Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated 5/14/18

Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to Julie Gann, Robin Marcotte, Fatima Sediqzad and Jake Stultz.


Ref No.

Issue Paper/ SSAP No./ Appendix





SSAP No. 101

Federal Income Tax Reform

Exposed updated revisions to reflect comments received from the January 2018 exposure. Exposure specifically requests comments on the assessment of reversal patterns of deferred tax items as a result of the new federal Act.



Issue Paper

Special Accounting Treatment for Limited Derivatives (VAIWG)

Exposed a revised issue paper detailing the special accounting guidance for limited derivatives hedging variable annuity guarantees.


SSAP No. 49
SSAP No. 56

Policy Loans

Exposed revisions to update the guidance for policy loans related to separate account products and to specify that all policy loans related to separate account policies shall be funded in order to be admitted in the general account. Exposure requests comments on an expected future blanks to remove the "contract loan" line from the Separate Account blank.


SSAP No. 43R

Reporting NAIC Designations as Weighted Averages

Exposed revisions to clarify that if a loan-backed or structured security has different NAIC designations by lot, then the reporting entity shall either report the entire investment on a single reporting line with the lowest applicable NAIC designation or report separately by purchase lots aggregated by NAIC designation.


SSAP No. 26R

VOSTF – Bank Loan Referral

Exposed a proposed referral response to the Valuation of Securities (E) Task Force indicating that borrowing base loans and debtor in possession (DIP) financings are collateral loans under SSAP No. 21, and not bank loans under SSAP No. 26R.


SSAP No. 32

VOSTF / BWG Symbol Changes

Exposed revisions to reflect revised reporting symbols adopted by the Valuation of Securities (E) Task Force.


SSAP No. 4

Regulatory Transactions
 Referral from the Reinsurance (E) Task Force

Exposed revisions to indicate that items acquired as part of "regulatory transactions" that meet the definition of an asset shall only be admitted with approval of the domestic state insurance department as a prescribed or permitted practice. Comments are requested on whether all "regulatory transactions" shall be reported on Schedule BA – Other Long Term Invested Assets.


SSAP No. 41R

Surplus Note Accounting
Referral from the Reinsurance (E) Task Force

Exposed revisions to indicate that surplus notes linked to other structures are not subordinate and do not qualify for reporting as statutory equity by the issuer. Also identifies that assets linked to issued surplus notes are not available for policyholder claims and shall be nonadmitted.


SSAP No. 21
SSAP No. 56

Private Placement Variable Annuities

ACLI Comment letter  received prior to exposure

Exposed revisions to SSAP No. 56 capture information on the insurer issuance of private placement life insurance and private placement variable annuities.  

Exposure requests information on how to differentiate private placement products that are investment-focused and traditional life insurance products when the insurer is the owner and beneficiary. This information will be used to develop subsequent revisions to SSAP No. 21.  


SSAP No. 97

SCA Loss Tracking

Exposed revisions to clarify guidance when a company's share of losses exceeds its investment in an SCA and to add a loss-tracking disclosure.


INT 18-02
INT 16-01

2019 ACA Section 9010 Assessment Moratorium

Exposed new INT 18-02 to provide guidance for the 2019 moratorium and future moratoriums for the federal ACA Section 9010 fee. Also exposed revisions to INT 16-01 to remove the reference to 2019 fee accruals and propose a Dec. 31, 2018 nullification.


Appendix D

ASU 2017-15, Elimination of FASB Topic 995 U.S. Steamship Entities

Exposed revisions to reject ASU 2017-15 as not applicable to statutory accounting.


SSAP No. 26R
SSAP No. 30
SSAP No. 32
SSAP No. 43R
SSAP No. 100R

ASU 2018-03, Recognition and Measurement of Financial Assets and Financial Liabilities

Exposed revisions to reject ASU 2018-03.


SSAP No. 41R
SSAP No. 52
SSAP No. 62R

Editorial Update

Exposed editorial revisions to SSAP Nos. 5R, 41R, 52 and 62R.


INT 05-05

Update INT 05-05 Medicare Part D Definitions

Exposed revisions to add a description of the Coverage Gap Discount Program and amend existing guidance on program payments and update definitions.


2018-15 INT 18-03

Additional Elements Under the Federal Tax Cuts and Jobs Act

Exposed an agenda item and draft INT to address the remaining elements from the Tax Cuts and Jobs Act. Items addressed include: 1) Repatriation Transition Tax, 2) AMT Credit, and 3) Global Intangible Low-Taxed Income Tax (GILTI).
2017-32 Issue Paper

SSAP No. 30—Unaffiliated Common Stock

Exposed an issue paper proposing substantive revisions to SSAP No. 30. Key elements addressed include: 1) Common Stock Definition; 2) Inclusion of Closed-End Funds and Unit Investment Trusts; and 3) Reporting Enhancements on Schedule D-2-2.


Issue Paper

ASU 2017-12, Derivatives and Hedging

Exposed an issue paper detailing the U.S. GAAP revisions from ASU 2017-12 with initial staff assessments. Exposure requests comments on the assessments, the revisions needed to incorporate suggested modifications, and the differences in derivative accounting between SAP and U.S. GAAP that should be retained.


Issue Paper

ASU 2016-13, Credit Losses

Exposed an issue paper that details U.S. GAAP concepts from ASU 2016-13 and identifies possible concepts for statutory accounting consideration. This exposure specifically requests input on other elements that should be assessed as part of an expected credit loss model under statutory accounting.


Conference Call
Thursday, May 24, 2018
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 / 5:00 a.m. Hawaii
Call duration: 1 hour

  • Materials will be posted on May 22 (due to a public comment period ending May 18)

INT 18-01: Updated Tax Estimates Under the Tax Cuts and Jobs Act (Act)

This interpretation provides a limited-time, limited-scope exception to SSAP No. 9 to not require recognition of changes in reasonable estimates from the Act as Type I subsequent events after the issuance of the statutory financial statements. Additionally, the INT provides instruction for reporting changes in deferred income taxes in the financial statements. This interpretation will be automatically nullified on Dec. 31, 2018.

INT 17-01: Extension of Ninety-Day Rule for the Impact of Hurricane Harvey, Hurricane Irma and Hurricane Maria
This interpretation temporarily extends the 90-day rule per paragraph 6 of SSAP No. 6 for policies impacted by Hurricane and Tropical Storm Harvey, Hurricane and Tropical Storm Irma, Hurricane and Tropical Storm Maria, and related flooding. This interpretation will be automatically nullified on February 16, 2018.

Subsidiary, Controlled or Affiliated (SCA)

Relating SVO Unit Prices to the Fair Value Hierarchy

Structured Securities

Accounting Practices and Procedures Manual

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 3, 2018

SAP to Annual Statement Disclosure Checklist Updated for 2017 Annual Statements
Updated 1/16/2018

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.


Education & Training Events

Related NAIC Publications


Statutory Accounting Principles (E)
Working Group

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. SSAPs 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.

2018 Charges

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