EXPOSURE DOCUMENT INDEX
The following is a list of documents exposed by various work groups of the 不良研究所官方 to the public. For additional information regarding these and other documents, their comment periods and pending actions – please visit the appropriate Committees & Activities page.
There are no exposure drafts at this time.
The below document is exposed for comments until COB January 18, 2024, by the Solvency Workstream of the Climate & Resiliency (EX) Task Force. Please submit comments to Dan Daveline.
The Task Force exposed the following memorandum. Please submit comments to 不良研究所官方, Dan Daveline and Bridgeway Analytics by COB July 24.
The Task Force exposed the following memorandum, please submit comments to Dan Daveline before March 12, 2025.
Annuity Suitability (A) Working Group Adopted FAQ Guidance Document
Draft Safe Harbor Guidance (Draft Date Aug. 7, 2025)
The following documents are being exposed for a 30-day public comment period ending Tuesday, September 9th.
- Revisions to Actuarial Guideline 49-A
- APF 2025-05 Contractually Guaranteed Revenue Sharing
- Generally Recognized Expense Table (GRET)
- AG 55 Template Presentation with Cover Letter
Please send comments to Scott O'Neal by September 9, 2025.
The following documents are being exposed for a 25-day public comment period ending Friday, July 25th:
- SOA 2025 Historical and Future Mortality Improvement Rates Presentation
- SOA 2025 HMI and FMI Rates Preliminary Recommendation
Please send comments to Scott O'Neal by July 25th, 2025
The following document is being exposed for an 80-day public comment period ending Monday, July 14th:
Note: Commenters are also requested to provide examples of different types of revenue sharing arrangements they feel would potentially be adversely affected by APF 2025-05 compared to the existing requirements, detailing their interpretation of the requirements with and without the clarifications to the guidance note. A reminder email will be distributed 30 days prior to the end of the exposure date.
Please send comments to Scott O'Neal by July 14th, 2025
There are no exposure drafts at this time.
There are no Exposure Drafts at this time.
The following document is being exposed for a 60-day public comment period ending, Tuesday, August 19th, 2025:
Please send comments to Amy Fitzpatrick by close of business on August 19th, 2025.
There are no exposure drafts at this time.
The following document is being exposed for a 60-day public comment period ending, Monday, September 15th, 2025, please send comments to Amy Fitzpatrick.
The following documents are being exposed for a 30-day public comment period ending Friday, September 12th:
- VM-21 Supplement Blank 8-13 Exposure for 30 days (1).docx
- DRAFT_Life_and_Fraternal_2026_VM21_Reserves_Supplement_Instructions_v20250725 with Opt
Please send comments to Jane Ren by September 12th, 2025
Extension: The following documents are being exposed for a 30-day public comment period ending Friday, September 19th Wednesday, August 20th:
Please send comments to Jane Ren by September 19th August 20th, 2025
Model #171 Revisions Tracked Redline Version (as adopted by the Committee on Nov. 19)
Model #171 Revisions Clean Version (as adopted by the Committee on Nov. 19)
QTL Template.xlsx Pennsylvania Revised Draft QTL Template Draft May 28, 2020
QTL Template Instructions.docx Revised Draft QTL Template Instructions May 28, 2020
MHPAEA assumptions exposure.docx MHPAEA Draft Assumptions March 10, 2020
The Task Force requests comments on the American Academy of Actuaries draft Knowledge Statements for Appointed Actuary for Health Blank.
Health Knowledge Statements_Draft.pdf
Please provide comments to eking@naic.org by Thursday, Oct. 31.
The Long-Term Care Actuarial (B) Working Group is considering revised cost-sharing factors to accompany implicit cost-sharing contained in the blended / if-knew aspect of the MSA approach adopted by the Working Group and the Long-Term Care Insurance (B) Task Force in late 2024.
Please provide comments to eking@naic.org on the following cost-sharing proposals by May 12, 2025:
Missouri Proposal:
鈥 No haircut for the 铿乺st 100%.
鈥 35% for the portion of cumulative rate increase between 100% and 400%
鈥 70% for the portion of cumulative rate increase between 400% and 800%
鈥 85% for the portion of cumulative rate increase between 800% and 1000%
鈥 95% haircut for the portion of the cumulative rate increase in excess of 1000%
鈥淎lternative鈥 Proposal, discussed on the February 21, 2025 Working Group call:
鈥 5% haircut for the 铿乺st 100%.
鈥 35% for the portion of cumulative rate increase between 100% and 400%
鈥 70% for the portion of cumulative rate increase between 400% and 800%
鈥 85% for the portion of cumulative rate increase in excess of 800%
There will be a Working Group call in mid to late May to choose between the proposals or factors in between those stated in the proposals.
PA white paper 7.18.2025.docx Draft Prior Authorization Framework White Paper (July 18, 2025)
Comments are requested by close of business April 21, 2022
ERISA Handbook case summary - Rutledge
Comments received
The Homeowners Market Data Call (C) Task Force is seeking comments on a revised Data Call Template and Data Call Definitions.
