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Top stories
• Regulators move to enhance the system
• NAIC principals weigh in on systemic risk
• Credit scoring debate takes center stage
• NAIC ponders natural catastrophe solutions
• Next steps for climate change d isclosure
• Reinsurance modernization efforts advance
Also in this issue
• NAIC accounting update
What’s next
• July 9-12, 2009: NCOIL 2009 Summer National Meeting,Philadelphia, PA
• September 21-24: NAIC 2009 Fall National Meeting,Washington, D.C.
Minneapolis, MN – With the question of a federal
regulatory mechanism for insurance actively being
discussed in Washington, D.C., regulators and industry
representatives attending the National Association
of Insurance Commissioner’s Summer 2009 National
Meeting focused on measures meant to improve
and strengthen the state-based system for insurance
regulation that’s been in place for more than 150 years.
From considering enhancements to the supervision of
insurance groups to adopting a complete revision to the
NAIC’s approach to derivative investments, regulatorscontinued the work of dusting off and revising existing
models and creating new ones – all in the name of
meeting the challenges of today’s marketplace.
Another focus has been to maintain consumer
protection and the strength and solvency of the
insurance industry in the face of a significant natural
catastrophe, or “mega cat.” To this end – and after
several years of deliberation – regulators passed out
of a parent committee a catastrophe white paper that
represents divergent views on addressing this important
area of industry risk. In this arena, too, the NAIC is
considering the construction of a catastrophe model
for varied natural disasters. The tool would be of similar
caliber to those used by professional modeling firms
and would allow regulators a window on learning
the risks so that they might better know what are the
appropriate rates and policy pricing for insurers who
cover these risks.
The topic of climate change continued to take the floor
as well. After adopting its climate change disclosure
survey at the spring meeting in March, the NAIC and
industry continued discussion on next steps, includinga regulator proposal to have companies file their
disclosure forms on the NAIC web site, rather than with
the regulator of their state domicile, as had previously
been discussed.
While the answer to the question of a federal regulator
has yet to be revealed, items serving to keep up the
momentum at future meetings include credit-based
insurance scoring; the advancement of the Standard
Valuation Law and changes to the group insurance
model law.
Summer 2009
NAIC Update
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With globalization ever at hand,regulators at the summer meetingdrove forward several model lawsmeant to modernize insuranceregulation.
Top stories
Regulators move to enhance the system
With globalization of the insurance industry ever at hand
and proposals both great and small in Washington, D.C.
to do everything from tweak to overhaul the current
state-based system of insurance regulation, regulators
at the summer meeting drove forward several important
model laws and revisions meant to modernize insurance
regulation. Some top items included: The passage of
a complete revision of the derivatives model law; the
advancement of principles-based reserving; and new
attention given to the supervision of insurance groups.
Derivatives
Regulators at the joint Executive Committee/Plenary
adopted amendments to the Derivatives Instrument Model
Regulation as part of a broader effort to modernize the
NAIC regulatory framework for these nancial instruments.
Since the 1990s, derivatives, including credit default swaps,
have become a signicant nancial instrument for insurers,
and therefore require more uniform and stringent oversight,
according to the NAIC.
One of the chief changes to the law is to require of insurers
a derivative use plan that has been reviewed and approved
by the state insurance regulator before a company would
be authorized to engage in derivatives transactions. The
plan must also be approved by a company’s board of
directors. The board would also be required to take action
to correct any deciencies in internal controls relative toderivative transactions.
Standard valuation law
Regulators took a signicant step towards making
principles-based reserving approach to the valuation of life
and annuity products a reality.
Passed out of the Life and Health Actuarial Task Force
following years of discussion, the revised Standard
Valuation Law was met with caution by the parent Life
Insurance and Annuities (A) Committee. Rather than pass
the item out to the Executive Committee, the A Committee
opted to open the item for a 30-day comment period to
be followed by a teleconference by the Principles-Based
Reserving Working Group and the Solvency Modernization
Initiative Task Force.
Insurance groups
The NAIC’s Group Solvency Issues working group is movingahead with its investigation into the feasibility of changes
to the NAIC Holding Company Model Act to better reect
challenges being seen in the marketplace.
At its meeting during the summer conference, the group
set its sights on scheduling an interim meeting that would
position regulators and industry to discuss divergent points
of view with hopes of coming to a consensus.
