Insurance Spotlight — NAIC Accounting Update: 2026 Summer National Meeting (September 17, 2026)

Introduction

On August 12, 2026, as part of the National Association of Insurance Commissioners (NAIC) 2026 Summer National Meeting held on August 10–14, 2026, in Columbus, Ohio, the NAIC Statutory Accounting Principles (E) Working Group (SAPWG) met to continue work on its focus areas. SAPWG is the working group within the NAIC that maintains revisions to the NAIC’s Accounting Practices and Procedures Manual (the “AP&P Manual”). The AP&P Manual contains guidance for insurers on preparing financial statements for financial regulation purposes.

This Insurance Spotlight highlights key statutory accounting topics discussed by SAPWG at the NAIC 2026 Summer National Meeting. A comprehensive list of SAPWG agenda items that were adopted, exposed for public comment, or deferred during the meeting or the preceding interim period can be found in the Appendix.

Interest Maintenance Reserve

SAPWG continued refining its proposed long-term revisions to SSAP No. 7,1 which are the main focus of Agenda Item 2023-14. The proposed revisions, which were originally exposed on April 20, 2026, include the following key changes to existing interest maintenance reserve (IMR) guidance:

Aligning the identification of interest-related realized gains and losses with the NAIC hierarchy of 20 bond designation categories and making the group amortization method, which is currently an optional amortization method, mandatory.
Requiring insurers to immediately recognize realized losses resulting from known liquidity sales (i.e., sales of investments in which the proceeds are not reinvested into fixed-income investments).
Requiring insurers to complete a “proof of reinvestment” template to show that the proceeds from the sale of fixed-income instruments that generated a deferred realized loss have been reinvested into new fixed-income instruments with a higher yield.
Clarifying the guidance on deferral and recognition of gains and losses resulting from accounting-effective hedging derivatives and certain replication transactions.
Adding more explicit guidance on the treatment of the IMR in reinsurance transactions (e.g., modified coinsurance [“modco”] and funds withheld [“FWH”] transactions) and eliminating the concept of hypothetical IMR.
Expanding the disclosure requirements and updating certain Annual Statement schedules.

Note that this is not a complete list of proposed changes. Readers are encouraged to read the reproposal of revised SSAP No. 7 2 and the accompanying updated draft issue paper.

The discussion at the NAIC 2026 Summer National Meeting was mainly focused on discussing comment letters received from interested parties.

The principal development was the deferral of the proposed effective date of revised SSAP No. 7 from January 1, 2027, to January 1, 2028. In addition, SAPWG adopted an amendment providing that INT 23-013 will remain effective through December 31, 2027. INT 23-01 was originally adopted as a short-term solution while the substantive update to SSAP No.7 was being drafted. It was initially intended to apply only to 2023 and 2024 reporting, but its period of effectiveness has since been extended multiple times. Accordingly, insurers will apply the existing guidance in INT 23-01 for the years ending (1) December 31, 2026, and (2) December 31, 2027.

Regulator discussion then focused on whether the proposed safeguards, including the 10 percent of adjusted capital and surplus limitation, were sufficient to support admission of net negative IMR. Key areas of concern included the effectiveness and auditability of the proof-of-reinvestment template, the interaction of admitted negative IMR with principles-based reserving and asset adequacy or cash flow testing, and the risk that insurers could increase negative IMR without demonstrating appropriate reinvestment activity. Regulators also discussed implementation risks related to insurer and vendor systems, data availability, testing, and reporting.

Interested parties agreed to work with members of SAPWG to demonstrate the effectiveness of the proposed safeguards with hopes of removing or increasing the 10 percent cap. The draft revised SSAP No. 7 remained in the exposure phase and was not adopted.

Next Steps

Insurers should monitor the next exposure and begin assessing the operational impact of the proposed requirements, including, but not limited to, those related to (1) the data needed to complete the “proof of reinvestment” disclosure, (2) controls over identification of known liquidity sales, (3) reconciliations of actuarial asset adequacy tests, and (4) reinsurance-related IMR activity.