The Template and Definitions documents are being exposed for 37 days. Please submit comments to Aaron Brandenburg at abrandenburg@naic.org by end of day, Sept. 15.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The following documents, AOWG 2025 Regulatory Guidance Draft and 027 Property 2025 Actuarial Opinion Draft, are now exposed for 30 days.
AOWG 2025 Regulatory Guidance Draft
027 Property 2025 Actuarial Opinion Draft
Comments should be sent to Roberto Perez (rperez1@naic.org) by Friday, Sept. 26.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The Adjuster Licensing (D) Working Group has been given the task of reviewing the 不良研究所官方 State Licensing Handbook, specifically Chapter 18鈥擜djuster Licensing.
The State Licensing Handbook was last updated and made available in 2021. The Producer Licensing Uniformity (D) Working Group has been given the charge to review the full handbook for any potential updates. To assist with this, the Adjuster Licensing (D) Working Group will review Chapter 18 and discuss necessary updates which will be presented to the Producer Licensing Uniformity (D) Working Group.
The Word and PDF version of Chapter 18 Adjuster Licensing can be found below.
The PDF Chapter 18 Adjuster Licensing Draft with track changes can be found below.
The Working Group will hold open monthly Webex conference calls to review comments received and finalize potential revisions.
2025 Monthly Calls:
- Chapter 18 Adjuster Licensing (Current Version) - WORD / PDF
- Chapter 18 Adjuster Licensing (Draft W/Track Changes) - PDF
Comments Received:
In 2022, the Working Group began working on their charge to:
Review existing 不良研究所官方 Models and Guidelines that address the use of lead generators for sales of Health Insurance products and identify models and guidelines that need to be updated or developed to address current marketplace activities.
The Working Group exposed suggested amendments on the Unfair Trade Practices Act (Model 880) for comment. Throughout the year the Working Group met via conference calls to discuss the comments received and revised the Draft as necessary.
The Working Group has exposed the 2nd Draft amendments for additional comments. (Draft Version 11.3.22).
These comments will be discussed at during the Working Group meeting taking place at the Spring National Meeting in Louisville, KY.
The Working Group will hold conference calls as necessary to finalize the amendments. The final draft will be distributed prior adoption.
Draft # 1:
Model 880 - Amendments Draft #1 8.31.22
Draft #2:
Model 880 - Amendments Draft #2 11.3.22
Draft #3:
Model 880 - Amendments Draft #3 6.29.23
New Comments Received:
- MO DOI Comments (7.21.23)
- 不良研究所官方 Consumer Reps Comments (7.25.23)
- AHIP Comments (7.21.23)
State Comments:
- HI DOI Comments (3.29.23)
- ME DOI Comments (11.18.23)
- MO DOI Comments (3.13.23)
- OH DOI Comments - PLMA (Model 218)
- OH DOI Comment Letter 11.15.22
- OH DOI Comment Letter 11.18.22
- OK DOI Comments (9.30.22)
- RI DOI Comments (8.1.22)
Industry Comments:
- ACLI Comments (9.30.22)
- AHIP Comment (9.30.22)
- AHIP Comment (11.18.22)
- AHIP Updated Comments (11.2.22)
- Health Benefits Institute Comments (9.30.22)
- 不良研究所官方 Consumer Representatives Comments (9.30.22)
- NAHU Comments (9.30.22)
2025 Exposure Drafts:
Draft New Chapter Conducting the Pet Insurance Examination May 22, 2025 Draft Comments Due Date June 21, 2025
Draft Chapter 21A-Conducting the Property and Casualty Travel Insurance Examination July 17 2025 Draft (Revisions to the February 11, 2025 Draft were made, in consideration of the APCIA and UStiA 03-12-25 Comments) Comments Due Date August 15, 2025
Draft Chapter 21A-Conducting the Property and Casualty Travel Insurance Examination February 11, 2025 Draft (Updated to add Review Procedures and Criteria and Documents to be Reviewed) Comments Due Date March 12, 2025
2024 Exposure Drafts:
Draft Chapter 23-Conducting the Life and Annuity Examination Chapter October 4, 2024 Draft (Updated to correspond to Actuarial Guideline XLIX-A鈥擳he Application of the Life Illustrations Model Regulation to Policies with Index-Based Interest (AG 49-A). NOTE: The Oct. 4, 2024 draft Chapter 23 was adopted by the Working Group at its Nov. 7, 2024 Webex meeting,
2023 and Prior Years' Exposure Drafts:
Draft Chapter 23-Conducting the Life and Annuity Examination October 4, 2023 Draft (The Oct. 4, 2023 draft contains changes from the previous version, dated June 6, 2023. The October 4, 2023 updates in the draft are highlighted in green, they occur on pages 14, 17, 29, 31, 32, 33, 38, 40, 45, 52, 55 and 56.)
NOTE: The Oct. 4, 2023 draft Chapter 23 was adopted by the Working Group at its Nov. 8, 2023 Webex meeting, the chapter underwent additional revisions during that meeting, as part of that adoption.
