Committees & Activities

Statutory Accounting Principles Working Group 
Financial Condition (E) Committee
Accounting Practices and Procedures Task Force

The Statutory Accounting Principles (E) Working Group is responsible for developing and adopting substantive and nonsubstantive revisions to the Statements of Statutory Accounting Principles (SSAPs). Statutory accounting principles provide the basis for insurers to prepare financial statements for financial regulation purposes, and SSAPs are considered level 1 (highest authority) in the statutory accounting hierarchy.

Substantive statutory accounting revisions introduce original or modified accounting principles. Substantive revisions can be reflected in an existing SSAP or a new SSAP. Nonsubstantive statutory accounting revisions are characterized as language clarifications that do not modify the original intent of an SSAP.

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.

The Emerging Accounting Issues (E) Working Group is responsible for responding to questions on the application, interpretation and clarification of statutory accounting principles. Additional information on this Working Group can be obtained via the following link:

2015 Charges

  • Maintain codified statutory accounting principles by providing periodic updates to the guidance that address new statutory issues and new GAAP pronouncements as they develop.—Essential and Ongoing
  • At the discretion of the chair, comment on exposed GAAP pronouncements affecting financial accounting and reporting.—Essential
  • Report its findings relative to these developing issues to the Accounting Practices and Procedures (E) Task Force.—Essential
  • Contribute the perspective and expertise of the Working Group via the chair, or his/her representative, to the development of NAIC regulatory guidance for any security under review by the Invested Assets (E) Working Group of the Valuation of Securities (E) Task Force. (Upon notice that a class of securities has been placed under regulatory review, the chair of Statutory Accounting Principles (E) Working Group, or his/her representative, will be deemed a member of the Invested Assets (E) Working Group.)—Essential
  • Provide comments on issues related to evaluating and/or implementing to International Financial Reporting Standards (IFRS) for possible U.S. statutory accounting use and provide input on the solvency modernization project as it relates to accounting and reporting issues.—Essential and Ongoing
  • 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.—Essential and Ongoing
  • Develop the proposed definition for “Primary Security” for use in the Principle-Based Reserving Implementation (EX) Task Force’s future consideration of a proposed XXX/AXXX Reinsurance Model Regulation.—Essential
  • Develop a Note to the Audited Financial Statements regarding compliance with the XXX/AXXX Reinsurance Model Regulation—Essential

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

Exposure Drafts Outstanding
Statutory Accounting Principles Working Group
Last Updated August 18, 2015

Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to, and

Ref No.

Issue Paper/ SSAP No./ Appendix





SSAP No. 26

Exposure: Questions Raised on BlackRock's "Calculated" Amortized Cost Valuation Proposal

Blackrock Comment Letter
(May 26, 2015)

Inquiries on the BlackRock proposal may be sent to Katie Garvey: However, all comments on the questions / discussion items included in the exposure document shall be submitted to NAIC SAPWG staff.


The Working Group exposed questions raised in contemplation of evaluating BlackRock's "calculated" amortized cost valuation proposal.

The Working Group directed NAIC staff to work with BlackRock and others to obtain information regarding these items and draft tentative responses. (The BlackRock Comment Letter, which includes the proposal, is provided as a supplement to the exposure.) In addition to the vendor and industry questions, which have been combined in the exposure document, three discussion questions from NAIC staff are detailed on pages 4-5.



Issue Paper No. 151

Revisions to Measurement Method for Surplus Notes

Substantive revisions to the measurement method for holders of non-rated surplus notes and surplus notes with designations below NAIC 1. Requests comments on specific discussion points, including whether the use of amortized cost should be expanded.


SSAP No. 26

Prepayment Penalties and Amortization on Callable Bonds

Nonsubstantive revisions to clarify the yield-to-worst concept for callable bonds.


SSAP No. 97

Nonadmitted Assets and Application of the SAP Guidance

Nonsubstantive revisions to: 1) clarify accounting for non-insurance SCAs; 2) add disclosure of permitted or prescribed practices for insurance SCAs; and 3) clarify adjustments for non-insurance SCAs meeting the revenue and activity test.


SSAP No. 15

ASU 2015-03: Simplifying the Presentation of Debt Issuance Cost

Nonsubstantive revisions to reject ASU 2015-03 and maintain the current guidance for debt issuance costs.


SSAP No. 92
SSAP No. 102

ASU 2015-04: Practical Expedient for the Measurement Date of An Employer’s Defined Benefit Obligation and Plan Assets

Nonsubstantive revisions to include guidance regarding interim re-measurement of plan assets and benefit obligations due to a significant event and adopt, with modification, ASU 2015-04.


SSAP No. 26 and SSAP No. 43R

Measurement Method for NAIC 5 Designations

Nonsubstantive revisions to require investments with an NAIC 5 designation held by a reporting entity that maintains an AVR to be reported at the lower of amortized cost or fair value.


Appendix F

Policy Statement Revisions – Membership and Roles of SAPWG

Revisions propose to disband the Emerging Accounting Issues (E) Working Group, with the Statutory Accounting Principles (E) Working Group incorporating a new process to issue interpretations and to increase its membership by two. Additionally, other proposed revisions reflect changes to reflect current SAPWG processes.  


SSAP No. 55

Clarification of Accounting Treatment for Fees Incurred for Salvage/Subrogation Recoveries

Nonsubstantive revisions to clarify that fees incurred for salvage and subrogation recoveries shall be reported gross, regardless of whether the fees are paid to third parties or processed internally.


