Statutory Accounting Principles Working Group (SAPWG)

Ref No.

SSAP No./Title/Description

Comment Deadline: February 23, 2018

SSAP No. 101

Federal Income Tax Reform

Exposed revisions, via evote, to reflect the new Tax Cuts and Jobs Act. With this exposure, the Working Group agreed to send a referral to the Capital Adequacy (E) Task Force to provide notice of the exposure and summary of the tax changes.


Larson Commentary

The new Tax Cuts and Jobs Act affects each insurer’s deferred tax calculation as the new tax rate should be used in preparing the deferred income tax for December 31, 2017.


We have prepared a memo summarizing the other key provisions contained in the exposure draft. If you did not receive a copy of this memo and would like one please email Karsten Hatch at   


Comment Deadline: January 19, 2018

SSAP No. 86, Schedule DB

Impact of Future Settled Premiums on Option Valuations

Exposed revisions to capture individual contract disclosures for derivatives with financing premiums, along with proposed changes to Schedule DB to reflect these disclosure requirements for year-end 2018.


Larson Commentary

Insurance companies that enter into equity option and interest rate swaption derivatives may be affected by this exposure draft.



SSAP No. 68, SSAP No. 97

Goodwill Limitation in SSAP Nos. 68 and 97

Exposed revisions to expand goodwill disclosures.


Larson Commentary

Discussions regarding the admissibility of goodwill. Interested parties liked the idea of making no changes. End result was compromising on just making additional disclosures, which is what this exposure draft seeks to accomplish.



SSAP No. 41, SSAP No. 97

Double-Counting of Surplus Notes

Exposed revisions to clarify that an SCA’s acquisition of a surplus note issued by the parent shall always be eliminated in the SCA’s value reported by the parent insurance company.


Larson Commentary

As noted by the NAIC, when a parent insurance company records their investment in an SCA and their proportionate share includes the surplus the surplus note issued by the SCA, there is a potential for the surplus to be double counted. This exposure draft provides the explicit guidance that the surplus note should be eliminated. Doing so will provide a more accurate picture of the insurance company’s financial position.



SSAP No. 92, SSAP No. 102

Updates to the Presentation and Disclosure of Pension and Postretirement

Exposed revisions to remove the Level 3 reconciliation disclosure.


Larson Commentary

The NAIC noted that the Level 3 reconciliation may not be necessary as the plan assets are not reported as assets in the balance sheet of insurance reporting entities.





SSAP No. 103R

Wash Sale Disclosure

Exposed revisions to exclude all cash equivalents, derivative instruments as well as short-term investments with credit assessments equivalent to an NAIC 1-2 from the wash sale disclosure. Proposed revisions also clarify that the wash sale disclosure should be captured in the financial reporting statement for the period in which the investment was sold.


Larson Commentary

The current guidance “only encompasses items that meet the wash sale disclosure and that have an NAIC rating of 3 through 6, or are considered non-rated.”



SSAP No. 30

SSAP No. 30 – Investment Classification Project

Exposed for comment proposed concepts to update SSAP No. 30. Key elements address the definition of common stock, the inclusion of closed-end funds and unit investment trusts, and consideration of the VOSTF referral to allow NAIC designations to be reported on D-2-2 for certain investments.


Larson Commentary

The NAIC seeks to provide clarification by identifying those items that may be outside the definition of common stock but are still in the scope of SSAP No. 30.



Appendix D

FASB Codification References

Exposed for comment the proposed project to identify FASB Codification references for U.S. GAAP guidance reflected in SSAP.


Larson Commentary

According to the NAIC, “in order to ensure that GAAP guidance previously adopted into SAP has not been revised with current FASB updates…” this exposure draft has been drafted “to inquire with the Statutory Accounting Principles working group on whether a comprehensive project should occur to better identify the FASB codification references for U.S. GAAP reflected in statutory accounting.”



SSAP No. 49, SSAP No. 56

Policy Loans

Exposed for comment key concepts noted in the agenda item for discussion to determine how to move forward in clarifying the policy loan guidance.


Larson Commentary

Through this exposure draft the NAIC seeks “to ensure consistent application, and to ensure that the guidance is clear involving policy loans, and when they would qualify for admittance in the general account, or recorded in the separate account.”



Appendix H

INT Updates

Exposed revisions to extend INT 02-22 and update and nullify INT 09-08.



Larson Commentary

INT 02-22 – Accounting for the U.S. Terrorism Risk Insurance Program was originally drafted to provide an interpretation of the Terrorism Risk Insurance Act of 2002. (TRIA). TRIA has been extended several times since its original adoption. With this exposure draft additional language has been added that extends INT 02-22 to remain in effect as long as the Terrorism Risk Insurance Act is authorized by the U.S. Congress.


Originally, INT 09-08 – Accounting for Loans Received Under the Federal TALF Program, “was created by the Federal Reserve to interpret the passage of the Term Asset-Backed Securities Loan Facility (TALF). This exposure draft nullifies INT 09-08 as there are no longer loans outstanding under the associated program.




2017-37 and


SSAP No. 47

Revenue Recognition ASUs

Exposed revisions to reject noted FASB ASUs in SSAP No. 47


Larson Commentary

This exposure draft specifically rejects the following ASUs: ASU 2014-09- Revenue from Contracts with Customers, 2016-08 – Revenue from Contracts with Customers: Principal versus Agent Considerations (Reporting Revenue Gross versus Net), and 2016-12 – Revenue from Contracts with Customers: Narrow-scope Improvements and Practical Expedients.


Blanks Working Group (BWG)

Ref No.


Comment Deadline: February 26, 2018
2017-21 Add language to General Interrogatory merger questions (5.1 annual and 4.1 quarterly) to require the filing of merger history with the NAIC, if the questions are answered “YES.”


2017-22 Add question to the Supplemental Exhibits and Schedules Interrogatories regarding the filing of the Statement of Exemption in the 2nd Quarter.


2017-23 Modify the annual statement instructions to reflect the requirement of filing the Life, Health and Annuity Guaranty Association Model Act Assessment Base Reconciliation Exhibit and the Adjustments to the Life, Health and Annuity Guaranty Association Model Act Assessment Base Reconciliation Exhibit by companies that are members of the life, health and annuity guaranty associations and write the respective lines of business.
2017-24 Add new category lines for bank loans to Schedules D (Parts 1, 3, 4 & 5), D, DL (Parts 1 & 2) and E (Part 2) and adjust category line number reference in the Default Component – Basic Contribution, Reserve Objective and Maximum Reserve Calculations.
2017-25 Add language to the instructions of the cash flow statement regarding the inclusion of restricted cash or restricted cash equivalents in the beginning and ending balance in the cash flow statement.


2017-26 Modifies the category line descriptions and adds crosschecks for lines 1499999, 2899999, 4299999, 4399999, 4499999, and 9999999 to clarify the subtotal calculations for protected cells and authorization categories. Replaces old references to “Part 5” with updated “Part 3” references throughout. Revise the calculation references in the headings for Columns 60, 66, and 74. Revises the calculation references for Columns 72 and 73 to clarify certain calculations related to amounts in dispute.

For more information contact Karsten Hatch.