Draft Chapter 23-Conducting the Life and Annuity Examination June 6, 2023 Draft (The June 6, 2023 draft contains changes from the previous version, dated Aug. 22, 2022. The June 6, 2023 updates in the draft are highlighted in blue, they occur on pages 30 and 34 (in Marketing and Sales Standards 9 and 10.)
Draft Chapter 23-Conducting the Life and Annuity Examination August 22, 2022 Draft (The Aug. 22, 2022 draft contained updates highlighted in yellow, which took into consideration comments received on the April 19, 2022 draft; the Aug. 22 draft was discussed at the Sept. 8 and Oct. 20, 2022 meetings and at the March 28, 2023 meeting.)
New Draft Chapter 23-Conducting the Life and Annuity Examination April 19, 2022 Draft (Updated to correspond to revisions adopted by the 不良研究所官方 in February 2020 to the Suitability in Annuity Transactions Model Regulation (#275))
New Draft Travel Insurance-Related Standardized Data Requests (Revised October 2023 by the Travel Insurance regulator-only SMEs, taking the comments received from Virginia Oct. 28, 2022, Missouri Sept. 16, 2022 and the CEJ Sept. 16, 2022 into consideration)
- Revised Travel In Force SDR, October 25, 2023 Draft Redline
- Revised Travel In Force SDR, October 25, 2023 Draft Redline Accepted
- Revised Travel Claims SDR, October 25, 2023 Draft Redline
- Revised Travel Claims SDR, October 25, 2023 Draft Redline Accepted
NOTE: The Oct. 25, 2023 new draft Travel Insurance In-Force SDR and the Oct. 25, 2023 new Travel Insurance Claims SDR were adopted by this Working Group at its Nov. 8, 2023 Webex Meeting
- Travel In Force SDR, August 17, 2022 Draft
- Travel Claims SDR, August 17, 2022 Draft
Draft Chapter 4-Collaborative Actions June 6, 2023 Draft (The purpose of the revisions is to incorporate changes into Chapter 4, providing nonregulators with transparency and insight regarding the multistate process that occurs at the Market Actions (D) Working Group (MAWG))
NOTE: The June 6, 2023 draft Chapter 4 was adopted by the Working Group at its July 18, 2023 Webex meeting, the chapter underwent additional revisions during that meeting, as part of that adoption.
Revised Draft Chapter 24B-Conducting the MHPAEA-Related Examination July 11, 2022 Draft (This draft was discussed at the July 14, 2022 Webex. Changes were made to Standard 5 on pages 14-15 and Standard 6 on pages 17-18; they are shown in yellow highlight. These revisions were made to the July 6, 2022 Chapter 24B Draft).
NOTE: The Chapter 24B-Conducting the MHPAEA-Related Examination adopted by this Working Group on July 14, 2022 and by the Market Regulation and Consumer Affairs (D) Committee on August 12, 2022 at the Summer 2022 Hybrid National Meeting is provided at this link Chapter 24B-Conducting the MHPAEA-Related Examination Adopted 8-12-2022. Regulators, this document is also provided on the Market Regulation Handbook Web Page on StateNet.
New Draft Chapter 24B-Conducting the MHPAEA-Related Examination July 6, 2022 Draft (Updated with regard to the Working Group's June 9th discussion on comments received on the April 19, 2022 Chapter 24B Draft)
New Draft Chapter 24B-Conducting the MHPAEA-Related Examination April 19, 2022 Draft (Updated to correspond with updated federal guidance on Mental Health and Substance Use Disorder Parity Compliance)
- WI 05-25-22 Comments
- MO 05-27-22 Comments
- VA 05-27-22 Comments
- AHIP 05-27-22 Comments
- ABHW 05-27-22 Comments
- BCBSA 05-27-22 Comments
New Draft Chapter 1-Introduction July 6, 2022 Draft (Revisions relate to the Working Group's discussion re: the Oct. 27, 2021 Chapter 20 draft in its previous meetings on Nov. 4, 2021, March 10, 2022, April 21, 2022 and June 9, 2022)
NOTE: The posted revisions to the July 6, 2022 draft Chapter 1-Introduction were adopted by the Working Group on its July 14, 2022 call.
New Draft Chapter 20-General Examination Standards July 6, 2022 Draft (Revisions relate to the Working Group's discussion re: the Oct. 27, 2021 Chapter 20 draft in its previous meetings on Nov. 4, 2021, March 10, 2022, April 21, 2022 and June 9, 2022)
NOTE: The posted revisions to the July 6, 2022 draft Chapter 20-General Examination Standards were adopted by the Working Group on its July 14, 2022 call.