Comments received so far include those from regulators in
Illinois, Kansas, Missouri, Nebraska, North Carolina, South
Carolina, Virginia, Washington, and Wisconsin. Meanwhile,
interested parties weighing in include the Property Casualty
Insurers Association of America, the American Insurance
Association and the American Council of Life Insurers.
Emboldening oversight of insurer groups has been one
of the major goals of the NAIC’s Solvency Modernization
Initiative since it was formed amid notable changes in
the marketplace in the fall of 2008. The 2009 charge
of the working group regarding insurance groups is to
study the need to modify the model act to the extent it
addresses issues identied in the current environment. At
the conclusion of the study, the working group is to decide
whether a model law development/revision is in order.
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State regulators weigh in on systemic risk
The future of the state-based insurance regulation and
how that ts into what is being contemplated by the
Obama administration and the 111th Congress in regards
to changes in the oversight of the nancial sector are very
much top of mind for ofcials at the NAIC.
As the current environment has sparked considerable
interest to repair what are seen as gaps in the broader
nancial system, NAIC principals have found themselves
facing federal lawmakers a number of times in recent
months in an effort to both educate and to state the case
for state-based insurance regulation.
And while attendees at the Minneapolis meeting seemed to
fall on both sides of the issue – some in favor of a federal
regulator, others wanting to stick with the current regulatoryregime – NAIC President and New Hampshire Insurance
Regulator Roger Sevigny and NAIC CEO Terri Vaughan made
their thoughts very clear at the summer meeting.
“The rhetoric being tossed back and forth on Capitol Hill
questions the oversight offered by a state-based system,”
Sevigny said during the summer meeting opening session.
“As a whole, the insurance industry continues to be strong
in this erratic economy – in part because of the strengths of
our system. So the question is, why reinvent the wheel?”
For her part, Vaughan asked state regulators in attendance
to offer their input on how states might t into the council
approach being discussed on the federal level.
In response, NCOIL past President and Rhode Island Rep.
Brian Kennedy said that his group continues to “be against
insurance regulation at a national level but we’re warming
to the idea of a council, sharing thoughts on a state and
federal level.”
The inter-agency council approach has been advocated by
Sen. Susan Collins (R-Maine) as part of a broader package
to reform U.S. nancial regulation. More recently, President
Obama has released a white paper via the U.S. Treasury
which suggests a “council of regulators.”
NCOIL ofcials cautioned, however, that while it was
good to have a “seat at the table” on the federal front; it
should be kept very clear that the overall system of state-
based insurance supervision should continue to be the key
overseer of insurance regulation.
Credit scoring debate takes center stage
The heated topic of credit-based insurance was vetted at
no less than six sessions of the summer meeting as industry
representatives, consumers and regulators clashed on thefairness of the long-time underwriting tool.
While the debate is not new, recent attention to the issue
stems in part from the current challenges in the marketplace
and fears that the newly jobless might unduly be penalized
as their bills go unpaid and their credit scores begin to drop
– thus, putting them in line to pay higher policy premiums.
At the main event – a two-hour hearing – the NAIC’s
Property and Casualty Insurance Committee and Market
Regulation and Consumer Affairs Committee took
comments from an array of interested parties. However, the
joint group failed to take action on the matter as testimony
ran long. A continuation of the debate is scheduled for a
conference call in the near future.
As it stands, consumer representatives, believing that the
practice unfairly discriminates against low income and
minority populations, are urging regulators to ban the use
of credit-based insurance scoring or at the minimum, issue a
temporary moratorium on the tool until a consensus can be
reached by competing interests.
Proponents of the underwriting tool, such as the National
Association of Mutual Insurance Companies, cite the success
of a credit-based insurance scoring model issued by the
National Conference of Insurance Legislators, which balancesthe interests of both consumer and industry. Since adopted
by NCOIL in 2003, 22 states have passed some version of the
NCOIL law. Speaking at the meeting, Candace Thorson of
NCOIL noted that an amendment to the model that targets
consumers whose fallen credit is traceable to the nancial cri-
sis is expected to be considered by legislators at the group’s
summer meeting in July.
Top stories, cont.
NAIC principals leading effort to maintain state-based regulation
Therese M. (Terri) Vaughan
NAIC Chief Executive Ofcer
Roger Sevigny, NAIC President,
New Hampshire Insurance
Commissioner
Photos courtesy of the NAIC
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NAIC ponders natural catastrophe solutions
Fifteen is a charm. At least it is for the NAIC’s Property and
Casualty Insurance (C) Committee, which, after 14 tries over
four years, has adopted a white paper that opines on what
consumers, insurers, and elected ofcials might do to curb
the impact of a so-called, "mega catastrophe."
