Column in the investment schedules (all statements). | Adopted. Effective January 1, 2025. |
| 2023-09 | New Life Note 37. | Withdrawn. |
| 2023-12 | Updates the reporting categories in Schedule BA for debt securities that do not qualify as bonds. | Re-exposed until January 21, 2024; proposed effective date is January 1, 2025. |
Several editorial changes also were adopted, effective immediately.
New items were then exposed for comment, with an exposure deadline of January 21, 2024.
| Reference # | Subject | Disposition |
|---|---|---|
| 2023-13 | Adds disclosure to Note 5 regarding negative Interest Maintenance Reserve (IMR) for Life/Fraternal companies. | Exposed for comment. |
If adopted, the above exposure would have an effective date of year-end 2024 for data-capture. However, Life/Fraternal companies admitting negative IMR for 2023 reporting are required to provide this same information. Those companies should use this proposal as a guideline to the information they should be providing.
| Reference # | Subject | Disposition |
|---|---|---|
| 2023-14 | Revises the Health Test language in the General Interrogatories (Life/Fraternal, Property/Casualty, Health statements). | Exposed for comment. |
| 2023-15 | New Life/Fraternal General Interrogatory for completing C-2 mortality risk in RBC. (Replacement for 2023-09 above.) | Exposed for comment. |
Memos from the SAPWG were received and will be posted as guidance on the BWG webpage for year-end. These items were adopted by the SAPWG after the annual statement instructions had formally been adopted but are needed to assist companies in completing their 2023 statements. Covered in the memos were the reporting of negative IMR for the Life/Fraternal companies, the note disclosure for corporate alternative minimum tax, and additional instructions for the reporting of paid-in-kind (PIK) interest in Note #5. Any other items adopted prior to December 31, 2023 could result in the posting of additional guidance, so watch the webpage carefully.
The group then moved onto a quick review of the state filing checklists for year-end 2023. It is the Working Group’s responsibility to monitor the state checklists and approve them before the states post them to their websites. Besides being available on the states’ websites, the checklists also are available on the NAIC website. BWG will meet in February to address items that were exposed during this meeting and any other matters that might arise.
Health Risk-Based Capital (RBC) Working Group – November 8, 2023
This meeting got off to a very slow start and didn’t have a quorum present at first. Once a quorum was obtained, it proved difficult for the chair to get group members to make motions and even to vote. The group did adopt proposal 2023-11-H, XR014 Fee-for-Service & Other Risk Revenue – Medicare & Medicaid. This proposal indicates the inclusion of Medicare and Medicaid amounts in Column 1 of the Underwriting Risk. The adopted proposal will be effective for 2024 RBC reporting. The American Academy of Actuaries (Academy) provided a report on its work on Health Care Receivables and the H2 Underwriting Risk. The Academy’s presentation was exposed for comment through January 8, 2024. The Working Group then discussed pandemic risk and, in particular, healthcare before, during, and after the pandemic. An overview of the work of the Risk Evaluation Ad Hoc Group was briefly discussed as well as the 2022 Health RBC statistics. For those interested, the statistics will be posted to the Working Group’s webpage.
Reinsurance Task Force – November 16, 2023
This virtual meeting took the place of a physical meeting at the upcoming NAIC National Meeting. The Task Force adopted the report of the Reinsurance Financial Analysis Working Group regarding regulator-to-regulator sessions held to review certified reinsurers and reciprocal jurisdiction reinsurers. A status report regarding the activities of the Mutual Recognition of Jurisdictions Working Group (MRJWG) also was adopted. During its meetings, MRJWG reapproved Bermuda, France, Germany, Ireland, Japan, Switzerland, and the United Kingdom as qualified jurisdictions and Bermuda, Japan, and Switzerland as reciprocal jurisdictions. The Uniform Checklist for Reciprocal Jurisdictions Reinsurers was adopted as well as a referral to the Property and Casualty RBC Working Group. The RBC proposal would add new disclosures for catastrophe reinsurance programs to the Property/Casualty RBC. The Task Force decided the proposed disclosures would be best positioned in the RBC rather than the annual statement because of the confidentiality of some of the requested information. The Task Force received a report of other NAIC projects that might affect reinsurance, as well as the status of the implementation of the Term and Universal Life Insurance Reserve Financing Model Regulation (#787).
Blanks Working Group Interested Parties (IPs) – November 13, 20, & 27, 2023
The BWG IPs have scheduled a series of calls over approximately the next 12 months. These calls will not only handle the regular routine exposure and adoption of items by BWG, but also will discuss implementation issues industry has found in adopted revisions. Although not limited in scope, the focus of these implementation problems will be the new reporting resulting from the SAPWG’s bond project. Concerns that have been found will then be filtered back to regulators with the hope of having them settled for 2025 reporting.
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