For many of us, December brings colder weather, holiday shopping, family gatherings, and kids home from school. This year, December also brought the NAIC’s Fall National Meeting. Many of the working groups did not meet during the National Meeting but instead held meetings just prior to or just after the meeting. Here is a summary of some of those gatherings.
NAIC/AICPA Working Group – December 1, 2025
This call was held to receive a report from the Regulator Access to Audit Documentation Drafting Group and then to consider approval of updated sound practices documents related to regulators accessing CPA audit workpapers. The two documents are entitled:
- Four Step Process to Obtain Access to CPA Workpapers
- Best Practices: Insurance Regulator Access to Audit Documentation
The Four Step document is intended to be an addition to current processes available to regulators and would most likely be utilized where regulators are experiencing difficulties in obtaining access to CPA workpapers. It was developed by the American Institute of CPAs (AICPA). Both documents are available on the Working Group’s website. The Working Group plans on developing training material on the new practices and expectations during the first quarter of 2026. The training will be presented via a webinar.
Risk-Based Capital (RBC) Model Governance Task Force – December 2, 3, & 10, 2025
All year, the Task Force has been working on developing a set of guidance principles for risk-based capital. Although the adoption of those principles appears to be closer, it did not happen during the December 2 meeting. Bridgeway Analytics provided an overview and summary of the revised principles, as well as a retrospective of the process to date. The discussion covered the purposes and uses of the RBC.
On December 3, via an email vote, the Task Force adopted its 2026 charges. Those charges include continued work on the RBC principles, completing a comprehensive gap analysis and constancy assessment of the different RBC formulas, the development of an education and public messaging campaign to highlight the benefits and strengths of RBC, overseeing the coordination among all NAIC committees/task forces in regard to RBC, and to create a process of analyzing both retrospective and future adjustments to RBC.
During the December 10 meeting, which occurred at the NAIC Fall National Meeting, the focus was once again the development of the RBC principles. Bridgeway Analytics gave a brief overview of current revisions, noting that it offered two different revision options to the language used regarding equal capital for equal risk. After the Task Force members chose the option they preferred, the principles were adopted.
The discussion then turned to the next steps to be taken in 2026. Areas of action followed the Task Force’s adopted 2026 goals, which are quite aggressive, and consisted of RBC preamble edits, analyzing retrospective and future RBC adjustments, a gap analysis of the RBC formulas, planning and coordinating with the American Academy of Actuaries (Academy), and an education and public messaging campaign to highlight the RBC framework’s benefits and strengths.
NAIC/Consumer Liaison Committee – December 8, 2025
During this meeting, Commissioner Jon Godfread (North Dakota) and Deputy Commissioner of Climate and Sustainability Michael Peterson (California) received consumer advocacy awards. Appointments of the 2026 funded and unfunded consumer representatives were announced. Presentations were given by:
- United policyholders on wildfire risk reduction
- Consumer Federation of America on how much consumer’s credit score impacted the price of homeowners insurance
- American Kidney Fund, the Rhode Island Parent Information Network, the National Alliance on Mental Illness, and the Disability Rights Education and Defense Fund addressing health insurance issues, including reduced affordability, reduced preventive care and vaccine access, and discrimination in benefit designs
The final presentation covered how flawed death records make it difficult to locate beneficiaries of unclaimed benefits.
Financial Regulation Standards & Accreditation Committee – December 9, 2025
During this very brief meeting, the Committee added new guidelines related to conflicts of interest and confidentiality protections to the review team guidelines and the self-evaluation guide. In addition, revisions to the self-evaluation guide added items pertaining to domestic multistate insurance companies and staffing fluctuations.