While on the radar screen of the NAIC for years, the effort
toward the current white paper draft, “Natural Catastrophe
Risk: Creating a Comprehensive National Plan,” began in
2005, shortly following Hurricane Katrina. Since that time,
the document has been vetted by industry, state regulators,
consumer representatives, and other state governing
groups, such as the National Conference of Insurance
Legislators. Over time, controversial provisions, as with the
suggestion that insurers provide an “all perils” for properties
in high-risk zones, drew much disagreement, making
consensus difcult to achieve.
The nal framework outlines steps that regulators believe
must be taken to accomplish the dual purpose of providing
a comprehensive plan that protects the public, while
simultaneously providing assurances (such as a federal
backstop) to the insurance industry in the event of a
catastrophic natural event such as a major hurricane or
earthquake. The multilayered plan includes provisions
such as incentives to hurricane-proof properties (such with
the installation of wind-resistant garage doors), providing
tax-deferred catastrophe reserves for insurers, and making
mandatory offers of all-perils homeowner’s insurance,creating state and regional catastrophe backstops, and
installing a national catastrophe backstop.
The nal draft passed out of C Committee on June 15,
ofcially cited as version 15a, contains a good portion of
the original framework, plus an assortment of opinions and
11th-hour edits made by a collection of states. The white
paper now includes a disclaimer on the cover which notes
that the document represents various opinions and a number
of approaches to addressing natural catastrophe risk.
Next steps for climate change disclosure
With mandatory disclosure of large insurers’ climate
change-related business practices slated to begin in the
2009 reporting year, the NAIC Climate Change and Global
Warming Task Force is contemplating reporting options.
At the task force’s session during the summer confer-
ence, regulators gathered information on which insurance
companies would volunteer to do a test run of the survey
submissions. So far, a collection of life and health insurers
have stepped up to the plate to volunteer and are expected to
submit anonymous results to be released by the fall meeting.
NAIC staff at the session presented regulators with options
by which survey results might be submitted, compiled, and
distributed to the public. These include use of the NAIC’s
Consumer Information Source website, which is availableto regulators and the public, and/or use of the System for
Electronic Rate Form Filing.
As the program was originally slated to operate though
each insurers’ state domiciliary regulator, industry groups
such as the Property Casualty Insurers Association (PCI) have
expressed concern that the test run lays the groundwork for
the NAIC to eventually become the repository of company-
sensitive information.
“(This) opens the much larger question of (the NAIC’s)
authority as a trade association to collate and make
available industry data,” PCI d irector of policy analysis David
Kodama said in a statement issued by the trade.
As to questions on the uniformity of responses, task force
Chairman and Pennsylvania Insurance Commissioner Joel
Ario indicated that the NAIC would not be issuing guidance
as to how to ll out the survey questions.
Adopted at the spring national meeting, the Climate Risk
Disclosure Proposal includes eight questions that require
companies to disclose everything from the actions they
are taking to manage climate change risks to how they are
building climate change awareness into their investment
management strategies.
The proposal requires mandatory disclosure by insures with
premiums over $500 million in the 2009 reporting year
and insurers with premiums over $300 million in the 2010
reporting year.
NAIC Minneapolis meeting by the numbers
Average annual temperature in Minneapolis: 45ºAttendees: 1,500
Sessions: 72
Number of drafts to catastrophe white paper: 15
Changes to 2009 winter meeting location: 1
(Honolulu to San Francisco)
Top stories, cont.
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NAIC accounting update
The National Association of Insurance Commissioners
(NAIC) held their 2009 Summer National Meeting in
Minneapolis, Minnesota from June 12 to June 16, 2009.
This section of the newsletter contains a summary of
the signicant matters impacting statutory accounting
discussed at the NAIC Summer 2009 National Meeting.