New Draft Chapter 20-General Examination Standards, Oct. 27, 2021 Draft (Revisions Relating to the Insurance Holding Company System Regulatory Model Act (#440)
- ACLI 05-18-22 Comments
- NV 04-14-22 Comments
- AHIP/BCBSA 04-15-22 Comments
- AHIP/BCBSA 04-15-22 FAH Market Conduct Communications 04-15-22 Excerpt
- State Farm Nov. 24, 2021 Comments
- ACLI Dec. 17, 2021 Comments
New Draft Chapter 21-Conducting the Property and Casualty Examination, April 19, 2022 Draft Revisions to the 4-19-22 draft are shown in yellow highlight (Revisions Relating to the Real Property Lender-Placed Insurance Model Act (#631)
NOTE: The posted revisions to the April 19, 2022 Conducting the Property and Casualty Examination chapter were adopted by the Working Group on its April 21, 2022 call.
New Draft Chapter 21-Conducting the Property and Casualty Examination, Oct. 27, 2021 Draft (Revisions Relating to the Real Property Lender-Placed Insurance Model Act (#631).
- Industry Trade Associations Nov. 11, 2021 Comments Received by the 不良研究所官方 on Nov. 23, 2021
- Examination Resources Dec. 17, 2021 Comments
New Draft Chapter 24-Conducting the Health Examination, Sept. 30, 2021 Draft (Revisions Relating to the Health Maintenance Organization Model Act (#430)
NOTE: The draft Chapter 24 was adopted by the Working Group on its November 4, 2021 conference call,
New Draft Chapter 25-Conducting the Medicare Supplement Examination, Sept. 27, 2021 Draft (Revisions Relating to the Model Regulation to Implement the 不良研究所官方 Medicare Supplement Insurance Minimum Standards Model Act (#651)
NOTE: The draft Chapter 25 was adopted by the Working Group on its November 4, 2021 conference call, the chapter underwent an additional revision as part of that adoption.
Updated Draft Title Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
New Draft Title Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
- Title In Force SDR March 23, 2021 Draft
- Title Claims SDR March 23, 2021 Draft
- RI 04/01/21 Comments
- NE 04/23/21 Comments
- CEJ 04/23/21 Comments
- ALTA 04/23/21 Comments
- CO 04/29/21 Comments
NOTE: The Title SDRs were adopted by the Working Group on its September 2, 2021 conference call, the Title Claims SDR underwent an additional revision as part of that adoption.
NOTE: The posted revisions to the Conducting the Health Examination chapter were adopted by the Working Group on its November 19, 2020 call.
New Draft Long-Term Care Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
NOTE: The Long-Term Care In Force and Long-Term Care Claims SDRs were adopted by the Working Group on its November 19, 2020 call.
New Inland Marine Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
NOTE: The Inland Marine In Force and Inland Marine Claims SDRs were adopted by the Working Group on its July 23, 2020 call.
NOTE: The Limited Long-Term Care Exam Standards, Dec. 11, 2019 draft, were adopted by the Working Group on its July 23, 2020 call.
New Farmowners Standardized Data Requests for Inclusion in the Reference Documents of the Market Regulation Handbook
NOTE: The Farmowners In Force SDR and Farmowners Claims SDR were adopted by the Working Group on its Dec. 18, 2019 call, and adopted by the Market Regulation and Consumer Affairs (D) Committee on its July 27, 2020 call.
Cybersecurity (EX) Task Force Referral to Market Conduct Examination Standards (D) Working Group
The following items have been tabled by the Working Group until further notice.
Draft New Health Reform Market Conduct Examination Standards for Nondiscrimination for inclusion in the Market Regulation Handbook
Aug. 10, 2015 Draft
- 不良研究所官方 Consumer Representatives' 9/03/15 Comments
- National Women's Law Center (NWLC) 9/03/15 Comments
Draft New Health Reform Market Conduct Examination Standards for Nondiscrimination for inclusion in the Market Regulation Handbook
Aug. 3, 2015 Draft
Section D. Standards of Chapter 14-Sampling of the Market Regulation Handbook 9/18/14
There are no exposure drafts at this time.
There are no exposure drafts at this time.
MCAS - Pet Insurance Scorecard Ratios Draft
- Pet Insurance Scorecard Ratios v1.9 2/21/2024
Charge to Assess Currently Available Market Analysis Data
- Market Analysis Data Sources 6/23/2023
Draft Documents
Other Health
Other Health MCAS Blank - Draft Approved by Working Group - 05/22/25
Other Health MCAS Data Call and Definitions - Draft Approved by Working Group - 05/22/25
Private Passenger Auto
Private Passenger Auto MCAS Blank - Draft Approved by Working Group - 05/01/25
Private Passenger Auto MCAS Data Call and Definitions - Draft Approved by Working Group - 05/01/25
Lender Placed Home and Auto (LPI)
LPI MCAS Blank - Draft Approved by Working Group - 05/22/25
LPI MCAS Data Call and Definitions - Draft Approved by Working Group - 05/22/25
Homeowners
Homeowners MCAS Blank - Draft Approved by Working Group - 05/22/25
Homeowners MCAS Data Call and Definitions - Draft Approved by Working Group - 05/22/25
Pet
Pet MCAS Data Call and Definitions - Draft Approved by Working Group - 05/22/25
Disability Income
Disability Income MCAS Blank - Draft Approved by Working Group - 05/22/25
Disability Income MCAS Data Call and Definitions - Draft Approved by Working Group - 05/22/25
Long-Term Care (LTC)
LTC MCAS Blank - Draft Approved by Working Group - 05/22/25
LTC MCAS Data Call and Definitions - Draft Approved by Working Group - 05/22/25
Short-Term Limited Duration (STLD)
STLD MCAS Blank - Draft Approved by Working Group - 05/22/25
STLD MCAS Data Call and Definitions - Draft Approved by Working Group - 05/22/25
MCAS Proposals
Travel
DRAFT Travel MCAS Blank - Exposed to Working Group - 05/22/25
DRAFT Travel MCAS Data Call and Definitions - Exposed to Working Group - 05/22/25
Market Regulation Certification Program v2.44 clean 05/09/2023
Certification Program Scoring Matrix 04/19/2023
Market Regulation Certification Implementation Plan Adopted 12/9/2022
The Task Force's Improper Marketing of Health Insurance (D) Working Group has been working on its charge to:
Review existing 不良研究所官方 Models and Guidelines that address the use of lead generators for sales of Health Insurance products and identify models and guidelines that need to be updated or developed to address current marketplace activities.