Fair Value Disclosures

During the NAIC 2026 Summer National Meeting, SAPWG reexposed Agenda Item 2026-06 upon receiving a referral from the Investment Analysis (E) Working Group. First exposed on May 18, 2026, Agenda Item 2026-06 contains a proposed revision to SSAP No. 1004 that would remove the existing exclusion for equity method investments from the aggregate fair value disclosure for financial instruments, thereby requiring the disclosure to include investments within the scope of SSAP No. 485 and SSAP No. 97.6 Regulators indicated that they believe the revision is necessary to eliminate reporting questions, improve consistency, and provide a more complete view of insurers’ investment exposures because fair values for these investments are already reported on Schedule BA but are exempted from the aggregate fair value disclosures. Regulators also noted that the existing disclosures, adopted largely in 2009, provide limited information about investments measured and reported at fair value and do not allow regulators to readily assess aggregate changes in Level 3 fair values without separately aggregating Schedule BA data.

However, various commenters urged SAPWG to take a more targeted approach rather than apply the change uniformly to all equity method investments. In comments, interested parties identified three types of equity-method investments that should be considered separately:

Operating entities such as insurance, service, investment, and other companies that are operating business entities.
Equity method investments that (1) hold interests in entities that apply the accounting guidance in ASC 9467 and (2) are generally carried at fair value.
Other equity investments, such as interests in limited partnerships (LPs) and limited liability companies (LLCs) that hold real estate and other assets.

These commenters raised concerns that obtaining fair values for operating entities could be costly and impracticable, is not generally required under U.S. GAAP, and could create competitive concerns if publicly disclosed. Although the commenters viewed reported equity values as a potentially appropriate fair value proxy for entities that are subject to ASC 946, they requested further consideration of the scope, materiality, practicability, and valuation challenges associated with real estate and other investments.

If adopted, the revision already proposed by SAPWG and any additional revisions proposed on the basis of feedback from stakeholders would become effective on December 31, 2026. Because the existing disclosure illustration permits variable reporting lines, implementation would not require an immediate Annual Statement template change; however, a blanks proposal would be developed to explicitly identify investments disclosed under SSAP No. 48 and SSAP No. 97. NAIC staff also recommended reviewing the Annual Statement Instructions to ensure that all references to “fair value” are used in a manner consistent with the term’s definition in SSAP No. 100. Additional revisions to the broader fair value disclosures may be considered in future projects on the basis of regulator and industry feedback.

Next Steps

Insurers should monitor the status of the exposure and assess the reliability of the current fair value disclosures on Schedule BA. Insurers may consider classifying equity method investments into the three categories noted by interested parties and begin considering the feasibility of obtaining fair value estimates that would be in compliance with SSAP No. 100 as potentially revised.

Beyond fair value disclosures, SAPWG has an ongoing project, Agenda Item 2025-26, that requested comments on various aspects of the equity method of accounting, including (1) the timing of recognition of equity value increases and declines, (2) goodwill and negative goodwill, (3) income recognition, (4) impairment, and (5) disclosures on Schedule BA. SAPWG indicated that it would propose additional revisions to SSAP No. 48 at the NAIC 2026 Fall National Meeting. In preparation for potential changes to guidance, insurers should ensure that they have a full understanding of their equity method investment portfolio, including the impact of the equity method of accounting on financial reporting and risk-based capital (RBC).

Insurance Company–Owned Life Insurance

SAPWG exposed Agenda Item 2026-08 to reconsider the reporting of amounts realizable under qualifying insurance company–owned life insurance (ICOLI) policies. Under current guidance in SSAP No. 21,8 these amounts are reported on the statutory balance sheet in the aggregate write-in line as admitted “other-than-invested assets” and are therefore not subject to an RBC charge for life insurers. The SAPWG proposal responds to the growth of ICOLI holdings — particularly amounts invested through vehicles holding Schedule BA–type assets — and requests comments on whether the amounts should instead be reported on Schedule BA under a new “Realizable Amounts Under ICOLI Policies” category, with additional detail regarding underlying investments.

The proposal would build on, rather than replace, the guidance adopted in Agenda Item 2018-08. That guidance established the scope criteria, including compliance with IRC Section 7702,9 ownership and control of the policy, and acquisition primarily to address employee-benefit or key-person risks. It also retained the existing measurement approach and required disclosure of cash surrender value held within investment vehicles by investment category while declining to exclude ICOLI products containing investment risk. Agenda Item 2026-08 does not propose changes to those eligibility or measurement requirements; instead, it focuses on enhanced reporting and whether the underlying investment exposure should result in different RBC treatment.