Statutory Accounting Principles Working Group (SAPWG) – December 9, 2025
As is usual, the meeting was divided into a hearing for items that had previously been exposed for comment, and a regular meeting to discuss or continue discussion of other items. The following activity took place during the hearing. Unless otherwise noted, adoption is effective immediately.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-12EP | Clarifies the treatment of issue papers in Level 5 of the statutory hierarchy. | Adopted. |
| 2024-21 | Although not a change to statutory accounting, this item removes the reporting of investment subsidiaries from statutory statement reporting. | Adopted effective 2026. |
Statement of Statutory Accounting Principle (SSAP) No. 97 does not establish a reporting category of or valuation for investment subsidiaries, thus the elimination. There is a concurrent blanks proposal to eliminate this reporting category from Schedule D – Part 6 and within the Asset Valuation Reserve (AVR) in the annual statement. In addition, a referral is being sent to the Capital Adequacy Task Force regarding treatment of investments subsidiaries in the RBC formulas.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-18 | Adopts certain revisions from Accounting Standards Update (ASU) 2019-21, Simplifying the Accounting for Income Taxes, and incorporates U.S. GAAP guidance previously only incorporated by reference into SSAP No. 101, Income Taxes. | Adopted. |
| 2025-20 | Amends SSAP Nos. 2, 21, 26, and 43 to consolidate some existing Notes to Financials disclosures and add disclosures for residuals identifying a company’s measurement method. | Adopted effective December 31, 2026. |
Currently, the disclosure requirements under SSAP Nos. 26 and 43 and for non-bond debt securities and residuals in SSAP No. 21 are different for some of the same elements. This adopted item provides consistency of reporting for like elements. The item also includes a new general interrogatory to identify if a company is reporting residuals under the allowable earned yield (AEY) or practical expedient (PE) measurement methods and/or if the company is transitioning from the PE to the AEY approach. The disclosure revision not only applies to Notes to Financials in the statutory statement but to the audited financials as well. The new adoption also results in changes to the statutory statement reporting instructions for adoption by the Blanks Working Group.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-21 | Revises SSAP Nos. 92 and 102 clarifying retirement plan assets can be held at net asset value (NAV) and NAV assets are to be included in the required fair value disclosure. | Adopted. |
| 2025-01 | Includes further revisions to SSAP No. 22 regarding sale-leaseback transactions restricting cash or assets received from the sale and the use of sale-leaseback accounting. | Revised and re-exposed for comment through February 13, 2026. |
This item has been bounced around for some time and industry had hoped it would be adopted at this meeting. However, more revisions were made to the document indicating that not just cash received could not be restricted in the transaction, but that any other asset received from the sale also could not be restricted in order to use sale-leaseback accounting. Thus, the re-exposure.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-13 | Through SSAP Nos. 37 and 40 revisions, residential mortgage loans held in qualifying statutory trusts are allowed to be accounted for and reported as if directly held. | Adopted effective January 1, 2027, with early adoption allowed. |
The above item should be reviewed carefully. One of the key concepts is the definition of a qualifying trust. For companies electing to early adopt this item, the new statement reporting format will not be in place for year-end 2025, so some creative categorization may be needed. The new reporting format will be in place for 2027 reporting.
| Reference # | Subject | Disposition |
|---|---|---|
| 2024-15 | Creation of a new SSAP to provide accounting guidance for interest-rate hedging derivatives used for asset-liability management derivatives. | Staff directed to concurrently develop SSAP and Issue paper. |
| 2025-19 | Revises SSAP Nos. 2, 21, 26, 30, 32, and 43 to add a new statement reporting column identifying private placement securities, as well as an aggregate disclosure detailing key information by type of public/private securities. | Adopted effective December 31, 2026. |
This item was addressed because of expressed interest from regulators to better be able to identify private placement securities. The SSAPs were amended to require disclosure of whether an investment is publicly registered, a Rule 144 investment, or a private placement security. This will be done by adding an electronic-only reporting column to various investment schedules. In addition, Notes to Financials #5 is to report the total book/adjusted carrying value (BACV), fair value (with fair values determined by level 2 and level 3 reported), the total amount of aggregate deferred interest and paid-in-kind interest, and the total BACV supported by private letter ratings.