The Working Group began reviewing the Unfair Trade Practices Act (Model 880) in 2022. During the 2023 Summer National Meeting the Working Group adopted amendments to Model 880 (8.14.23).
The Task Force opened the adopted draft (8.14.23) for comment through Monday, Oct. 16, 2023.
The Task Force met by conference call on October 20th to review comments received on draft amendments for the Unfair Trade Practices Act (Model #880).
During the conference call the Task Force agreed to accept additional revisions from the comments received. The additional revisions have been applied to Draft #6 (10.20.23).
The Draft #6 (10.20.23) was open for comment until Friday, Nov. 10, 2023.
The Task Force will review the updated draft (10.20.23) for potential adoption.
Draft #6 (10.20.23):
Comments Received on Draft #6 (10.20.23):
-----------------------------------------------------------------
Draft #5 (8.14.23):
Comments Received on Draft #5 (8.14.23):
- Missouri DOI Comments
- Missouri DOI Comments (within Model)
- Virginia DOI Comments
- Coalition Against Insurance Fraud and 不良研究所官方 Consumer Representatives Comments
- Coalition Against Insurance Fraud and 不良研究所官方 Consumer Representatives Comment Letter
---------------------------
Antifraud Plan Repository Workflow
The Antifraud Technology (D) Working Group has been working on their first charge which is to: Review and provide recommendations for the development of an Antifraud Plan Repository to be used by insurers to create and store an electronic fraud plan for distribution among the states/jurisdictions. To assist with this process the Working Group created a subject matter expert (SME) group to finalize the Antifraud Plan Repository Workflow document. The SME Group exposed the draft to the Antifraud Technology (D) Working Group on May 6, 2022.
The Working Group adopted the draft on May 19, 2022 and it was presented to the Antifraud (D) Task Force. The Task Force will hold a meeting on June 30, 2022 to review any comments received and potentially adopt the draft.
Antifraud Plan Repository Workflow
There are no exposure drafts at this time.
UNIFORM LICENSING STANDARDS
The Working Group has requested state updates to the Uniform Licensing Standards Compliance Charts.
The ULS charts were last updated in 2017. To confirm we have the correct information; we are asking each state to review the ULS Checklist and provide their responses.
For any non-compliance areas please indicate whether it is due to a regulation/rule or a department process. In addition, if there is any legislation pending please update the chart with that information.
We are still working to collect all state responses. Please send your responses back to me at Gwelker@naic.org and Courtney.Khodabakhsh@oid.ok.gov.
不良研究所官方 STATE LICENSING HANDBOOK REVIEW
The Producer Licensing Uniformity (D) Working Group has been given the charge to: Provide oversight and ongoing updates to the State Licensing Handbook, as needed.
The Working Group distributed a State Licensing Handbook checklist listing out each chapter with an option to select 鈥淵ES or NO鈥 whether the chapter should be opened for review. The checklist results are copied below.
The Working Group is currently reviewing the State Licensing Handbook. At this time, the Working Group is soliciting comments/suggestions on Chapter 9 Lines of Insurance, Chapter 10 Surplus Lines and Chapter 11 Appointments.
Please review the chapters and provide your suggestions/comments by Friday, July 11, 2025 to Gwelker@naic.org, Courtney.khodabakhsh@oid.ok.gov and Monicka.richmeier@ks.gov.
