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. 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

  5. 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

  6. 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

  7. 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

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

  9. 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

  10. 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

  11. 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:

Adopted Revisions
Statutory Accounting Principles Working Group
Last Updated: December 16, 2015

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

Exposure Drafts Outstanding
Statutory Accounting Principles Working Group
Last Updated April 6, 2016

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

NOTE: All items have a comment deadline of May 20, 2016, with the exception of agenda item 2016-03, which has an extended comment period ending June 5, 2016.

Ref No. Issue Paper/ SSAP No./ Appendix Title Description
ETF Exposure SSAP No. 26 Investment Classification Project: SVO-Identified ETFs in SSAP No. 26 Exposed draft revisions to SSAP No. 26—Bonds to incorporate revised guidance for SVO-Identified Exchange Traded Funds (ETFs)
2016-03 Variable Annuities Special Accounting Treatment for Limited Derivatives Exposed agenda item with a request for comment on concepts for a “special accounting provision” drafted in response to the charge to consider “hedge accounting treatment” for certain limited derivatives related to variable annuity products that do not meet hedge effectiveness requirements. 
2015-21 SSAP No. 55 Clarification of Accounting Treatment for Fees Incorrect for Salvage/Subrogation Recoveries Nonsubstantive revisions proposed by interested parties to clarify the reporting of salvage and subrogation expenses.
2015-25 SSAP No. 97 Inclusion of Filing Guidance Nonsubstantive revisions propose a new appendix detailing the subsidiary, controlled and affiliated entities filing process.
2015-27 Investment Schedules Quarterly Reporting of Investment Schedules Exposure details alternatives for quarterly investment reporting offered by interested parties. This agenda item is considering reporting revisions to expand investment information received in the interim.
2015-46 SSAP No. 3 Correction of an Error Clarification Nonsubstantive revisions clarify that guidance in SSAP No. 3 pertains to accounting errors and shall not preclude companies from amending their annual or quarterly financial statement filings due to reporting errors. Exposure also includes interested parties’ comments and the NAIC staff response.
2015-51 SSAP No. 86 Definition of Notional Nonsubstantive revision proposes the definition of “notional,” reflecting language suggested by the industry.
2015-52 SSAP No. 1 Clarification of Permitted Practice Disclosure Nonsubstantive revisions clarify the disclosure requirements for prescribed or permitted practices.
2016-02 SSAP No. 22 Leases Exposed substantive agenda item with a request for comments on different statutory accounting options for leases.

SSAP No. 26

SSAP No. 30
Removal of the Class 1 List from the P&P Manual Nonsubstantive revisions in response to the removal of the Class 1 Money Market Mutual Fund List from the P&P Manual.
2016-06 SSAP No. 26
SSAP No. 30
SSAP No. 32
SSAP No. 43R
SSAP No. 100
Financial Instruments Nonsubstantive revisions reject ASU 2016-01 while requesting comments on whether elements in ASU 2016-01 should be considered for statutory accounting.
2016-13 Appendix F Appendix F – Policy Statement on Coordination with P&P Manual, SVO and VOSTF Nonsubstantive revisions propose a new policy statement detailing coordination with the P&P Manual and the Valuation of Securities (E) Task Force.
*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
Thursday, June 9, 2016
11:00 a.m. Eastern / 10:00 a.m. Central / 9:00 a.m. Mountain / 8:00 a.m. Pacific / 7:00 a.m. Alaska / 6:00 a.m. Hawaii
Call duration: 90 Minutes

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 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 12, 2016

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
Sr. Accounting and Reinsurance Policy Advisor
Phone: 816-783-8481
Fax: 816-460-7654
Fatima Sediqzad
SCA Valuation & Accounting Policy Advisor
Phone: 816-783-8894
Fax: 816-460-7548
Please see the current Committee List for a complete list of committee members.