During the meeting, the following items were exposed for comment, with a comment deadline of February 13, 2026. When adopted, some of the items below will eventually result in statement reporting changes.
| Reference # | Subject |
|---|---|
| 2025-22 | SSAP No. 61 changes would clarify how Interest Maintenance Reserve (IMR) eliminated as a part of a reinsurance transaction influences the reinsurance collateral requirement. |
The exposure asks for comments on two different approaches; a symmetrical approach where derecognized net negative IMR would reduce required collateral or an asymmetrical approach where derecognized net negative IMR does not influence the collateral required for reinsurance credit. The two different options are being presented because the IMR Ad Hoc Subgroup was not able to reach a consensus position between regulators and industry.
| Reference # | Subject |
|---|---|
| 2025-23 | Introduces the concept of and a reporting template for IMR proof of reinvestment. |
This issue is a direct result of the work being done by the IMR Ad Hoc Subgroup regarding negative IMR. One of the primary concepts of negative IMR is that the sale of the fixed-income instruments have been reinvested into new fixed income instruments with a higher yield. Although that sounds like a simple explanation, the issue is very complicated and beyond the scope of this summary. Companies should carefully review the proposal to understand the full implications. The proof of reinvestment would become a disclosure requirement under SSAP No. 7.
| Reference # | Subject |
|---|---|
| 2025-24 | Proposes revisions to SSAP Nos. 1, 5, 21, 26, and 43 consolidating and clarifying disclosure requirement for commitments and contingent commitments. |
At first glance, this proposal looks like a simple reorganization of the existing disclosures. But it is much more material than that. Companies should review the proposal carefully, as the proposed definition of “commitments” is different than what U.S. GAAP currently uses. The required disclosure would include commitments for investments, another significant deviation from current reporting. Disclosure requirements would be incorporated into Notes to Financials #14, which, in turn, is partially pulled directly into the RBC formulas. The proposed effective date is year-end 2026, which may be a difficult deadline for industry to meet.
| Reference # | Subject |
|---|---|
| 2025-25 | Changes to SSAP No. 56 address nonadmittance of assets held under “general account” basis in the separate accounts (SA) and would incorporate the concept of nonadmitted assets on the SA balance sheet. |
Although the concept of nonadmitted assets has always existed within the SA statement, they have never been separated out in the reporting, as happens in the general account. Because of the work that has been taking place regarding the admission of negative IMR amounts, regulators have decided it is now time to show nonadmitted amounts in the SA statement. This will be accomplished by including “Nonadmitted Assets” and “Net Admitted Assets” columns on the Asset Page, a line reporting the change in nonadmitted assets to the surplus account reconciliation, and an “Exhibit of Nonadmitted Assets.” As proposed, these changes will not be effective until 2027.
| Reference # | Subject |
|---|---|
| 2025-26 | Requests feedback on specific aspects and application of equity changes under SSAP No. 48. |
| 2025-27 | Would expand the reporting requirements under SSAP No. 1 for modified coinsurance (MODCO) and funds withheld (FWH) assets and add a new investment schedule reporting code identifying restricted assets held for MODCO and FWH reinsurance arrangements. |
In 2025, Note to Financials #5L was expanded to provide aggregate information on MODCO and FWH reinsurance assets. The above proposal would result in the identification of specific assets listed in the investment schedules that are pledged for collateral for those reinsurance agreements. There are several questions arising from this possible revision, but the most prominent would be how to report assets that are not fully pledged as collateral. For example, a bond may be 60% pledged as collateral, but the other 40% is not pledged. How would that be reflected in new reporting?
| Reference # | Subject |
|---|---|
| 2025-28 | Revisions would allow repurchase agreements with maturity dates greater than one year to be an admitted asset under SSAP No. 103. |
| 2025-29 | Clarifies specific questions that have arisen due to the implementation of the principles-based bond definition and associated reporting. |
| 2025-31 | Changes note the ending of the coverage gap discount program and adds the Center for Medicare & Medicad Services manufacturer’s discount program in INT 05-05 – Accounting for Revenues Under Medicare Part D Coverage. |
| 2025-32 | Deletes language that previously should have been removed from SSAP No. 40. |
| 2025-33 | Updates expense descriptions and categories for statement reporting. |
Anyone who has reviewed the expense reporting and/or instructions in the various statements realizes there is antiquated terminology still in use; for example, telegrams, cables, radiograms, teletypes, etc. This proposal will update the terms used for the expense categories as well as clarify expenses related to computer technology that have not been clear. The intent of this item is to update the existing schedules and classification of expenses, not to change accounting for these expenses.