Next Steps

Insurers should monitor the development of Agenda Item 2026-08 and assess the potential impact of enhanced reporting and RBC requirements on existing ICOLI arrangements. In the interim, insurers should confirm that (1) ICOLI balances reported as other-than-invested assets reconcile to related disclosures and (2) evaluate whether they have access to the underlying investment information that may be required if the proposal is adopted. Companies with significant exposure to investment vehicles or Schedule BA–type assets should also consider the potential implications for statutory reporting, RBC, and data-collection processes. Comments on the exposure are due by October 2, 2026.

Appendix

The tables in the sections below summarize SAPWG agenda items adopted, exposed for public comment, or deferred during the NAIC 2026 Summer National Meeting or the preceding interim period. New statutory accounting principle (SAP) concepts, which are changes in accounting principles or in the method of applying those principles, have explicit effective dates as documented below. All SAP clarifications, which are changes that clarify existing accounting principles, are effective upon adoption unless otherwise noted.

Agenda Items Adopted

SAPWG did not adopt any new SAP concept items during the NAIC 2026 Summer National Meeting. However, SAPWG adopted the following SAP clarification items as final during the meeting or the preceding interim period:

Reference No.	Relevant Guidance	Insurance Type	Revisions Adopted	Financial Statement Impact	Disclosure	Effective Date
2025-27	SSAP No. 1, Accounting Policies, Risks & Uncertainties, and Other Disclosures	Property and casualty (P&C) Life Health	“SSAP No. 1 Modco/FWH Code” Restricted asset disclosure revisions were adopted to separately disclose assets held under modco and FWH reinsurance arrangements. This update was made to align SSAP No. 1 with updates to Annual Statement footnote 5L(1) adopted in 2025. Previously, SAPWG proposed revisions that would also add reporting code categories within the investment detail schedules for modco assets, FWH assets, and collateral assets received and recognized on the balance sheet. However, action on the proposed reporting codes was deferred to further assess retention of restricted asset codes in the Annual Statement.	No	Yes	May 18, 2026
2026-05	SSAP No. 1, Accounting Policies, Risks & Uncertainties, and Other Disclosures	P&C Life Health	“Securities Lending Restricted Asset Reporting” Revisions clarify the disclosure for collateral associated with securities lending transactions related to the asset lent by the reporting entity that is still reported on the financial statements. Recommendations to the Blanks (E) Working Group and the Capital Adequacy (E) Task Force provided for Annual Statement and RBC reporting, respectively.	No	Yes	August 12, 2026
2026-03EP	SSAP No. 15, Debt and Holding Company Obligations SSAP No. 52, Deposit-Type Contracts Various other SSAPs	P&C Life Health	“Editorial and Maintenance Update” Replacement of “CUSIP” with “Security Identifier.” Addition of “U.S.” before references to “generally accepted accounting principles” or “GAAP.” Removal of the word “funding” from the beginning of the paragraph describing Federal Home Loan Bank agreements.	No	No	May 18, 2026
2026-01	SSAP No. 52, Deposit-Type Contracts	P&C Life Health	“Disclosure of FABNs and Similar Structures” This agenda item is related to a referral from the Macroprudential (E) Working Group regarding funding agreement–backed notes (FABNs). Revisions include recommended disclosures, as well as a glossary of funding agreement–backed structures. The disclosures capture all funding agreements that back special-purpose vehicle (SPV) issuances, by the following types: FABNs. Funding agreement–backed commercial paper. Funding agreement–backed repurchase agreements. Funding agreement–backed loans. Funding agreements issued into muni prepay structures. Other funding agreements backing SPV issuances. The following information is required by type of structure: Balance. Existence of a put feature or embedded option. SPV issuance that differs from the corresponding funding agreement. Book-adjusted carrying value of pledged collateral. Narrative description of terms that differ from those in the corresponding funding agreement. Maturity distribution. Whether issued in non-U.S. currency and whether hedged.	No	Yes	May 18, 2026
2025-22	SSAP No. 61, Life, Deposit-Type and Accident and Health Reinsurance	Life Health	“IMR Impact to Reinsurance Collateral” This agenda item is related to both unauthorized and certified reinsurers for which collateral is required for the ceding company to receive reserve credit. The amount of the collateral required is affected by IMR derecognized by the cedent. The Reinsurance (E) Task Force noted agreement with the “asymmetrical method,” under which derecognized net positive IMR is included in, but derecognized net negative IMR is excluded from, the collateral requirement calculation regardless of the terms in the reinsurance treaty. Consequently, SAPWG adopted the following clarifications: Include all net positive IMR derecognized as a result of the reinsurance transactions. Exclude net negative IMR derecognized as a result of the reinsurance transaction.	Yes	No	August 12, 2026
2023-14	INT 23-01, Net Negative (Disallowed) Interest Maintenance Reserve	Life	“SSAP No. 7 — Asset Valuation and Interest Maintenance Reserve” Adopted an amendment providing that INT 23-01 will remain effective through December 31, 2027, with nullification on January 1, 2028.	Yes	Yes	August 12, 2026
2026-07	Annual Statement	Life Health	“Referral on AVR Affiliated Common Stock” Adopted recommended Annual Statement and instruction changes for subsidiary, controlled, and affiliated (SCA) common stock, updating and clarifying reporting categories (affiliated — certain other) for the asset valuation reserve (AVR) Annual Statement Instructions as follows: Certain other — SCA entities with valuations affected by statutory accounting that result in a lower AVR maximum reserve factor. Other — All other SCA entities. With adoption, SAPWG is recommending these Annual Statement changes to the Blanks (E) Working Group. The Capital Adequacy (E) Task Force is also being notified.	No	No	August 12, 2026
2025-13	Issue Paper No. 172, Qualifying Statutory Trusts	P&C Life Health	“Residential Mortgage Loans Held in Statutory Trusts” Adopted Issue Paper No. 172, which discusses the new SAP concept adopted in 2025 that allows investments in mortgages held in qualifying statutory trusts to be (1) included within the scope of SSAP No. 37, Mortgage Loans, and (2) reported on Schedule B — Mortgage Loans.	No	No	May 18, 2026

