NAIC Spring 2020: Blanks Working Group Updates

NAIC working groups held a series of conference calls after the cancellation of the 2020 Spring National Meeting. The is a summary of recent updates from the Blanks Working Group pertinent to investment accounting and reporting.

Download Clearwater’s full NAIC Spring 2020 market insight paper here.

ADOPTED ITEMS

Effective December 31, 2020

2019-28BWG – Modify the instruction for Supplemental Investment Risk Interrogatories (SIRI) Lines 13.02 through 13.11 clarifying when to identify the actual equity interests within a fund and aggregate those equity interests for determination of the 10 largest equity interests

This item clarifies when to identify the actual equity interests within a fund, including an exchange-traded fund (ETF) or a mutual fund, and aggregate those equity interests to determine the 10 largest equity interests. The proposal modifies the instruction for SIRI lines 13.02 through 13.11 to indicate that the company must look through a non-diversified fund to aggregate exposures in the top 10 equity interest, but a look through is not required with diversified funds. It also clarifies any equity fund that qualifies individually as one of the largest equity interests should be included in the top 10 list.

This item was adopted by Statutory Accounting Principles Working Group (SAPWG) at the fall meeting.

2019-29BWG – Modify the instruction and blank for SIRI question 14.01

The SAPWG and BWG adopted the disclosure of the ten largest fund managers at the 2019 Spring National Meeting. It clarifies that interrogatories 14.06 through 14.15 in the blank need to be completed regardless of the answer to SIRI question 14.01.

2020-03BWG Modified – Modify the instruction and illustration for 13(11) to the Notes to Financial Statement. Change the numbering from 1 through 13 to A through M to reflect the disclosure addition for SSAP No. 41R – Surplus Notes being adopted by SAPWG and correct the instruction

This item reflects the changes adopted by the SAPWG (Ref#2019-37) by changing the numbering from 1 through 13 to A through M to reflect the disclosure addition for SSAP No. 41R – Surplus Notes. It emphasizes the percentage of interest payments offset shall be reported.

2020-08BWG Modified – Add a disclosure instruction for 10C to the Notes to Financial Statement for related party transactions not captured on Schedule Y to reflect the disclosure addition for SSAP No. 25 – Affiliates and Other Related Parties being adopted by the SAPWG. Combine existing 10C into 10B instructions and illustration narrative.

The SAPWG adopted revisions (Ref#2019-33) to SSAP No. 25 – Affiliates and Other Related Parties that would clarify identification of related parties and affiliates and incorporate disclosures to ensure regulators have the full picture of complicated business structures. The item was adopted with interested parties’ recommended editorial changes.

2020-13BWG Modified – Remove Line 24.04 from the General Interrogatories, Part 1 and renumber remaining lines for Interrogatory Question 24. Modify Lines 24.05 and 24.06 to require reporting amounts for conforming and non-conforming collateral programs.

The answers to Interrogatory Questions 24.05 and 24.06 depend on the answer to Questions 24.04. This works for companies that have all conforming or non-conforming collateral programs. If the answer is both, only the collateral amount for the conforming program is captured. This proposal removes Line 24.04 and requires companies with both conforming and non-conforming collateral programs to capture the collateral amount for both.

2020-17BWG – Adjust the asset valuation reserve (AVR) presentation to include separate lines
for each of the expanded bond designation categories.

The BWG and SVO adopted the 20 bond designations for 2020 reporting, which will flow into the RBC, but will not include factors. An impact analysis will need to be done to confirm the new factors for the 20 designations for next year. In the meantime, the current factors for designations 1 through 6 will remain in the RBC.

It applies the same expanded presentation to the AVR Default Component Report.

2020-18BWG Modified – Clarify the instructions to indicate which funds reported on Schedule D, Part 2, Section 2 (annual filing) and Schedules D, Part 3 and 4 (quarterly filing) must have NAIC
Designation, NAIC Designation Modifier and SVO Administrative Symbol. Modify the reference to the SVO P&P Manual found in the Blanks instructions.

The instructions on Schedule D, Part 2, Section 2 were modified to include securities reported on Line 9599999 (Unit Investment Funds) and 9699999 (Closed-End Funds) to provide the appropriate NAIC Designation, Modifier, and SVO Administrative Symbol assigned by the SVO and published in AVS+ per SVO P&P Manual instructions. NAIC Designation and Designation Modifier should not be provided for securities reported on these lines that have not been assigned one by the SVO. A list of funds is published on the SVO website.

This item modified the reference of SVO Identified Funds to the SVO P&P Manual found in Schedule D Part 1, Schedule D Part 2 Section 2, Summary Investment Schedule, Schedule E Part 2 (annual and quarterly filings), Investment Schedules General Instructions.

