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Latest NAIC Updates Surrounding COVID-19

 

Recently the National Association of Insurance Commissioners (NAIC) Statutory Accounting Principles Working Group adopted the four interpretations below.

  • INT 20-01:ASU 2020-04 – Reference Rate Reform (Ref #2020-12)
    • This interpretation discusses how ASU 2020-04 should be adopted. The general consensus is that this guidance requiring a shift away from LIBOR shouldn’t require de-recognition and recognition of existing transactions. There is additional guidance specifically related to derivative transactions which we recommend you read through if your company participates in those types of transactions.
  • INT 20-02: Extension of Ninety-Day Rule for the Impact of COVID-19
    • This interpretation provides a one-time optional extension of the ninety-day rule for uncollected receivables. For both first and second quarter 2020 filings, receivables that were in good standing prior to the emergency declaration for COVID-19, are not required to be non-admitted because they are past due by more than ninety days.
  • INT 20-03: Troubled Debt Restructuring Due to COVID-19
    • This interpretation applies to those who may be unable to meet their contractual obligations due to COVID-19. See the interpretation for the requirements for debt modifications to not be classified as troubled debt restructuring.
  • INT 20-04: Mortgage Loan Impairment Assessment Due to COVID-19
    • This interpretation applies to specific investments noted in the following SSAP Nos. 26R, 37, 30, 43R and 48 which have underlying characteristics of mortgage loans. For those qualifying investments, impairment analysis can be deferred until Q3 2020 financial reports.

The full interpretations can be found on the NAIC’s website at the following link:

https://content.naic.org/cmte_e_app_sapwg.htm

Contact your Larson & Company insurance accounting specialist for help implementing these new standards.