Summary
• The Statutory Accounting Principles Working Group
(SAPWG) conducted hearings and meetings to address
comments on certain substantive and nonsubstantive
issues (refer to pages 7 through 9 for details). The
comment deadline for the issues newly exposed at the
meeting is August 7, 2009. Refer to page 9 for details of
certain specic hot topics facing the industry including
– Re-REMIC transactions
– Changes to deferred tax asset admissibility
– Deferred premium asset and unearned premium reserve
• The Emerging Accounting Issues Working Group
(EAIWG) held a meeting to take action on certain
tentative positions and to address certain outstanding
issues (refer to page 10 for details). The comment
deadline for the issues newly exposed at the meeting is
August 7, 2009.
• The NAIC/AICPA Working Group updated the previously
provided results of a survey sent out to the states
regarding how the states plan on incorporating the
NAIC Model Audit Rule (MAR) in their state. Surveys are
being sent quarterly and the results of the May 2009
survey were as follows (includes District of Columbia in
the survey):
– Statute/Law – 13 states
– Regulation/Rule – 32 states
– Combination – 6 states
The survey also addresses when states plan to present the
MAR amendments to their legislature or when they plan to
change the related regulation. As of the May 2009 survey,
twenty-three (23) states have adopted changes to address
the MAR and the remaining twenty-eight (28) states
(includes District of Columbia in the survey) are expected to
present amendments or adopt changes to address the MAR
in 2009.
For those states that have presented the adopted changes
to the MAR to their respective legislature, none of the states
indicated any signicant problems with the proposed rule.
NAIC staff will continue to revise the implementation
guide and, specically, will address the questions related
to certain exposed wording which appeared to contradict
the disclaimer within Section 14 indicating that the section
shall not apply to SOX Compliant Entities or wholly owned
subsidiaries of SOX Compliant Entities. Regulators also
commented that it is their interpretation and expectation
that management’s report on internal control would
consider materiality at the regulated entity level and not on
a group basis.
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Statutory Accounting PrincipleWorking Group
Reference Title Sector Amendments
Exposed
FS
Impact
Disclosure Effective
Date
2009-02 SSAP No. 91R
Accounting or
Transers and Servicing
o Financial Assets and
Extinguishments o
Liabilities
P&CLifeHealth
Nonsubstantive Change – Adopted as nal changes toSSAP No. 91R adopting the guidance of FSP FAS 140-3,
Accounting or Transers o Financial Assets and Repurchase
Financing Transactions.
Y N Immediate
2009-01
2009-03
2009-04
2009-05
Various P&CLifeHealth
Nonsubstantive Change - Adopted as fnal changesto Issue Paper No. 99 rejecting the ollowing as not
applicable to statutory accounting:
FSP FAS 117-1,• Endowments o Not-For-Proft
Organizations: Net Asset Classifcation o Funds
Subject to an Enacted Version o the Uniorm Prudent
Management o Institutional Funds Act, and Enhanced
Disclosure or All Endowment Funds
FSP EITF 99-20-1,• Amendments to the Impairment
Guidance o EITF Issue No. 99-20-1
Statement of Position 07-2,• Attestation Engagements
That Address Specifed Compliance Control Objectives
and Related Controls at Entities That Provide Services
to Investment Companies, Investment Advisors, or
Other Service Providers
Statement of Position 07-1,• Clarifcation o the Scope
o the Audit and Accounting Guide or Investment
Companies and Accounting by Parent Companies and
Equity Method Investors or Investments in Investment
Companies and FASB Sta Position 07-1-1, Eective
Date o AICPA Statement o Position 07-1
N N Immediate
2003-12 IP No. 135
FASB Interpretation
45: Guarantor’s
Accounting
and Disclosure
Requirements or
Guarantees, Including
Indirect Guarantees
o Others, and
Interpretation o FASB
Statements No. 5, 57,
and 107 and Recession
o FASB Interpretation
No. 34 (FIN 45)
P&CLifeHealth
Exposed proposed Issue Paper No. 135 – The proposedissue paper requires reporting entities to recognize, atinception of a guarantee, a liability for the obligations ithas undertaken. Intercompany or related party guaranteewould be recognized unless such is considered an“unlimited” guarantee.
Y Y TBD
Current Developments: The SAPWG adopted the following amendments as nal:
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Reference Title Sector AmendmentsExposed
FSImpact
Disclosure EffectiveDate
2008-28 IP No. 137
Transer o Property and
Casualty Reinsurance
Agreements in Run-o
P&C Substantive Change - This issue paper proposes amendingSSAP No. 62, Property and Casualty Reinsurance, allowingrun-off reinsurance contracts, meeting specied criteria, toreceive prospective accounting treatment.
