Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated 5/25/18

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





Issue Paper

Special Accounting Treatment for Limited Derivatives (VAIWG)

Exposed a revised issue paper detailing the special accounting guidance for limited derivatives hedging variable annuity guarantees.


SSAP No. 49
SSAP No. 56

Policy Loans

Exposed revisions to update the guidance for policy loans related to separate account products and to specify that all policy loans related to separate account policies shall be funded in order to be admitted in the general account. Exposure requests comments on an expected future blanks to remove the "contract loan" line from the Separate Account blank.


SSAP No. 43R

Reporting NAIC Designations as Weighted Averages

Exposed revisions to clarify that if a loan-backed or structured security has different NAIC designations by lot, then the reporting entity shall either report the entire investment on a single reporting line with the lowest applicable NAIC designation or report separately by purchase lots aggregated by NAIC designation.


SSAP No. 26R

VOSTF – Bank Loan Referral

Exposed a proposed referral response to the Valuation of Securities (E) Task Force indicating that borrowing base loans and debtor in possession (DIP) financings are collateral loans under SSAP No. 21, and not bank loans under SSAP No. 26R.


SSAP No. 4

Regulatory Transactions
 Referral from the Reinsurance (E) Task Force

Exposed revisions to indicate that items acquired as part of "regulatory transactions" that meet the definition of an asset shall only be admitted with approval of the domestic state insurance department as a prescribed or permitted practice. Comments are requested on whether all "regulatory transactions" shall be reported on Schedule BA – Other Long Term Invested Assets.


SSAP No. 41R

Surplus Note Accounting
Referral from the Reinsurance (E) Task Force

Exposed revisions to indicate that surplus notes linked to other structures are not subordinate and do not qualify for reporting as statutory equity by the issuer. Also identifies that assets linked to issued surplus notes are not available for policyholder claims and shall be nonadmitted.


INT 05-05

Update INT 05-05 Medicare Part D Definitions

Exposed revisions to add a description of the Coverage Gap Discount Program and amend existing guidance on program payments and update definitions.


2018-16 SSAP
No. 1
Summary Investment Schedule Updates Exposed an agenda item with revisions to Appendix A-001 to maintain a breakout between public and nonpublic unaffiliated common stock and to use the current mortgage type categories on Schedule B Mortgages instead of the mortgage payment status.
2018-15 INT 18-03

Additional Elements Under the Federal Tax Cuts and Jobs Act

Exposed an agenda item and draft INT to address the remaining elements from the Tax Cuts and Jobs Act. Items addressed include: 1) Repatriation Transition Tax, 2) AMT Credit, and 3) Global Intangible Low-Taxed Income Tax (GILTI).
2018-08 SSAP
No. 56
Private Placement Variable Annuities Exposed an agenda item to limit the products captured within the scope of that guidance to products that qualify as life insurance under Internal Revenue Code §7702 and for which the insurer holder is not subject to investment risk.
2017-32 Issue Paper

SSAP No. 30—Unaffiliated Common Stock

Exposed an issue paper proposing substantive revisions to SSAP No. 30. Key elements addressed include: 1) Common Stock Definition; 2) Inclusion of Closed-End Funds and Unit Investment Trusts; and 3) Reporting Enhancements on Schedule D-2-2.


Issue Paper

ASU 2017-12, Derivatives and Hedging

Exposed an issue paper detailing the U.S. GAAP revisions from ASU 2017-12 with initial staff assessments. Exposure requests comments on the assessments, the revisions needed to incorporate suggested modifications, and the differences in derivative accounting between SAP and U.S. GAAP that should be retained.


Issue Paper

ASU 2016-13, Credit Losses

Exposed an issue paper that details U.S. GAAP concepts from ASU 2016-13 and identifies possible concepts for statutory accounting consideration. This exposure specifically requests input on other elements that should be assessed as part of an expected credit loss model under statutory accounting.


There are no advance materials at this time.

INT 18-01: Updated Tax Estimates Under the Tax Cuts and Jobs Act (Act)

This interpretation provides a limited-time, limited-scope exception to SSAP No. 9 to not require recognition of changes in reasonable estimates from the Act as Type I subsequent events after the issuance of the statutory financial statements. Additionally, the INT provides instruction for reporting changes in deferred income taxes in the financial statements. This interpretation will be automatically nullified on Dec. 31, 2018.

INT 17-01: Extension of Ninety-Day Rule for the Impact of Hurricane Harvey, Hurricane Irma and Hurricane Maria
This interpretation temporarily extends the 90-day rule per paragraph 6 of SSAP No. 6 for policies impacted by Hurricane and Tropical Storm Harvey, Hurricane and Tropical Storm Irma, Hurricane and Tropical Storm Maria, and related flooding. This interpretation will be automatically nullified on February 16, 2018.

Subsidiary, Controlled or Affiliated (SCA)

Relating SVO Unit Prices to the Fair Value Hierarchy

Structured Securities

Accounting Practices and Procedures Manual

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 April 3, 2018

SAP to Annual Statement Disclosure Checklist Updated for 2017 Annual Statements
Updated 1/16/2018

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.


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.

2018 Charges

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