Jt. Conference Call of Variable Annuities Working Group & C-3 Phase II/AG 43 Subgroup
Wednesday, February 14, 2018
2:00 pm ET/1:00 pm CT

Please submit comments to Dan Daveline by COB, March 2, 2018. The Working Group intends to schedule an all-day meeting at the NAIC Spring National Meeting at which time the Working Group will begin discussing formal comments. To assist in organizing comments for that meeting, please organize your comments as follows:

VA QIS II Recommendations vF

Revised AG 43 (REDLINE on ORIGINAL) vF


  1. Start each of your comments with a reference to the Recommendation (e.g. 1-28 as shown on page 7 and 8) as used in the attached PowerPoint from Oliver Wyman;
  2. For each comment you submit, please provide an alternative recommendation that would address the rational equally better if not in an improved way (Note, OW has a rational for each of its 28 recommendations as shown on pages 21-56 of the Powerpoint from Oliver Wyman). Please provide your own rational for why your suggestion is better;
  3. For the redline changes to the AG and RBC, feel free to incorporate you proposed comments. However, understand the Working Group may choose to first focus on conceptual changes and only later modify the language;


Related NAIC Publications


Variable Annuities Issues (E) Working Group


2018 Charges

The Variable Annuities Issues (E) Working Group will:

  1. Oversee the NAIC's efforts to study and address, as appropriate, regulatory issues resulting in variable annuity captive reinsurance transactions. Complete by the 2018 Fall National Meeting

  2. Develop a model guideline that represents narrowly defined statutory language the states may use in removing the limitations that may exist within their investment statutes that may otherwise limit the extent of hedges an insurer may use in its risk management. Complete by the 2018 Fall National Meeting

  3. Consider proposed changes to the statutory framework designed to reduce the level and volatility of the non-economic aspect of current reserve and risk-based capital (RBC) requirements and refer to the C-3 Phase II/AG 43 (E/A) Subgroup once overall policy decisions are made and finalization of actual proposed changes are ready for consideration. Complete by the 2018 Fall National Meeting