State Licensing Handbook - Chapters
- 1 鈥 Modern Producer Licensing
- 6 鈥 Prelicensing Education
- 7 鈥 Application Review for Initial Licenses
- 8 鈥 Testing Programs
- 9 鈥 Lines of Insurance
- 10 鈥 Surplus Lines Producer Licenses
- 11 - Appointments
- 12 鈥 Business Entity
- 13 鈥 Temporary Licenses
- 14 鈥 Continuing Education
- 18 鈥 Adjuster
- 19 鈥 Bail Bonds Agent
- 24 鈥 Managing General Agents
- 25 鈥 Multiple Employer Welfare Arrangements
- 30 鈥 Viatical and Life Settlement Brokers
Chapter 9, 10 and 11 Comments Received (as of 7.11.25):
- CA, WA, & SILA Comments - Chapter 11
- NC Comments - Chapter 11
- ND Comments - Chapter 9, 10 and 11
- RI Comments - Chapter 9
- VA Comments - Chapter 11
- CIAB & WSIA Comments - Chapter 10 (12.30.24)
- CIAB & WSIA Comments - Chapter 10 (8.1.25)
- CIAB Comments - Chapter 11
SLH - Checklist Individual Responses:
The State Licensing Handbook (individual chapters and appendix) can be found on the 不良研究所官方 website: /state_licensing_handbook.htm
The Working Group will continue to meet monthly in order to review the State Licensing Handbook.
_________________________________________________________________________
不良研究所官方 State Licensing Handbook
The Producer Licensing Uniformity (D) Working Group has asked the Uniform Education (D) Working Group to review State Licensing Handbook chapters specific to continuing education. The three chapters identified are:
- Chapter 6 鈥 Prelicensing Education
- Chapter 8 Testing Programs
- Chapter 14 Continuing Education.
To efficiently review these chapters the Working Group is asking to review Chapter 6 鈥 Prelicensing Education first. Once comments have been received the Working Group will meet by conference call to review and begin reviewing potential revisions for the State Licensing Handbook. The chapters have been copied below.
Please submit your suggestions/comments to Gwelker@naic.org.
- SLH - Chapter 6 Prelicensing Education
- SLH - Chapter 8 Testing Programs
- SLH - Chapter 14 Continuing Education
*The Working Group is currently taking comments on all three chapters. The Working Group will continue to meet monthly to review and finalize.
SLH Chapter Edits:
- SLH - Chapter 6 Prelicensing Education - (Draft Edits 5.7.25)
- SLH - Chapter 8 Testing Programs - (Draft Edits 6.18.25)
-
SLH - Chapter 14 Continuing Education - (Draft Edits Coming Soon)
SLHB Comments Received:
- CA DOI Chapter 6
- CA DOI Chapter 8 (6.9.25)
- CA DOI Chapter 14
- OK DOI Chapter 6
- OK DOI Chapter 8
- ME DOI Chapter 8
- ME DOI Chapter 14
- ACLI Chapter 8 (6.17.25)
- PIA Comments
- VA Comments Chapter 6
- VA Comments Chapter 8
- VA Comments Chapter 14
---------------------------------
CE Audit Procedures
The Uniform Education (D) Working Group adopted the 不良研究所官方 CE Audit Guidelines on Oct. 29, 2024. The adopted document can be found below. The Producer Licensing (D) Task Force will review the document at the Fall National Meeting as part of the Working Group reports.
CE Audit Guidelines (Adopted by UEWG on Oct. 29, 2024)
Continuing Education Reciprocity Agreement
In 2019, the Working Group reviewed the Continuing Education Reciprocity (CER) Agreement. The 不良研究所官方's General Counsel advised the Working Group that a revision of the agreement would not be feasible due to the date of the CER Agreement and inaccurate/dated information it contains. The decision was to create a new CER Agreement. During the Fall National Meeting the Producer Licensing (D) Task Force adopted the 2019 CER Agreement. The agreement will be presented to the Executive (EX) Committee during the Summer National Meeting for final adoption. The adopted draft is attached below.
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Testing and Examination Pass Rates
The draft 2026 charges for the Financial Condition (E) Committee and the working groups that report directly to the E Committee are exposed for a 45-day comment period (until COB Oct. 2). The proposed 2026 charges for the E Committee task forces are excluded and will be added into these revised charges once adopted by the applicable task force. However, the old Valuation of Securities (E) Task Force has now been renamed the Invested Assets Task Force and those charges, along with the three new working group under the Invested Assets (E) Task Force, were adopted by the Committee in July. The combined task force and working group charges will be presented to the Committee for possible adoption in November. Please send any comments on the attached to 不良研究所官方 staff Dan Daveline by COB October 2.
Exposure Drafts Still Open For Consideration with Comments Received:
Investment Framework
The following document is exposed for a 30-day comment period ending August 15, 2025, please submit comments to Maggie Chang.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
During the December 12th, regulator call, the National Treatment and Coordination (E) Working Group discussed a new Corporate Amendment change type. The new change type is Reinstatement. The Working Group is exposing the new change type for Corporate Amendments and Instructions for a 45-day comment period ending February 17, 2025, please submit comments on the edits or suggestions to Bon Rector.
Comments on exposed items should be addressed to Director Elizabeth Kelleher Dwyer and Commissioner Glen Mulready, Co-Chairs of the Restructuring Mechanisms (E) Working Group, and directed to 不良研究所官方 staff, Robin Marcotte and Dan Daveline.
