Insurance: NAIC 2025 Summer meeting

ISSUES & TRENDS | September 2025

We report on actions and discussions on conference calls and at the NAIC 2025 Summer meeting.

Applicability:

  • All insurance companies

Key impacts

During its Summer meeting and on calls before it, the National Association of Insurance Commissioners (NAIC) adopted the following guidance:

  • INT 23-01 to extend the effective date to December 31, 2026, clarify guidance, and establish an additional current-period admittance limit for a net negative interest maintenance reserve.
  • VM-22 framework for principle-based reserving of non-variable annuities.
  • Actuarial Guideline 55 for asset-adequacy analysis of reserves related to certain life reinsurance treaties.
  • Generator of economic scenarios for VM-20, VM-21, and VM-22.

The NAIC exposed revisions to the following guidance:

  • SSAP Nos. 2, 21, 26, and 43 to add consistent disclosures for debt securities among the SSAPs and a new general interrogatory to identify whether an insurer is reporting residuals under the allowable earned yield or practical expedient measurement method and if it is transitioning from the practical expedient to the allowable earned yield approach.
  • SSAP Nos. 2, 21, 26 and 43 to add an aggregate disclosure of key investment information by type of private placement securities and identify private placement securities in the investment schedules. 
  • SSAP No. 37 to expand its scope to include mortgage loans acquired through qualifying investments in a statutory trust and be reported on Schedule B.
  • Annual Statement Instructions to eliminate the concept of investments in noninsurance subsidiary, controlled or affiliated entities that hold assets for the benefit of the insurer and its affiliates, including removing investment subsidiary from Schedule D-6-1 and asset valuation reserve instructions.

The NAIC discussed the following guidance:

  • SSAP No. 61 and the Question and Answer of Appendix A-791 to add guidance for risk transfer analysis on combination coinsurance and yearly renewable term reinsurance contracts with interdependent features.

Report contents

  • Meeting highlights
  • Accounting highlights
  • Actuarial highlights
  • Risk-based capital
  • Valuation of Securities Task Force 

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Insurance: NAIC 2025 Summer meeting

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