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, 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. SSAP’s 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.

2016 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 as they develop.—Essential and Ongoing

  2. At the discretion of the chair, comment on exposed GAAP pronouncements affecting financial accounting and reporting.—Essential

  3. Report its findings relative to these developing issues to the Accounting Practices and Procedures (E) Task Force.—Essential

  4. 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

  5. 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

  6. 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, and other valuation manual requirements. This process will include the receipt of periodic reports on changes to the valuation manual on items that require coordination as well as the development of an accounting mechanism to address reserve volatility.—Essential and Ongoing

  7. 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 states have prescribed statutory accounting that differs from the guidance issued by the NAIC. Utilize this information to consider possible changes to statutory accounting.—Essential

  8. Develop and adopt changes to SSAP No. 86—Accounting for Derivative Instruments and Hedging Activities, with an effective date of Jan. 1, 2017, or earlier, which allow hedge accounting treatment under SSAP No. 86 for certain limited derivative contracts (e.g., interest rate hedges with counterintuitive effects) that otherwise do not meet hedge effectiveness requirements. In adopting such an allowance, consider if the requirement to meet hedge effectiveness can be replaced by some other information that demonstrates strong risk management is in place over the identified hedges.—Essential

  9. Finalize public disclosure on variable annuity risks as developed by the Variable Annuities Issues (E) Working Group.—Essential

  10. Consider whether current or future changes to reserves resulting from implementation of the Variable Annuities Framework will be reported in the Annual Statement as a “Change in basis.”—Essential

  11. Provide authoritative guidance on current statutory accounting issues, generally relating to application, interpretation and clarification of existing statutory accounting principles, by conducting meetings at NAIC national meeting sites and other meetings and conference calls when necessary.—Essential and Ongoing

  12. Evaluate individual statutory accounting issues based on its established timeline and report its findings to the Accounting Practices and Procedures (E) Task Force.—Essential and Ongoing

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

Exposure Drafts Outstanding
Statutory Accounting Principles Working Group
Last Updated Nov. 24, 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 Title Description
DEC. 8, 2015
(Comments are Requested by Noon Central if Feasible)
2015-08 SSAP No. 97 Nonadmitted Assets and Application of the SAP Guidance Nonsubstantive revisions to  clarify accounting for SCAs; and clarify adjustments for non-insurance SCAs meeting the revenue and activity test.
2015-44 A-695 Model 695 updates to Appendix A Nonsubstantive revisions to reflect changes previously adopted by the Life Insurance and Annuities (A) Committee.
2015-53 SSAP No. 61R Disclosure of XXX/AXXX Reinsurance Framework Impact on RBC Disclosure of captive framework impact on RBC developed by the Principle-Based Reserving Implementation (E) Task Force for year end 2015
JAN. 15, 2016
2015-54 SSAP No. 107 Update Risk Corridors Disclosures Nonsubstantive revisions to update the disclosures regarding ACA risk corridors program
Feb. 5, 2016
2013-36 SSAP No. 26 Investment Classification Review

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.

Working Group directed NAIC staff to continue working with issuers, vendors and industry regarding questions raised in contemplation of evaluating BlackRock's "calculated" amortized cost valuation proposal.

Tentative responses from the prior exposure are reflected in the updated exposure document.


Issue Paper No. 151

SSAP No. 41R

Valuation for Holders of Surplus Notes

Concurrent exposure of an Issue paper and draft SSAP No. 41R detailing substantive revisions for the holder’s valuation of surplus notes.

2014-28 Issue Paper 153 Asbestos and Pollution Reinsurance Reporting Exception Issue paper providing historical documentation of changes adopted for certain asbestos and pollution reinsurance contracts.