The following documents have been exposed with a public comment period ending Friday, July 12, 2024
Comment Letters:
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
Blanks (E) Working Group
Items Received for Comment
Last Updated May 29, 2025
Please address comment letters to Roy Eft, Chair of the Blanks (E) Working Group, and direct to 不良研究所官方 support staff, Mary Caswell and Jill Youtsey.
| Ref No. | Description | Comment Deadline |
| 2025-16BWG | Update Health Annual Statement Instructions for the Prescribed Language for Statement of Actuarial Opinion, Section 4 (Identification Section) for consistency in reporting. Also update the Statement of Actuarial Opinion, Section 7 (Opinion Section), Item C, to be consistent with the Life/Fraternal Annual Statement Instructions and VM-30. | July 14, 2025 |
Exposure Drafts Outstanding
Statutory Accounting Principles (E) Working Group
Last Updated: August 11, 2025
Please address comment letters to Dale Bruggeman, Chair of the Statutory Accounting Principles (E) Working Group, and direct to Julie Gann, Robin Marcotte, Jake Stultz, Jason Farr and Wil Oden.
For the status of all SAPWG agenda items, please refer to the Maintenance Agenda. (updated June 5, 2025)
| EXPOSURES with PUBLIC COMMENT PERIOD ending JUNE 6, 2025 | |||
| 2025-12EP | Preamble | Editorial Revisions | Exposed editorial footnote revisions clarify the treatment of issue papers in Level 5 of the statutory hierarchy and update the reference to U.S. Securities and Exchange Commission (SEC) rules and interpretations as authoritative U.S. GAAP for SEC registrants. |
| EXPOSURES with PUBLIC COMMENT PERIOD ending SEPTEMBER 19, 2025 | |||
| 2025-19 | Annual Statement | Private Securities | Exposed revisions incorporate a new electronic reporting column to identify private placement securities in the investment schedules and incorporate an aggregate disclosure that details key investment information by type of security (public and private placement type). |
| EXPOSURES with PUBLIC COMMENT PERIOD ending OCTOBER 17, 2025 | |||
| 2024-21 | Annual Statement | Investment Subsidiaries | Exposed revisions eliminate the investment subsidiary concept from the instructions. The intent to send a referral to the Life Risk-Based Capital (E) Working Group upon adoption of the agenda item, along with suggested RBC instruction changes, is also exposed. |
| 2025-01 | SSAP No. 22 | Lease Clarification | Exposed expanded revisions clarify that sale-leasebacks with restrictions on access to the cash received from the sale do not qualify for sale-leaseback accounting and must be accounted for by the seller using the financing method. With this exposure, comments are requested on transition guidance for companies that have arrangements that will no longer qualify as sale-leasebacks. |
| 2025-13 | SSAP No. 37 | Statutory Trusts | Exposed revisions to the draft guidance allow residential mortgage loans in qualifying statutory trusts to reflect several recommended changes per discussions with industry. |
| 2025-18 | SSAP No. 101 | ASU 2019-12, Simplifying the Accounting for Income Taxes |
Exposed revisions adopt, with modification, certain revisions from ASU 2019-12, and recommend fully incorporating U.S. GAAP guidance from APB No. 28, which had previously been incorporated by reference. |
| 2025-20 | SSAP No. 26 SSAP No. 21 SSAP No. 43 Annual Statement |
Debt Disclosures | Exposed revisions improve utilization of existing disclosures, clarify guidance, and incorporate consistent locations and frequency for specific debt security disclosures. The revisions also propose disclosures for residuals that identify the company鈥檚 measurement method, whether the company is transitioning from the practical expedient to the allowable earned yield (AEY) method, and for those following the AEY method, information comparable to SSAP No. 43 for impaired securities. |
| 2025-21 | Annual Statement | Retirement Plan Assets Held at NAV | Exposed revisions clarify that retirement plan assets can be held at net asset value (NAV) and shall be included in the required fair value disclosure. |
| EXPOSURES DEFERRED for SUBSEQUENT INTERIM or NATIONAL MEETING | |||
| 2018-07 | SSAP No. 41 | Surplus Note Accounting 鈥 Referral from the Reinsurance (E) Task Force | The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent interim or national meeting. |
| SSAP No. 68 | ASU 2014-17, Business Combinations, Pushdown Accounting | The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent interim or national meeting. | |
| SSAP No. 68 SSAP No. 97 |
Attribution of Goodwill | The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent interim or national meeting. | |
| SSAP No. 62 | Retroactive Reinsurance Exception | The Statutory Accounting Principles (E) Working Group deferred discussion of this agenda item for a subsequent interim or national meeting. | |
| 2023-31 | SSAP No. 58 | Updates from Model 630 Mortgage Guaranty Insurance | Exposed intent to review the revisions to the Mortgage Guaranty Insurance Model Act (#630) for incorporation into SSAP No. 58鈥擬ortgage Guaranty Insurance and Appendix A-630 as applicable. The exposure requests input on an effective date. |
| 2024-12 | SSAP No. 27 | Updates to SSAP No. 27 | This agenda item was deferred at the 2024 Summer National Meeting to be discussed at a subsequent meeting. |
The Capital Adequacy (E) Task Force is exposing the following for a 45-day public comment period ending August 14, 2025, please submit comments to Eva Yeung.