2020-19BWG Modified – Add a code of “%” to the code column for all investments which have been reported Schedule DA, Part 1 and Schedule E, Part 2 for more than one consecutive year. Add certification to the General Interrogatories, Part 1 inclusion of these investments on Schedule DA, Part 1 and Schedule E, Part 2.

The SAPWG adopted two items (2019-20 and 2019-42) that are related to this change. The purpose of this change is to identify when cash equivalents and/or short-term investments stay on the applicable investment schedule for more than one reporting period with a code of “%”. It adds a new question to the General Interrogatories to certify if the investments on Schedule DA Part 1 and Schedule E Part 2, met the criteria:

• The investment can be liquidated by the insurer on the maturity date
• The investment was acquired from nonrelated party at an arm-length
• The investment was acquired from a related party but the insurer has completed robust re-underwriting of the transaction that will be available for regulator review.

Investments that don’t meet these criteria will be recorded as long-term investments.

As SAPWG will do the editorial change that includes cash equivalents in paragraph 16e of SSAP No. 2R, the working group recommended to adopt this agenda item pending for SAPWG adoption of that editorial change.

2020-20BWG Modified – For Schedule D, Part 1, add code “10” to Column 26 – Collateral Type for ground lease financing. Renumber “Other” code to 11

The VOSTF adopted an amendment to the P&P Manual during the fall 2019 meeting to add ground lease financing transactions as a newly defined asset class. This was effective January 1, 2020, and the amendment was sent to the SAPWG for consideration.

Ground lease financing is defined as “real estate loans secured by the obligation to pay debt service by means of rental payments of subleased property where a long-term ground lease was issued in which the lease intends significant land development and the subleasing of such property to other long-term tenants.”

This item was adopted with minor corrections for reference numbers on Form A.

2020-21BWG Modified – Add new Line 4.05 for valuation allowance for mortgage loans to the Summary Investment Schedule and renumber existing Line 4.05 to 4.06. Modify the instructions to include a crosscheck for new Line 4.05 back to Schedule B – Verification Between years. Clarify the instructions for 4.01 through 4.04 to explicitly show crosschecking to Column 8 of Schedule B, Part 1.

This schedule addresses the fact that the amount reported on Schedule B, Part 1, Column 8 excludes the valuation allowance, even though the total reported for mortgage loans in the Summary Investment Schedule must tie to the asset page, and that page includes the valuation allowance.

It reflects changes adopted by the SAPWG (Ref#2020-07) in May 2020 by adding new line 4.05 to the Summary Investment Schedule to prevent crosscheck errors.

EXPOSED ITEM

2020-26BWG – Add a new Column 5 to Schedule DB, Part D, Section 1 and renumber the remaining columns. Add instruction for the new Column 5, add the column reference to Column 7, and adjust other column references in crosschecks. Correct column references for this schedule on the Liability Page, Asset Page and Schedule DB Verification. Modify instruction language for the disclosure Note 8A(8)

This item proposes to reflect changes concurrently exposed by SAPWG (Ref#2019-38) in May 2020 to SSAP No. 86 by adding a new column for Present Value of Financing Premium on Schedule DB Part D Section 1.

It was exposed with a proposed effective date of March 31, 2021.

DEFERRED ITEM

2020-02BWG Modified – Modify the instruction and illustration for Note 10L to reflect the disclosure changes for SSAP No. 97 – Investments in Subsidiary, Controlled, and Affiliated Entities being adopted by SAPWG

This proposal was exposed with changes adopted by the SAPWG (Ref#2019-32) in March 2020 to SSAP No. 97 – Investments in Subsidiary, Controlled, and Affiliated Entities to emphasize that a look-through is permitted through more than one downstream holding company if each look-through entity complies with the requirements in SSAP No. 97.

It is deferred until the SAPWG adopt agenda item 2019-14, which was exposed with a comment deadline of May 29, 2020.

2020-22BWG Modified – Modify the instructions and illustration for Note 3A and a new Note 3E with instructions and illustrations to be data captured. Modify the blank and instructions for Schedule D, Part 6, Sections 1 and 2.

This proposed modifications to the Notes to Financial Statement and Schedule D, Part 6 Section 1 reflect changes being adopted for SSAP No. 68 – Business Combinations and Goodwill and SSAP No. 97 – Investments in Subsidiary, Controlled and Affiliated Entities by the SAPWG.

A new note, 3E, would be created for subcomponents and calculation of Adjusted Surplus and Total Admitted Goodwill. For Schedule D Part 6 Section 1, Column 7 is removed and columns after that are renumbered.

The item is deferred until the SAPWG adopt agenda item 2020-03, which was exposed with a comment deadline of May 29, 2020.

OTHER ITEM

Electronic Blanks and Instructions Publications

NAIC staff announced digital copies of Blanks and Schedule Instructions will be available (TBD) through Bookshelf.