Agenda Items Exposed

SAPWG exposed the following items for written comments by interested parties:

Reference No.	Relevant Guidance	Insurance Type	Revisions Exposed	Financial Statement Impact	Disclosure	Effective Date
2023-14	SSAP No. 7, Asset Valuation Reserve and Interest Maintenance Reserve	Life	Proposed New SAP Concept: “SSAP No. 7, Asset Valuation Reserve and Interest Maintenance Reserve” Exposed a reproposal of revised SSAP No. 7, an updated draft issue paper, and related proposed revisions to other SSAPs, along with proposed changes to the Annual Statement. The proposed revisions include those related to the following: Mechanical updates to AVR/IMR allocation and amortization rules. Proof of reinvestment that incorporates guidance from Agenda Item 2025-23. Derivative “hedging — other” transition guidance. Prohibiting losses from “known liquidity sales” from being deferred in IMR. Elimination of hypothetical IMR in reinsurance transactions. Required disclosures for entities admitting net negative IMR. Annual Statement updates to financial statement captions and the Exhibit of Capital Gains (Losses). The discussion during the NAIC 2026 Summer National Meeting focused on the admittance limitations included in the exposure. Future discussion will focus on evaluating the effectiveness of the guardrails included in INT 23-01, other than the admission limit.	Yes	Yes	To be determined (TBD) (tentative effective date changed to January 1, 2028)
2026-08	SSAP No. 21, Other Admitted Assets	P&C Life Health	Proposed New SAP Concept: “SSAP No. 21 — ICOLI” SAPWG is requesting regulator comment and direction because of increased insurer investment and concerns about exposure to private credit markets. This agenda item exposes a possible change in the reporting of amounts realizable for company-owned life insurance (COLI) or ICOLI. It focuses on whether the reporting of ICOLI assets held in investment vehicles should be changed from write-ins as “other-than-invested assets” on line 25 of the asset page to reporting on Schedule BA in a new category titled “Realizable Amounts Under ICOLI Policies.” Under current guidance, amounts are not subject to RBC for life insurance entities, and there is minimal RBC impact for P&C insurance and health insurance entities. This agenda item has been referred to the Capital Adequacy (E) Task Force to inform its members that new RBC changes may be needed.	TBD	TBD	TBD
2026-15	SSAP No. 23, Foreign Currency Transactions and Translations	P&C Life Health	Proposed New SAP Concept: “SSAP No. 23 — Canadian Translations” Proposed elimination of the optional Canadian insurance operations exception for foreign currency translation since the U.S. and Canadian dollars are no longer close to equivalent.	Yes	TBD	TBD
2026-04	SSAP No. 24, Discontinued Operations and Unusual or Infrequent Items	P&C Life Health	Proposed SAP Clarification: “ASU 2025-10, Accounting for Government Grants Received by Business Entities” Reexposed rejection of FASB Accounting Standards Update (ASU) No. 2025-10, Accounting for Government Grants Received by Business Entities. The reexposure would: Reject grant accounting and require income-related government grants to be accounted for as gain contingencies. Provide guidance, in a manner consistent with U.S. GAAP terminology, on grants related to an asset.	No	No	TBD
2026-10	SSAP No. 26, Bonds	P&C Life Health	Proposed New SAP Concept: “SSAP No. 26 — Embedded ALM Risk” This item addresses multicollateral structured credit investments — specifically, asset-backed securities (ABS) with a broad spectrum of underlying collateral, potentially including both investment-grade and non-investment-grade bonds and direct loans, unrated loans and debt securities, mortgage loans, or equity investments. These structures could also contain a significant amount of asset-liability duration mismatch. Duration of the debt tranches could be significantly longer than the collateral assets supporting them. SAPWG is proposing to expand the requirements for ABS to qualify for bond treatment as follows: ABS that are not self-liquidating would be required to overcome the presumption that equity-backed debt instruments do not meet the bond definition. An assessment of whether self-liquidating financial ABS include significant embedded asset/liability management (ALM) risk would be required. If they include such risk, the ABS would not qualify under the bond definition.	Yes	No	TBD