| Reference # | Subject | |
|---|---|---|
| 2025-34 | Revises SSAP No. 51 and SSAP No. 52 to provide guidance on the optional implementation period regarding the economic scenario generator and non-variable annuities under the Valuation Manual revisions. | |
In addition to the above items, SAPWG discussed a memorandum to the Blanks Working Group regarding the new Schedule S – Part 8 in the Life/Fraternal Statement. The IMR Ad Hoc Subgroup provided an update on the work it is performing in review of the IMR.
As noted, some of the above activity also will result in needed changes to the statutory statement format and instructions. Appropriate items were referred to the Blanks Working Group, which then released them for comment via email. A summary of those email releases can be found toward the end of this article.
Reinsurance Task Force – December 9, 2025
The Task Force adopted the report of the Reinsurance Financial Analysis Working Group. The Working Group reported it has approved 107 reciprocal jurisdiction reinsurers and 42 certified reinsurers for passporting. Currently, 49 states and two territories have adopted the passporting process. A listing of reciprocal and certified reinsurers approved for passporting can be found on the certified and reciprocal reinsurers’ webpage. The report of the Mutual Recognition of Jurisdiction Working Group indicated that annual reviews were completed and all seven approved existing jurisdictions have been reapproved.
The meeting then turned to an update on what other NAIC groups are working on that affects or may affect reinsurance. Those projects were:
- Implementation of Actuarial Guideline (AG) LV (55) – Application of the Valuation Manual for Testing the Adequacy of Reserves Related to Certain Life Reinsurance Treaties
- Offshore life reinsurance discussions
- Property/Casualty reinsurance discussions
- Macroprudential reinsurance worksheet and 13-point plan
- AG 53 reviews focusing on reinsurance
- Revisions to SSAP No. 61 regarding risk analysis
- Principle-Based Reserving AG 22 on longevity reinsurance risk charges in RBC
- SAPWG IMR reinsurance collateral
Accounting Practices & Procedures Task Force – December 10, 2025
The Task Force adopted the minutes of its two working groups, SAPWG and the Blanks Working Group, and then adjourned.
Valuation of Securities Task Force (VOSTF) – December 10, 2025
The following action was taken on proposed amendments to the Purposes and Procedures Manual of the NAIC Investment Analysis Office (P&P Manual).
| Subject | Disposition |
|---|---|
| Allows a 30-day grace period for filing the private rating letter annual update. | Adopted effective immediately. |
| Changes the effective date for the modeling of collateralized loan obligations to 2026. | Adopted effective immediately. |
A summary of a project addressing identification of investments in the quarterly and annual statements was provided. The project would combine the CUSIP and ISIN fields in the statements into one new field (security identification (ID) field) and add new fields to identify the type of security ID being reported and if that ID has been verified. The next step is to develop a proposal for the changes to the Blanks Working Group.
The discussion then turned to the recognition of the new committee structure replacing the current VOSTF beginning January 1, 2026. The new structure will consist of the Invested Assets Task Force, which will then oversee three working groups; the Invested Assets Working Group, the Investment Designation Analysis Working Group, and the Credit Rating Provider Working Group. This was the final meeting of the VOSTF.
The Task Force received updates on the activities of SAPWG, the RBC Investment Risk and Evaluation Working Group, the Credit Rating Provider Rating Due Diligence Framework, and the Filing Exemption Discretion Project.
