Exposure Drafts Outstanding
Statutory Accounting Principles Working Group
Last Updated April 11, 2017

Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to Julie Gann, Robin Marcotte, Fatima Sediqzad and Jake Stultz.


Ref No. Issue Paper/ SSAP No./ Appendix Title Description


Appendix F

Policy Statement on Coordination with P&P Manual, SVO and VOSTF

New policy statement describes coordination and collaboration between the Purposes and Procedures Manual of the Investment Analysis Office and Accounting Practices & Procedures Manual.


SSAP No. 37

Mortgage Loans with Multiple Lenders

Revisions to the definition of a mortgage loan, as well as examples of investments intended to be captured within SSAP No. 37.


SSAP No. 43R

Definition of Loan-Backed and Structured Securities

Exposed agenda item, originally proposing a definition change for securities in scope, with the intent to dispose without incorporating a definition change.


SSAP No. 101

ASU 2016-16 – Intra-Entity Transfers of Assets Other than Inventory

Rejects ASU 2016-16 with a comment request on whether the rejection would create timing differences with U.S. GAAP.


SSAP No. 69

ASU 2016-18: Statement of Cash Flows - Restricted Cash

Adopts ASU 2016-18 with a year-end 2019 effective date. Exposure requests comments on whether a definition for "restricted cash and cash equivalents" is needed and if there are concerns with retrospective application.


Appendix D

ASU 2017-06: Plan Accounting – Master Trust Reporting

Exposed revisions to reject ASU 2017-06, which provides accounting guidance to address a plan's accounting for pension plans, as not applicable in Appendix D, Nonapplicable GAAP Pronouncements.


SSAP No. 104R

ASU 2016-09: Improvements to Employee Share-Based Payment Accounting

Adopts with modification ASU 2016-09. Requests comment on the proposed transition guidance and whether transition guidance is needed for non-GAAP companies.


Appendix D

ASU 2017-02: Clarifying When a Not-for-Profit Entity That Is a General Partner or a Limited Partner Should Consolidate a For-Profit Limited Partnership or Similar Entity

Exposed revisions to reject ASU 2017-02 which addresses consolidation guidance as not applicable in Appendix D, Nonapplicable GAAP Pronouncements.


Appendix D

ASU 2017-03 – Amendments to SEC Guidance

Exposed revisions to reject ASU 2017-03 as not applicable in Appendix D Nonapplicable GAAP Pronouncements


SSAP No. 97

Extension of SCA Filing Deadlines

Revises the deadlines for Sub 1 and Sub 2 filings and requests comments on the proposed time frames, including whether the proposed time frames will improve compliance with filing requirements.


Appendix A-010

2016 Cancer Claim Cost Valuation Tables

Incorporates the 2016 Cancer Claim Cost Valuation Tables into Appendix A-010.


SSAP No. 26R

Bank Loans

Requests input regarding statutory accounting guidance for bank loans, focusing on loans directly issued by the reporting entity, and whether such loans should be captured within the scope of SSAP No. 26R.


SSAP No. 65

Expand High Deductible Disclosures

Expands disclosures for high-deductible policies to facilitate data capture for year-end 2017.


SSAP No. 41R

Amortization and Accretion Surplus Notes

Proposed revisions to SSAP No. 41R to provide guidance regarding surplus notes issued at a discount or a premium.

MO 280

Model 280

Investments of Insurers

Revisions are technical changes to remove the "Class 1" reference as the concept of Class 1 Money Market Mutual Funds no longer exists. The revisions also propose to correct the definitions of repurchase and reverse repurchase agreements within the Model.



IP No. 156

Variable Annuities

Exposure considers prior industry comments and  identifies key areas where input is requested.


SSAP No. 86

Impact of Future Settled Premiums on the Option Valuations

Exposed agenda item to clarify liability recognition for the cost to acquire derivatives with a deferred or financing premium, as well as to provide disclosures and specific reporting for these premiums. Industry was requested to provide an illustrated Schedule DB to identify proposed revisions to capture information on these derivative structures.


SSAP No. 86

Settlement of Variation Margin

Requested input on the legal settlement impact related to variation margins.