2026-11	SSAP No. 37, Mortgage Loans	P&C Life Health	Proposed SAP Clarification: “Residential Mortgage Loan Definition” This agenda item is in response to a referral from the Investment Analysis (E) Working Group that requested consideration of whether the definition of residential mortgage loans should be refined to distinguish these loans from commercial, commercial-like, or other types of mortgage loans. SAPWG is requesting comments on current references to one- to four-family property and multifamily properties that are based on provisions in Code of Federal Regulations (CFR) Title 12. This agenda item could have an impact on Schedule B — Mortgage Loans and, ultimately, RBC.	Yes	No	TBD
2026-13	SSAP No. 47, Uninsured Plans SSAP No. 54, Individual and Group Accident and Health Contracts	P&C Life Health	Proposed SAP Clarification: “Medicaid — Updates” This agenda item is related to (1) state-directed payments in Medicaid-managed care and (2) separate payment terms. Clarification is needed regarding whether these payments are considered to be “at risk” for accounting and reporting as part of an insured plan. As stated in the agenda item, SAPWG exposed revisions to both SSAP No. 47 and SSAP No. 54 that would provide that “Medicaid contracts payments classified as capitated payments are included in insured plans.”	Yes	No	TBD
2026-02	SSAP No. 61, Life, Deposit-Type and Accident and Health Reinsurance	Life Health	Proposed SAP Clarification: “Valuation of Funds Withheld Liability” Reexposed proposed revisions to SSAP No. 61 related to a ceding entity’s accounting for coinsurance with FWH arrangements and the amount withheld that is recorded as a separate liability. Regarding liability under a reinsurance agreement, the agenda item addresses segregated collateral, the funded and unfunded portions of FWH liability, and situations in which investment risk and assets are not segregated. The reexposure moves the agenda item’s proposed guidance to the accounting and reporting section of SSAP No. 61, with references to the coinsurance with FWH and funds held with unauthorized or certified reinsurers. In addition, the reexposure notes that corresponding proposed revisions to the Annual Statement Instructions will be recommended upon adoption of the final SSAP revisions.	Yes	No	TBD (tentative effective date changed to December 31, 2027)
2026-12	SSAP No. 62, Property and Casualty Reinsurance	P&C	Proposed SAP Clarification: “Retroactive Reinsurance Exception” Retroactive reinsurance applies to contracts covering existing risk and requires special accounting (“retroactive reinsurance accounting”) as a result of coverage of past risk. However, an exception to retroactive reinsurance accounting applies in cases involving a retroactive reinsurance contract between insurers that are 100 percent owned or controlled by a common parent or ultimate controlling person. In these cases, the retroactive reinsurance contract may be treated as a prospective reinsurance contract as long as there is no gain in surplus from the transaction. SAPWG exposed a new disclosure to capture details of the type of retroactive reinsurance transaction to which the exception applies.	No	Yes	TBD
