NAIC 2025 Fall meeting

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

• SSAP Nos. 2, 21, 26, and 43 to add (1) consistent disclosures in the SSAPs for debt securities and (2) new disclosures for residual interests, including whether the insurer is using the allowable earned yield method.
• SSAP Nos. 2, 21, 26, 30, 32 and 43 to add an aggregate disclosure of key investment information by type of private placement investment and identify private placements in the investment schedules. 
• SSAP No. 37 to expand its scope to include mortgage loans acquired through qualifying investments in a statutory trust.
• SSAP No. 61 and the Question and Answer of Appendix A-791 to add guidance on risk transfer for contracts with interdependent features, including combination coinsurance and yearly renewable term reinsurance contracts.
• 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 subsidiaries from Schedule D-6-1 and asset valuation reserve instructions.

The NAIC exposed revisions to 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. 56 to add guidance about admissibility of assets held at book value in separate accounts.
• SSAP No. 61 to clarify how interest maintenance reserve derecognized in a reinsurance transaction influences the collateral required for reinsurance credit for unauthorized or certified reinsurers. 
• A new statutory accounting concept and related template for an IMR proof of reinvestment requirement to support deferral of realized loss through negative IMR.

The NAIC discussed the following guidance:

• Directed NAIC staff to prepare an issue paper and a SSAP 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.