SSAP No. 26

Prepayment Penalties and Presentation of Callable Bonds

Exposed three options for the accounting and reporting treatment of prepayment penalties: 1) investment income, 2) realized capital gains, subject to IMR and 3) realized capital gains, excluded from IMR.


SSAP No. 23

Foreign Currency Translation for Canadian Insurance Operations

Nonsubstantive revisions to clarify the optional accounting treatment for translation of Canadian Insurance Operations.


SSAP No. 97

Inclusion of Filing Guidance

Nonsubstantive revisions to incorporate a new disclosure and incorporate the filing process for SCA investments from the Purposes and Procedures Manual of the NAIC Investment Analysis Office.


SSAP No. 97

ASU 2011-10: Derecognition of in Substance Real Estate

Nonsubstantive revisions to reject ASU 2011-10.


SSAP No. 1

Quarterly Reporting of Investment Schedules

Exposed agenda item with a request for quarterly investment proposals identifying what should be captured, and the form of such submissions, that considers both cost concerns and regulatory benefits.


Appendix A


Revisions to the Accounting Practices & Procedures Manual Preamble

Nonsubstantive revisions to the Preamble to: 1) restructure to clarify historical guidance, 2) include the preamble within level 4 of the SAP Hierarchy, and 3) add a narrative reference to INT 00-20.


SSAP No. 55

Title Note 25 and SSAP No. 55

Nonsubstantive revisions to provide title specific language to the quarterly disclosure of changes to reserve and loss adjusting expense liabilities for events covered in prior years.


SSAP No. 107

SSAP No. 107 Revisions – Premium Adjustments Subject to Redetermination

Nonsubstantive revisions regarding contracts subject to redetermination, which are consistent with recent revisions adopted in SSAP No. 54.


Various SSAPs

Non-Recourse Charity Notes

Substantive concept exposure requests comments on the structure of transactions that could be considered in-scope and proposals to clarify the accounting and reporting.


SSAP No. 97

Application of Equity Method

Nonsubstantive revisions to clarify the guidance in paragraphs 10-12 related to application of the equity method.


SSAP No. 78

Aging and Revenue Recognition of Multi-Peril Crop policies

Nonsubstantive concept exposure to collect information regarding any needed updates to SSAP No. 78 and the intent to develop clarifying language regarding: 1) the use of the billing date for application of the 90-day rule; 2) defining the processing date or updating the term; 3) providing more specificity regarding the period of risk for purposes of earning revenue; and 4) developing a glossary of terms including dates that are specific to the federal crop programs.


SSAP No. 1

Insurance-Linked Securities Disclosure

Nonsubstantive concept exposure to collect information regarding the use of insurance-linked securities by both insurers and reinsurers, with an example template of what may be requested for disclosure.


SSAP No. 65

Proposed Disclosure Regarding High Deductible Policies

Nonsubstantive revisions to capture information regarding recoverables from policyholders under high deductible policies.


SSAP No. 61R

Variable Annuity Captive Disclosures

Nonsubstantive revisions to capture information regarding reinsurance agreements with affiliated captive reinsurers.



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

Exposed agenda item requesting comments on the GAAP disclosures for short-duration insurance contracts and whether revisions to statutory accounting disclosures should be considered

MA Review

2001-21 Redundant Paragraphs in SSAP No. 54 and Appendix A-585
2003-01 Investments in Guaranteed Investment Contracts
2004-17 Clarification of Accounting and Reporting Guidance for Financial Instruments Used to Hedge Options Embedded in Variable Annuity Guarantees (Guaranteed Minimum Death Benefits and Guaranteed Living Benefits)
2008-21 Accident and Health Claims with multiple dates of service
2007-25 FAS 159:  The Fair Value Option for Financial Assets and Financial Liabilities

This Memo reviews older agenda items with recommendations to either dispose the agenda item without revisions to SAP or to reject as not applicable.

Dispose: 2001-21, 2003-01, 2004-17, and 2008-21.

Reject as N/A: 2007-25

*Please forward all comment letters to, and


Conference Call Calendar

NAIC conference calls & interim meetings are available on the NAIC Conference Call Calendar. See NAIC's revised policy statement on open meetings.

Conference Call
Monday, Oct. 19, 2015
3:00 p.m. Eastern/2:00 pm. Central/1:00 p.m. Mountain/12:00 noon Pacific/11:00 a.m. Alaska/9:00 a.m. Hawaii
Call duration: 1 hour

  • Materials not yet available
Conference Call Calendar

Introduction to
Statutory Accounting Principles
Two-Week Online Self-Study Course

documents and resources
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 for NAIC staff 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 September 2015

SAP to Annual Statement Disclosure Checklist Updated for 2014 Annual Statements

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
Related NAIC Publications
Draft meeting minutes are available free for meeting attendees 10 business days after a national meeting concludes, using the User ID and Password supplied by the NAIC. Regulators may access minutes via StateNet.
Final committee minutes and Proceedings of the NAIC are available to non–attendees, after adoption at the next national meeting, for free in the PDF format through the NAIC Products & Services website.

Accounting Practices and Procedures Manual

Annual and Quarterly Statement Instructions

States' Prescribed Differences from NAIC Statutory Accounting Principles

Media queries should be directed to the NAIC Communications Division at 816-783-8909 or
Julie Gann
Senior Manager - Accounting and Reporting
Phone: 816-783-8966
Fax: 816-460-7821
Robin Marcotte
Sr. Manager, Accounting
Phone: 816-783-8124
Fax: 816-460-7571
Josh Arpin
Statutory Accounting and Reinsurance Policy Advisor
Phone: 816-783-8481
Fax: 816-460-7654
Please see the current Committee List for a complete list of committee members.