Regulatory Framework Task Force – December 10, 2025
The Task Force adopted the Prior Authorization White Paper, which outlines principles and recommendations for improving the prior authorization process for medical processes. Minutes from the following groups were adopted:
- Employee Retirement Income Security Act (ERISA) Working Group
- Mental Health Parity and Addiction Equity Act Working Group
- Prescription Drug Coverage Working Group
The National Committee for Quality Assurance provided a presentation covering updates to the 2026 utilization management standards. The ERISA Working Group provided an update on its work to develop guidance on level-funded plans and other alternatives that could potentially impact the small group market.
Executive (EX) Committee – December 10, 2025
The Committee adopted minutes of some of its previous meetings, reports from its task forces, and its 2026 charges. The group approved a motion to amend the Insurance Holding Company System Regulatory Act (#440). Director Heather Carpenter of Arkansas and Commissioner Ned Gaines of Nevada were appointed to the Consumer Board of Trustees, which oversees the NAIC’s Consumer Participation Program. A status report on revisions to the Privacy of Consumer Financial and Health Information Regulation (#672) was provided.
Joint Meeting of the Financial Stability Task Force & the Macroprudential Working Group – December 10, 2025
After adopting various meeting minutes, the proposed 2025 Liquidity Stress Testing Framework (LST Framework) was exposed for a 45-day comment period, ending January 26, 2026. The LST Framework is used by regulators to help assess insurers’ ability to meet financial obligations during stressed market conditions. The funding agreement-backed notes blanks proposal was re-exposed for a 45-day comment period. This proposal would provide additional disclosures beginning with year-end 2026 regarding funding agreements that support funding agreement-backed notes. Updates from the Valuation Analysis Working Group and activity of the International Association of Insurance Supervisors were provided.
Financial Condition Committee – December 11, 2025
The meeting began with the adoption of the minutes of most of its task forces and working groups. The Committee then turned its attention to some items that required separate handling from meeting minutes. This included:
- Adoption of the list of qualified and reciprocal jurisdictions.
Bermuda, France, Germany, Ireland, Japan, Switzerland, and United Kingdom will retain their designation.
- Adoption of the list of jurisdictions that recognize and accept the group capital calculation.
Canadian Office of the Superintendent of Financial Institutions (all Canadian provinces except Quebec), European Union member states, United Kingdom, Bermuda, Japan, and Switzerland.
- Receiving informal oral comments on the collateralized loan obligation timeline.
- Adoption of the accounting issue 2024-06; Risk Transfer Analysis of Combination Reinsurance Contracts.
This item originated in the Statutory Accounting Principles Working Group as a referral from the Valuation Analysis Working Group and has generated a lot of conversation as it traveled through the adoption process. The adoption revises SSAP No. 61 regarding the determination of risk transfer in reinsurance contracts. The revisions are effective immediately for new/newly amended contracts. For existing contracts, the effective date is year-end 2026 and will be treated as a change in accounting principle under SSAP No. 3 – Accounting Changes and Corrections of Errors.
- Adoption of the Restructuring Mechanisms White Paper.
Joint Meeting of the Executive Committee & Plenary – December 11, 2025
The main point of this meeting is to hear and adopt/receive committee, subcommittee, and task force minutes of meetings. As always, a few items are handled separately outside of the realm of minute adoptions. Items handled separately this time were:
- Adoption of the 2026 Generally Recognized Expense Table
- Amendments to Actuarial Guideline XLIX-A (49-A) – The Application of the Life Illustrations Model Regulation to Policies with Index-Based Interest Sold on or After December 14, 2020
- Adoption of the Long-Term Care Insurance Multistate Rate Review Framework
- Adoption of the Homeowners Market Data Call Template and Definitions
- Adoption of the 2024-06: Risk Transfer Analysis on Combination Reinsurance Contracts
Other action items included:
- Adoption of the NAIC 2026 budget
- Adoption of the 2026 NAIC proposed committee charges
The various NAIC zones announced their election of officers for 2026. The public meeting was then adjourned for the election of the 2026 NAIC officers. The new officers elected are:
- President – Scott White, Commissioner of the Virginia Bureau of Insurance
- President Elect – Elizabeth Dwyer, Director of the Rhode Island Department of Business Regulation
- Vice President – Jon Pike, Commissioner of the Utah Insurance Department
- Secretary/Treasurer – Michael Wise, Director of the South Carolina Department of Insurance
So ended the last NAIC National Meeting for 2025. However, the following activity took place afterward.
