Exposure Drafts Outstanding
Statutory Accounting Principles Working Group
Last Updated March 17, 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


Issue Paper

SSAP No. 26R

Investment Classification Project

BlackRock's Systematic Valuation Methodology

Updated 9/6/2016

BlackRock’s Responses
related to “Questions Raised on BlackRock’s Calculated Valuation Proposal”

Exposed issue paper and draft substantively revised SSAP No. 26—Bonds.

Revisions to the issue paper and the proposed SSAP guidance reflects discussion and direction from the SAPWG 16, 2017 conference call.

The March 31, 2017, comment deadline is anticipated to allow for discussion during the Spring National Meeting. Commenters are requested to advise if more time is needed.





SSAP No. 55

SSAP No. 65



ASU 2015-09, Financial Services - Insurance - Disclosures about Short-Duration Contracts


Revisions, recommended by interested parties, incorporate additional disclosures from ASU 2015-09 that are not currently captured for statutory. 

The proposed revisions also reject ASU 2015-09 for statutory accounting, with indication that reporting entities shall follow the established statutory accounting disclosures.  


Issue Paper

Special Accounting Treatment for Limited Derivatives Current exposure requests additional information from industry. (Previously exposed Issue Paper and Illustrations included for reference.)

Project Overview - Substantive revisions, for inclusion in a new SSAP, proposing special accounting treatment for certain limited derivatives related to variable annuity products.
2016-13 Appendix F Policy Statement on Coordination with P&P Manual, SVO and VOSTF Revisions to Appendix F to add a policy statement detailing the SAPWG coordination with the VOSTF and SVO.
2016-48 86 Impact of Future Settled Premiums on Option Valuations Revisions to clarify the accounting and reporting of derivative contracts with deferred or financing premiums.
SAPWG Response

IRBC Referral
N/A Referral response to Investment Risk Based Capital Exposure of draft SAPWG response to the IRBC request to review the bond characteristic proposal.
2010-08 Appendix F Policy Statement on Coordination with Valuation Manual Proposes a new policy statement on coordination with the Valuation Manual, which is consistent with the policy statement in the Valuation Manual.
2016-39 SSAP No. 37 Mortgage Loans with Multiple Lenders Clarifies that a reporting entity providing a mortgage loan as a "participant in a mortgage loan agreement" shall consider the mortgage loan in scope of SSAP No. 37.
2016-40 SSAP No. 43R Definition of LBSS Proposed revisions, in accordance with a VOSTF referral, incorporate a revised definition for SSAP No. 43R securities. Comments are specifically requested on the securities that will be included / excluded from the scope of SSAP No. 43R as a result of this definition change.

Additionally, the exposure proposes revisions to SSAP No. 43R to remove old implementation guidance.
2016-41 SSAP No. 26 AVR and IMR in SSAP No. 26 Requested regulators and industry to provide information on current practices for allocating gains and losses between AVR and IMR, as well as information on the recognition of OTTI if the security is sold in the same reporting period in which the OTTI is first identified.
2016-42 Appendix C Appendix C Introduction Updates the introduction of Appendix C in the Accounting Practices and Procedures Manual to promote consistent application of the actuarial guidelines.
2016-43 INT 01-25 Inflation Indexed Securities Clarifies that the guidance in INT 01-25 is limited to direct obligations of the U.S. government.

Also requested information on the volume of foreign inflation-indexed securities held by U.S. insurance reporting entities and whether specific guidance should be developed for these securities.
2016-44 Appendix A-791 Revisions to Appendix A-791 Incorporates additional language from the Life and Health Reinsurance Agreements Model Regulation (#791) to note that the reinsurance agreement shall constitute the entire agreement and that amendments need to be signed by all parties to be effective.
2016-45 SSAP No. 101 ASU 2016-16 Intra-Entity Transfers of Assets Other than Inventory Adopts with modification ASU 2016-16 and requires reporting entities to recognize the income tax consequences of an intra-entity transfer of an asset, other than inventory, when the transfer occurs.
2016-46 SSAP No. 69 ASU 2016-15 – Classification of Certain Cash Receipts and Cash Payments Adopts ASU 2016-15 to improve consistency in reporting, as well as minimize differences between SAP and U.S. GAAP on cash flow classifications.
2016-47 SSAP No. 30,
SSAP No. 48,
SSAP No. 97
ASU 2016-07 – Simplifying the Transition to the Equity Method of Accounting Adopts with modification ASU 2016-07 and provides guidance when an investment qualifies (or no longer qualifies) for the equity method of accounting.


Conference Call
Thursday, March 16, 2017
2:00 p.m. Eastern / 1:00 p.m. Central
Call duration: 90 minutes

2017 Spring National Meeting
Denver, Colorado
Saturday, April 8, 2017
9:00 - 11:30 a.m.

  • Materials not yet available

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 Jan. 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