The following documents are exposed by the Working Group Please submit comments to Derek Noe by COB, June 30, 2025.
Extension: The following documents are being exposed for a 30-day public comment period ending Friday, September 19th Wednesday, August 20th:
Please send comments to Jane Ren by September 19th August 20th, 2025
The following document is being exposed for a 45-day public comment period ending Monday, June 23rd:
Please send comments to Jane Ren by June 23rd, 2025.
The following documents are exposed for a 30-day comment period ending June 1, 2025, please submit comments to Eva Yeung.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The following document is being exposed for a 30-Day public comment period ending Tuesday, September 2nd:
Please send comments to Topher Hughes by September 2nd, 2025
On behalf of the Chair of the Task Force, the 2026 proposed charges for the Task Force and its Working Groups are exposed for public comment. No changes from 2025 charges are proposed.
Please submit any comments to jkoenigsman@naic.org by close of business July 23, 2025.
There are no Exposure Drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The following documents are being exposed for a 30-day public comment period:
P&P Manual Amendment to Permit a 30-day Grace Period to File a Private Rating Letter Annual Update
Blanks Update for Security Identifiers
P&P Manual Amendment to Change the Effective Date for the Financial Modeling of CLOs by SSG to 2026
Comments should be sent electronically to Charles Therriault and Denise Genao by Friday, September 12, 2025.
There are no exposure drafts at this time.
The following document is being exposed for a 60-day public comment period ending, Monday, September 15th, 2025, please send comments to Amy Fitzpatrick.
The following documents are being exposed for a 30-day public comment period ending Friday, September 12th:
- VM-21 Supplement Blank 8-13 Exposure for 30 days (1).docx
- DRAFT_Life_and_Fraternal_2026_VM21_Reserves_Supplement_Instructions_v20250725 with Opt
Please send comments to Jane Ren by September 12th, 2025
Extension: The following documents are being exposed for a 30-day public comment period ending Friday, September 19th Wednesday, August 20th:
Please send comments to Jane Ren by September 19th August 20th, 2025
At the Summer National Meeting, the Committee exposed the following items for a 30-day comment period ending September 12:
- Revisions to the Review Team Guidelines and Self-Evaluation Guide in Part C: Organizational and Personnel Practices to include new guidelines related to conflicts of interest and confidentiality protections when using contract resources.
- Revisions to the Self-Evaluation Guide in Part B1: Financial Analysis, Part B3: Department Procedures and Oversight, and Part C: Organizational and Personnel Practices to include new items to be reported by states when submitting interim annual reviews, including additional details pertaining to domestic multi-state insurance companies and staffing fluctuations.
Revisions can be found here. Please send any comments to Bailey Henning (bhenning@naic.org) by close of business on Friday, September 12.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
There are no exposure drafts at this time.
The Cybersecurity (H) Working Group is exposing the CFRF Referral Response and IDSM Compliance Guide, attached below, to all interested parties for a public comment period of 30 days, ending Saturday, Sept. 13, 2025.
CFRF Referral Response - Draft
IDSM Compliance Guide v5- Tracked Changes
IDSM Compliance Guide v5- Clean Copy
Please submit comments in writing to Koty Henry (khenry@naic.org) by Saturday, Sept. 13, 2025. If providing edits to the draft, please use underline/strikeout, if possible.
If you have any questions, please contact Miguel Romero (maromero@naic.org) or Koty Henry (khenry@naic.org).
There are no exposure drafts at this time.
The Third-Party Data and Models (H) Working Group met May 22, 2025, and requested proposed definitions of third-party data vendor and third-party model vendor for use in a regulatory framework. Please send to Kris DeFrain (kdefrain@naic.org) by Friday, June 20.
The Big Data and Artificial Intelligence (H) Working Group is exposing the AI Systems Evaluation Tool, attached below, to all interested parties for a extended public comment period of 60 days, ending Friday, Sept. 5, 2025.
Please submit comments in writing to Scott Sobel (ssobel@naic.org) by Friday, Sept. 5, 2025. If providing edits to the draft, please use underline/strikeout mode if possible.
If you have any questions, please contact Miguel Romero (maromero@naic.org) or Scott Sobel (ssobel@naic.org).
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The Big Data and Artificial Intelligence (H) Working Group is exposing a request for information regarding proposing an 不良研究所官方 Model Law on the Use of Artificial Intelligence in the Insurance Industry.
Any stakeholder wishing to provide comments regarding this request for information should submit them in writing to Miguel Romero (maromero@naic.org) within a 45-day comment period ending Monday, June 30. Comments will be made public upon completion of the comment period.
Articles Exposed for Comment:
Article V Request for Comments
This is a request for comments on Article V of the Chair Draft Revising the Privacy of Consumer Financial and Health Information Regulation (#672). Comments are due by June 18, 2025.
Articles Exposed Without Comment at This Time:
Article IV Exposure Clean Version