Conference Call
Thursday, June 8, 2017
11:00 a.m. Eastern / 10:00 a.m. Central / 9:00 a.m. Mountain / 8:00 a.m. Pacific / 7:00 a.m. Alaska / 5:00 a.m. Hawaii 
Call duration: 90 minutes

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Subsidiary, Controlled or Affiliated (SCA)

INT 15-01: Risk Corridors Collectibility

Relating SVO Unit Prices to the Fair Value Hierarchy

Structured Securities

Accounting Practices and Procedures Manual Updates

SSAP No. 43R flowchart

SAPWG Maintenance Agenda Submission Form (Form A)
See Policy Statement on SAPWG Maintenance Agenda Process for description and instruction. After completion of the Form A, please send to NAIC staff via email (see contact information below) for review. NAIC staff will send a confirmation of receipt. In order for NAIC staff to place the Form A on the Agenda, the Form A must be received no later than the comment deadline.

Maintenance Agenda
Updated May 5, 2017

SAP to Annual Statement Disclosure Checklist Updated for 2016 Annual Statements
Updated 1/31/2017

Please note, in an effort to go green, the spreadsheets are spaced to view the entire width on a computer screen. At other percentages or if printing, some detail may be lost.

Policy Statements
See Appendix F – Policy Statements of the Accounting Practices and Procedures Manual for a complete listing.

Join the Statutory Accounting Electronic Updates Membership



Education & Training Events

Related NAIC Publications


Statutory Accounting Principles (E)
Working Group

The Statutory Accounting Principles (E) Working Group is responsible for developing and adopting substantive, nonsubstantive and interpretation revisions to the NAIC Accounting Practices and Procedures Manual (AP&P Manual). The AP&P Manual provides the basis for insurers to prepare financial statements for financial regulation purposes.

Substantive statutory accounting revisions introduce original or modified accounting principles. Substantive revisions can be reflected in an existing Statement of Statutory Accounting Principles (SSAP) or a new SSAP. Nonsubstantive statutory accounting revisions are characterized as language clarifications that do not modify the original intent of a SSAP. SSAPs are considered the highest authority (Level 1) in the statutory accounting hierarchy.

An interpretation to an existing SSAP may be developed to provide timely application, interpretation or clarification guidance. Revisions classified as an interpretation shall not amend, supersede or conflict with existing, effective SSAPs. Interpretations are considered the second highest authority (Level 2) in the statutory accounting hierarchy.

Items for consideration by the Working Group can be submitted via a SAPWG Maintenance Agenda Submission Form (Form A) to the NAIC staff support listed on this Web page.

2017 Adopted Committee Charges
  1. Maintain codified statutory accounting principles by providing periodic updates to the guidance that address new statutory issues and new generally accepted accounting principles (GAAP) pronouncements. Provide authoritative responses to questions of application and clarifications for existing statutory accounting principles. Report all actions and provide updates to the Accounting Practices and Procedures (E) Task Force.

  2. At the discretion of the chair, develop comments on exposed GAAP and International Financial Reporting Standards (IFRS) pronouncements affecting financial accounting and reporting. Any comments are subject to review and approval by the chairs of the Accounting Practices and Procedures (E) Task Force and the Financial Condition (E) Committee.

  3. Coordinate with the Life Actuarial (A) Task Force on changes to the Accounting Practices and Procedures Manual related to the Valuation Manual VM-A, Requirements, and VM-C, Actuarial Guidelines, as well as other Valuation Manual requirements. This process will include the receipt of periodic reports on changes to the Valuation Manual on items that require coordination.

  4. Obtain, analyze and review information on permitted practices, prescribed practices or other accounting treatments suggesting that issues or trends occurring within the industry may compromise the consistency and uniformity of statutory accounting, including but not limited to activities conducted by insurers for which there is currently no statutory accounting guidance or where the states have prescribed statutory accounting that differs from the guidance issued by the NAIC. Utilize this information to consider possible changes to statutory accounting.

  5. Develop specific statutory accounting guidance for certain limited derivative contracts hedging variable annuity guarantees, subject to fluctuations as a result of interest rate sensitivity, reserved for in accordance with Actuarial Guideline XLIII—CARVM for Variable Annuities (AG 43). This guidance shall place an emphasis on reducing non-economic surplus volatility for these specific hedges in situations where strong risk-management is in place, with safeguards to ensure appropriate financial statement presentation and disclosures, sufficient transparency, and regulatory oversight. This charge shall be a high priority, with the earliest effective date feasible that allows for adequate development of guidance and related reporting schedules.

  6. Consider whether current or future changes to reserves resulting from implementation of the Variable Annuities Framework for Change will be reported in the annual financial statement as a “change in basis.”

The following Subgroup reports to the Statutory Accounting Principles Working Group:

For revisions adopted by the Working Group, please refer to the Accounting Practices and Procedures Manual Updates Web page