RBC Investment Risk & Evaluation Working Group – December 15, 2025
This meeting concentrated on the ongoing Collateralized Loan Obligation (CLO) project. The Academy provided an update on its current progress. The update included an explanation of how some decisions were made for the project, such as different correlations between elements. The Working Group members were given the opportunity to ask questions. Another update is expected from the Academy in January. In the meantime, the current update was exposed for a 45-day comment period ending January 29, 2026. Also exposed for the same comment period was proposal 2025-22-IRE, which covers the structural changes needed for the RBC formula for CLOs. Proposed factors will follow at a later date. Since the proposal also adds a section to the AVR, it will need to be coordinated with the Blanks Working Group. The chair announced that at this time the Working Group will not be moving forward with proposal 2025-12 addressing the RBC treatment of bond funds. This delay will give the Property RBC and Health RBC Working Groups time to consider if the same proposal would be appropriate for those formulas.
Blanks Working Group (BWG)– December 17, 2025 via email
Because of activity that occurred at the NAIC Fall National Meeting (mostly from SAPWG), the BWG received 10 proposals to expose for comment. The new items were exposed via email and are summarized below.
| Reference # | Subject | Disposition |
|---|---|---|
| 2025-21 | Revises the definition of Accepted Actuarial Designation based on material developed by the Society of Actuaries and the Casualty Actuarial Society. | Exposed for comment through February 6, 2026. |
| 2025-22 | Adds an electronic-only column to certain investment schedules indicating if the listed investment is a public, registered Rule 144, a private placement security, or not applicable. Also adds new disclosure requirements to Notes to Financials #5. (See SAPWG reference 2025-19 above.) | Exposed for comment through February 6, 2026. |
| 2025-23 | Enhances reporting in the SA statement to disclose nonadmitted assets. (See SAPWG reference 2025-25 above.) | Exposed for comment through February 6, 2026. |
| 2025-24 | Updates Notes to Financials #18B instructions for disclosure clarifications. (See SAPWG reference 2025-30 above.) | Exposed for comment through February 6, 2026. |
| 2025-25 | Expands Notes to Financials #2 instructions to include the reference to VM-20: Requirements for Principles-Based Reserves for Life Products. (See SAPWG reference 2025-34 above.) | Exposed for comment through February 6, 2026. |
| 2025-26 | Deletes outdated expense terminology and updates expense categories to reflect current types of expenses that exist for companies. (See SAPWG reference 2025-33 above.) | Exposed for comment through February 6, 2026. |
| 2025-27 | Adds a section to the AVR for reporting CLOs and adds a related footnote to Schedule D – Part 1 – Section 2. | Exposed for comment through February 6, 2026. |
| 2025-28 | Addresses the reporting of investments owned by a qualifying statutory trust. (See SAPWG reference 2025-13 above.) | Exposed for comment through February 6, 2026. |
| 2025-29 | Adds restricted asset codes in the investment schedules for the reporting of restricted assets. (See SAPWG reference 2025-27 above.) | Exposed for comment through February 6, 2026. |
| 2025-30 | Clarifies the reporting of retirement plan assets in Note to Financials #12 and #20 when the assets are valued using net asset value (NAV). (See SAPWG reference 2025-21 above.) | Exposed for comment through February 6, 2026. |
In addition, BWG sent a notification via a December 17, 2025 email indicating the 2026 quarterly instructions and illustrations for Note to Financials #8A have been modified. Revisions can be viewed by going to the BWG webpage, selecting the Documents tab, and selecting Updates to the Annual/Quarterly Statement Instructions – 2026 Instructions Revisions (updated 12/1/2026). Then select the appropriate statement type.
If you have any questions or need assistance, please reach out to a professional at Forvis Mazars.