Comment deadline updated 2-5-16

2015-02 Issue Paper No. 152 Short Sales Substantive revisions to incorporate accounting guidance for short sales and secured borrowing transactions.
2015-19 SSAP No. 1 & Annual Statement Quarterly Reporting of Restricted Assets Nonsubstantive revisions to clarify that disclosure of restricted assets shall be included in the annual financial statements, and in the interim financial statements if significant changes have occurred since the annual statement.
2015-21 SSAP No. 55 Clarification of Accounting Treatment for Fees Incurred for Salvage/Subrogation Recoveries Exposed agenda item with a request for comments on the updated issues noted within the “2015 Fall National Meeting Discussion” regarding the reporting of subrogation expenses.
2015-23 SSAP No. 26

SSAP No. 43R

Various Reporting Tools
Prepayment Penalties and Presentation of Callable Bonds – Bifurcation of Agenda Item 2015-04 Nonsubstantive revisions clarify the appropriate reporting of prepayment penalties.
2015-27 Investment Schedules Quarterly Reporting of Investment Schedules Exposed proposal for quarterly investment reporting. This proposal  suggests quarterly, electronic-only data as an NAIC supplemental filing that includes the CUSIP, par value, book adjusted carrying value and fair value for Schedule D investments.
2015-38 N/A in Appendix D ASU 2015-12 – Plan Accounting: Defined Benefit Pension Plans (Topic 960); Defined Contribution Pension Plans (Topic 962); and Health and Welfare Benefit Plans (Topic 965) Nonsubstantive revisions to reject ASU 2015-12 as not applicable.
2015-39 N/A in Appendix D ASU 2015-13 – Application of the Normal Purchases and Normal Sales Scope Exception to Certain Electricity Contracts within Nodal Energy Markets Nonsubstantive revisions to reject ASU 2015-13 as not applicable.
2015-40 SSAP No. 15 ASU 2015-15 – Presentation and Subsequent Measurement of Debt Issuance Costs Associated with Line-of-Credit Arrangements Nonsubstantive revisions to reject ASU 2015-15 and maintain the current accounting treatment for debt issuance costs.
2015-41 SSAP No. 26

SSAP No. 43R

5*/6* Securities Exposed agenda item requests comments on whether revisions are needed to statutory accounting if the SVO no longer provides a designation of 5* investments after reviewing insurer self-certifications. With the proposal, insurers will self-designate with disclosure in a general interrogatory.
2015-42 N/A in Appendix D ASU 2015-11: Inventory (Topic 330)—Simplifying the Measurement of Inventory Nonsubstantive revisions to reject ASU 2015-12 as not applicable.
2015-43 SSAP No. 86 EITF 99-02: Accounting for Weather Derivatives Nonsubstantive revisions to incorporate the definition of a weather derivative and adopt, with modification, EITF 99-02 to require weather derivatives to be reported and valued consistently with other derivatives.
2015-45 SSAP No. 26  Schedule D Reporting ETF Reporting in Investment Schedules Exposed two nonsubstantive options to modify the reporting of SVO bond-designated ETFs and Class-1 bond mutual funds.
2015-46 SSAP No. 3 Correction of an Error Clarification Nonsubstantive revisions to clarify guidance for filing amended financial statements as a result of material accounting errors and for  reporting errors.
2015-48 Updates to  Appendix D Review of Pending FAS 133 EITF’s Nonsubstantive revisions to identify that EITF 98-10, 99-1, 99-3 and 00-7 are rejected as not applicable and to update EITF 98-12 to reference the review of FAS 150.
2015-49 SSAP No. 97 Explicitly Excluding ETFs from SCA Guidance Nonsubstantive revisions to clarify that ownership in an ETF or mutual fund does not represent ownership in an underlying entity (as an SCA) unless ownership of the ETF actually represents control per SSAP No. 97.
2015-50 N/A in Appendix D ASU 2014-06: Technical Corrections and Improvements Related to Glossary Terms

“Chart of Corrections”
(This chart details the FASB revisions and SAP status)

Nonsubstantive revisions to reject ASU 2014-16 as not applicable to statutory accounting.
2015-51 SSAP No. 86 Definition of Notional Nonsubstantive revisions to incorporate a definition of “notional principal.”

Requests involvement by those with derivative experience in reviewing the proposed definition, and with the subsequent review of the impact to SSAPs and reporting instructions.

2015-52 SSAP No. 1


A/S Reporting Instructions
Clarification of Permitted Practice Disclosure   Nonsubstantive revisions to clarify the guidance and reporting requirements for permitted and prescribed practices
*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, Feb. 22, 2016
11:30 a.m. Eastern / 10:30 a.m. Central / 9:30 a.m. Mountain / 8:30 a.m. Pacific / 7:30 a.m. Alaska / 6:30 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
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 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 December 2015

SAP to Annual Statement Disclosure Checklist Updated for 2015 Annual Statements
Updated 1/27/2016

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.