Exposure Drafts Outstanding
Statutory Accounting Principles Working Group
Last Updated September 19, 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


SSAP No. 22R

ASU 2016-02: Leases

Exposed substantive revisions to incorporate revised GAAP guidance from ASU 2016-02, modified to retain the operating lease concept for statutory accounting.


SSAP No. 68
SSAP No. 97

Goodwill Limitation in SSAP Nos. 68 and 97

Exposed revisions to provide actual examples on the amount of goodwill recognized in comparison to the SCA equity value and request comments on various options on whether to further limit the amount of admitted goodwill and/or improve the identification of goodwill in comparison to the SCA equity value.


SSAP No. 26R

Wholly-Owned Ultra-Short Bond Portfolio in an LLC Series

Exposed a sponsor-submitted agenda item, which recommends that certain limited liability company (LLC) structures be eligible for inclusion in scope of SSAP No. 26R. Comments are requested on the three options to address the agenda item detailed in the NAIC staff recommendation.


SSAP No. 61R  SSAP No. 62R Appendix A-791

Reinsurance Risk Transfer

Exposed revisions to clarify reinsurance contracts risk transfer requirements, provide clarifications that reinsurance accounting credit for contracts which pass risk transfer is only for the amount of risk ceded, and updates terminology. The exposure also requests specific comments on noted issues.



INT 17-01T

Extension of Ninety-Day Rule for the Impact of Hurricane Harvey and Hurricane Irma

Exposes a tentative interpretation allowing an optional temporary 60-day extension of the existing 90-day rule (for a total of 150 days) for policies impacted by Hurricane Harvey and Hurricane Irma. This exposure has been updated to include Hurricane Irma.



SSAP No. 107

High-Cost Risk Pooling in ACA Risk Adjustment

Exposed revisions to provide guidance to report high cost risk pools, which were added to the federal ACA risk adjustment program, similar to an involuntary pool. Comments are also requested on the other alternative accounting approach noted in the agenda item.



Appendix F

Policy on Coordination with the P&P Manual

Re-exposed a new policy statement on coordination with the Purposes and Procedures Manual of the NAIC Investment Analysis Office, SVO and Valuation of Securities (E) Task Force.


SSAP No. 86

Impact of Future Settled Premiums on Option Valuations


Exposed revisions to capture information on financing premiums in derivative contracts (in aggregate and in individual contracts). The exposed disclosures are proposed to be required in a narrative format for year-end 2017, and captured electronically (either in Schedule DB or in a data-captured note) for year-end 2018.



Editorial Process

Exposed revisions to delete transition footnotes for the 2016 year-end and interim 2017 reporting of money market mutual funds and remove Actuarial Guideline 34 and Actuarial Guideline 39 on variable annuities which have not been in effect since 2009 from Appendix C.


SSAP No. 86

Settlement of Variation Margin

Exposed revisions to clarify that variation margin changes (in all instances) shall be recognized as unrealized gains or unrealized losses until the derivative contract has matured, been terminated and/or expired. A Jan. 1, 2018 prospective effective date is proposed for entities that previously recognized changes in variation margin as realized gains/losses.


SSAP No. 12

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

Exposed revisions to adopt with modification ASU 2016-09.


SSAP No. 97

Extension of SCA Filing Deadlines

Exposed revisions to incorporate a 90-day time period to file a Sub 1 after an initial acquisition or formation of an SCA, and an Aug. 31st deadline for Sub 2 filings, with provisions to allow a company a one-month deadline after the audit date for an SCA that regularly receives its audit report after Aug. 31st.


SSAP No. 26R

Bank Loans

Exposed revisions to expand the definition of a “bank loan” to include bank loans directly issued by a reporting entity.


SSAP No. 41R

Surplus Note Discount or Premium

Exposed substantive revisions to reflect the principle that the net balance of a surplus note issued at a discount or zero coupon should never be greater than the amount of cash and liquid admitted assets received.


SSAP No. 92
SSAP No. 102

ASU 2017-07: Improving the Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost


Exposed revisions to reject ASU 2017-07, with a notation that existing statutory disclosures on the components of pension cost shall continue.


Appendix D

ASU 2013-08:  Financial Services—Investment Companies – Amendments to the Scope, Measurement, and Disclosure Requirements

Exposed revisions to reject ASU 2013-08.


SSAP No. 104R

ASU 2017-09: Stock Compensation – Scope of Modification Accounting

Exposed revisions to adopt ASU 2017-09.


SSAP No. 22

ASU 2017-10: Determining the Customer of the Operation Services

Exposed revisions to adopt with modification ASU 2017-10, and clarify the customer of service concession arrangements.


SSAP No. 68
SSAP No. 90

Intangibles ASUs

Exposed revisions to reject five ASUs related to intangibles and incorporate guidance pertaining to triggering events for impairment assessment into SSAP No. 68.


SSAP No. 97

SSAP No. 97 – Foreign Entity Clarification

Exposed revisions that provide a consistency edit that limited statutory adjustments are required for all foreign insurance SCAs (8.b.iv. entities) regardless if they have audited U.S. GAAP or audited U.S. foreign GAAP financial statements.


SSAP No. 41R
SSAP No. 97

Double-Counting of Surplus Notes

Exposed revisions to clarify that the existing concept that restricts the “double-counting” of surplus notes issued by SCAs shall also apply to surplus notes that are issued by the parent and held by an SCA.


SSAP No. 43R

Remove 2009 SSAP No. 43R Implementation Guidance

Exposed revisions to remove outdated transition guidance pertaining to the 2009 substantive revisions, and update the Question and Answer Implementation Guide.



Money Market Mutual Fund Wash Sales

Exposed revisions to clarify that acquisitions and disposals of shares in money market mutual funds are not subject to the wash sale disclosure. Comments are requested on whether an exception to the wash sale disclosure should be considered for all cash equivalents.


SSAP No. 100


Exposed substantive revisions to allow net asset value (NAV) per share as a practical expedient to fair value either when specifically named in a SSAP or when specific conditions exist. This exposure proposes to adopt, with modification, applicable GAAP guidance, allowing consistency in reporting for when FASB allows use of NAV.


IP No. 143R

Guaranty Fund Assessments

Exposed revisions to document substantive changes adopted to SSAP No. 35R—Guaranty Fund and Other Assessments related to assessments for insolvencies of entities that wrote long-term care.



Interested Party Comments – Nov. 28, 2016

ASU 2016-13: Financial Instruments - Credit Losses

Agenda item has been posted to allow for continued industry and regulator review as discussions will resume to consider this ASU. A comment deadline was not established for this item at this time, but comments or discussion points may be submitted to NAIC staff.

In addition to the agenda item, comments originally received from the initial exposure have been posted to facilitate review.


Conference Call
Thursday, Oct. 12, 2017
3:00 p.m. Eastern / 2:00 p.m. Central
Duration: 1.5 hours

  • Materials not yet available

Conference Call
Monday, Nov. 6, 2017
3:00 p.m. Eastern / 2:00 p.m. Central
Duration: 2 hours

  • 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 August 10, 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.


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