2024-15	SSAP No. 86, Derivatives Reproposed SSAP No. 109, Asset Liability Management Derivatives	P&C Life Health	Proposed New SAP Concept: “Asset Liability Management Derivatives” Exposed reproposed SSAP No. 109 (a new SAP concept) and the related reproposed issue paper. The reproposed guidance would apply to interest rate hedging derivatives that do not currently qualify as effective hedges but are used by the insurance industry for ALM. Under the reproposals: Highly effective hedges would be recorded at amortized cost. A reporting entity would be allowed to recognize deferred gains and admitted deferred losses from highly effective ALM hedges that are hedging the liability portfolio through segregated surplus. The capital gains or losses that are recognized as deferred would be amortized into realized capital gains and losses over a period not to exceed 10 years. Reinsurance would trigger the immediate recognition of gains or losses related to a derecognized hedged liability portfolio. Insurers would be required to include derivative deferred gains and losses in actuarial projections, with a reconciliation of admitted deferred derivative losses to the reported deferred amounts reflected for principles-based reserving and cash flow testing. SAPWG directed a referral to the Life Actuarial (A) Task Force to review and assess the proposed derivative guidance.	Yes	TBD	TBD (tentative effective date is January 1, 2028)
2026-09	SSAP No. 86, Derivatives	P&C Life Health	Proposed New SAP Concept: “SSAP No. 86 — RSATs” The NAIC’s Securities Valuation Office (SVO) noted an increase in replication (synthetic asset) transaction (RSAT) filings and questions whether there are parameters in place for permitting or restricting RSATs. Most guidance on RSATs is included in the Purposes and Procedures Manual of the NAIC Investment Analysis Office (the “P&P Manual”). RBC is derived from the NAIC designation for increases and the associated cash component that reduces risk exposure for decreases. The exposed revisions are as follows: Key definitions and requirements for an RSAT to be effective. Restriction of the cash component to high-quality securities (U.S. government investments, municipal bonds, or corporate bonds reported on Schedule D-1-1 — Issuer Credit Obligations with an overall NAIC 1 or NAIC 2 designation). To be permissible, an RSAT must replicate investment-grade (NAIC 1 or NAIC 2) long-term bonds that would be reported on Schedule D-1-1. Potential elimination of fair value measurement of the derivative. A recommendation to the Capital Adequacy (E) Task Force that “the overall RBC impact from replicated assets and the cash component should be either a net increase to RBC or floored at zero.”	Yes	No	TBD
2026-06	SSAP No. 100, Fair Value	P&C Life Health	Proposed SAP Clarification: “Fair Value Disclosures” Reexposed this agenda item, which is related to disclosures about the fair value of equity method investments. Under current guidance in SSAP No. 100, equity method investments are exempted from the fair value disclosure requirements. A referral from the Investment Analysis (E) Working Group questioned the purpose of this exemption. As stated in the agenda item, SAPWG requested that stakeholders in the insurance industry “propose guidance and reporting categories that could be established to differentiate equity-method investments by ‘operating entities’ and structures that hold investments (‘holding entities’).”	Yes	Yes	TBD
2026-14	SSAP No. 101, Income Taxes INT 18-03, Additional Elements Under the Tax Cuts and Jobs Act	P&C Life Health	Proposed SAP Clarification: “Updates to INT 18-03 for OBBBA” Exposed an analysis of elements included in INT 18-03 and the impact of the One Big Beautiful Bill Act (OBBBA) on various previously enacted tax provisions. This agenda item notes the following: The eight-year period over which liability for the Repatriation Transition Tax can be paid expires at the end of 2026. The alternative minimum tax credits used in 2021 and earlier no longer exist. Global intangible low-taxed income (GILTI) was replaced with net controlled foreign corporation tested income (NCTI) and made permanent. SAPWG exposed this agenda item to nullify INT 18-03 on January 1, 2027, and add accounting guidance on the new NCTI item to SSAP No. 101.	Yes	No	TBD

