Insurance: NAIC 2026 Spring meeting

Applicability

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

Revisions to SSAP No. 22 to clarify that sale leasebacks with restrictions on access to the cash proceeds do not qualify for sale leaseback accounting and are accounted for by the seller using the financing method.
New statutory accounting concept and related template for an interest maintenance reserve proof of reinvestment requirement.
A proposal to update the reinvestment guardrails for VM-20, VM-21 and VM -22 to align them.

The NAIC exposed revisions to the following guidance:

SSAP No. 52 to add new disclosures and a glossary for funding agreement-backed notes and other similar structures.
SSAP No. 109 and related issue paper for interest rate hedging derivatives that do not qualify as effective hedges under SSAP Nos. 86 or 108 but are used for asset-liability management.
Questions about retrospective application of VM-22 to inforce policies and a proposed approach developed by interested parties.
VM-22 reinvestment guardrail requirements for pension risk transfer.
Proposal to modify the revised risk-based capital (RBC) treatment of collateralized loan obligations (CLOs) and a presentation from the American Academy of Actuaries on its modeling work and related factors for CLO debt tranches.
Proposal to revise RBC charges for collateral loans reported on Schedule BA based on the type of underlying collateral.

The NAIC discussed the following guidance:

SSAP Nos. 1, 5, 21, 26 and 43 and the Annual Statement Instructions to add a definition for commitments and consolidate and clarify disclosures by adding a new comprehensive contingent commitments disclosure.
SSAP No. 48 to review several concepts to evaluate whether the guidance is clear and is consistently applied as intended.