Agenda Items Deferred

SAPWG deferred action on the following items previously exposed:

Reference No.	Relevant Guidance	Insurance Type	Revisions Exposed	Financial Statement Impact	Disclosure	Effective Date
2025-24	SSAP No. 1, Accounting Policies, Risks & Uncertainties, and Other Disclosures SSAP No. 5, Liabilities, Contingencies and Impairments of Assets SSAP No. 21, Other Admitted Assets SSAP No. 26, Bonds SSAP No. 43, Asset-Backed Securities Annual Statement Instructions	P&C Life Health	Proposed SAP Clarification: “Commitments and Contingencies Disclosures” Current disclosures of commitments and contingent commitments are included in Notes 14 and 21 of the Annual Statement. To address the risk that insurers are entering into complex financial arrangements that include various commitments, this agenda item focuses on consolidating and clarifying disclosures of commitments and contingent commitments. Proposed revisions are as follows: Add to SSAP No. 5 a definition of “commitment” that states, in part: A commitment is a legally binding arrangement in which the reporting entity agrees to provide support or resources (most often cash or financial assistance) or to make payments to another party at a future date, but the arrangement does not yet meet the definition of a liability under this statement. If fulfillment of the commitment is not required until the occurrence of a specified event or until requested by another party (e.g., capital calls, delayed draws, etc.), the arrangement is considered a contingent commitment. Clarify the disclosure for loss contingencies and impairments of an asset by requiring the following information: Nature. Amounts accrued and an estimate of possible loss or range of loss. Add a disclosure describing commitments and contingent commitments. Add a comprehensive summary of commitments and contingent commitments with prescribed format in proposed updates to Note 14: Investment-related. Other (postretirement benefits, future rents, discontinued operations, tax credits, guarantees, guaranty fund assessments, and all other). Add disclosure of nonderivative forward purchase commitments (e.g., Government National Mortgage Association [GNMA] and private placement securities). Add disclosure of additional investment commitments to SSAP No. 21, SSAP No. 26, and SSAP No. 43. Comments are requested on the existence of clawback features in investments. SAPWG deferred action and directed NAIC staff to work with stakeholders in the insurance industry to clarify existing disclosure requirements, including the addition of a definition of commitments and contingent commitments.	Yes	Yes	TBD
2025-26	SSAP No. 48, Joint Ventures, Partnerships and Limited Liability Companies	P&C Life Health	Proposed SAP Clarification: “SSAP No. 48 Equity Changes” In review of valuation changes in the Annual Statement for entities accounted for under SSAP No. 48, inconsistencies were noted between unrealized gain or loss and valuation increase or decrease reported on the investment schedules. Although no revisions were proposed, this agenda item requests comments on equity method accounting in the following areas: Timing of recognition of equity value increases and declines. Acquisition at a discount with negative goodwill. Application of goodwill and related disclosures. Goodwill and basis differences. Negative investment income and impairment. Ownership percentage and related-party codes. SAPWG deferred action and directed an industry focus group to consider identified concerns in the above areas.	TBD	TBD	TBD

Contacts

	Andrew Pidgeon Audit & Assurance Partner Deloitte & Touche LLP +1 415 783 6426 apidgeon@deloitte.com		Bala Bellur Audit & Assurance Managing Director Deloitte & Touche LLP +1 813 769 3210 bbellur@deloitte.com
	Josh Martin Audit & Assurance Managing Director Deloitte & Touche LLP +1 860 725 3153 joshmartin@deloitte.com		John Tittle Audit & Assurance Specialist Deloitte & Touche LLP +1 312 486 5486 johntittle@deloitte.com