Y Y 2010
2007-24 IP No. 138
Fair Value
Measurements
P&CLifeHealth
Substantive Change – This issue paper proposes adoptingwith modication FASB Statement No. 157, Fair Value
Measurements, and FSP FAS 157-4, Determining Fair
Value When the Volume and Level o Activity or the Asset
or Liability Have Signifcantly Decreased and Identiying
Transactions That Are Not Orderly . The denition of fair
value and the three-level fair value hierarchy are acceptedfor statutory accounting. This issue paper rejects theconsideration of an entities own credit risk in determiningthe fair value of a liability.
Y Y TBD
2009-09 SAAP No. 60
Financial Guaranty
Insurance
P&CLife
Nonsubstantive Change – Exposed revisions proposingthe disclosures similar to the intent of disclosures requiredby FASB No. 163, Accounting or Financial Guarantee
Contracts, but modied to be applicable under currentstatutory accounting guidance for nancial guaranteeinsurance contracts. This change impacts disclosures only,with review of possible accounting changes occurring at alater date.
N Y 2009
2009-08 FSP SOP 94-3-1 andAAG HCO-1
Omnibus Changes
to Consolidation
and Equity Method
Guidance or Not-For-
Proft Organizations
P&CLifeHealth
Nonsubstantive Change - Exposed changes to IssuePaper No. 99 rejecting as not applicable to statutoryaccounting.
N N TBD
Current Developments: The SAPWG adopted the following amendments as nal:
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9
Reference Title Sector Amendment status update FSImpact
Disclosure EffectiveDate
2006-30 SSAP No. 92
Accounting or
Postretirement Benefts
Other Than Pensions,
A Replacement o SSAP
No. 14
SSAP No. 100
Accounting or
Pensions, A
Replacement o SSAP
No. 89
P&CLifeHealth
NAIC staff was directed to consider comments receivedfrom the exposures of these proposed SSAPs and modifyas considered appropriate for statutory accounting. SSAPNos. 92 and 100 are to be re-exposed at a future date.
Y Y 2011(tentative)
The SAPWG took the following other actions:
Other SAPWG Matters:
• The SAPWG, EAIWG and Valuation of Securities Task Force discussed re-REMIC transactions (re-securitization asset backed securities). Althoughregulators noted that facts and circumstances may vary, generally a transfer would fall under the guidance of SSAP No. 25 and not SSAP No. 91R; thusbe expected to occur at fair value under SSAP No. 25 and considered a non-economic transaction. States were encouraged to involve the NAIC staff ifthey were approached by a company contemplating such transactions. No further action is planned.
• The SAPWG agreed to defer the item on consideration of increasing the admission of deferred tax assets related to the Capital and Surplus ReliefWorking Group (Reference #2009-06).
• The SAPWG continues to work on the deferred premium asset and unearned premium reserve matter (Reference #2009-10) and is expecting to hold a joint call with the Life and Health Actuarial Task Force to further discuss the issues.
• A subgroup was formed to consider changes to the Accounting Practices and Procedures Manual to address changes necessitated by current projects
including the FASB Accounting Standards Codication and the Principles-Based Reserv ing project.
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Emerging Accounting IssuesWorking Group
The Emerging Accounting Issues Working Group
(EAIWG) continues to address the many questions thatare developing as new accounting pronouncements areissued.
The EAIWG adopted as nal the following tentativeconsensus positions:
• INT09-04:ApplicationoftheFairValueDenition.
The Working Group adopted this interpretationwhich claries the application of the NAICAccounting Practices and Procedures Manual glossarydenition of fair value in situations where the volumeand level or activity for the asset or liability havesignicantly decreased and transactions which areforced sales or liquidation sales.
• INT09-03:EITF08-7:AccountingforDefensive
Intangible Assets (EITF 08-7). The consensusadopts, with modication, EITF 08-7 and clariesthat defensive intangible assets are assets, butnonadmitted for statutory accounting and reportingpurposes.
The EAIWG exposed the following tentative consensus
positions:
• EITF08-3:AccountingbyLesseesforMaintenance
Deposits (EITF 08-3). The Working Group exposeda tentative consensus clarifying that refundablemaintenance deposits shall be accounted for asassets which are nonadmitted. Other costs that donot increase the value or the usefulness of the leasedassets shall be expensed when incurred.
• EITF08-8:AccountingforanInstrument(oran
embedded eature) with a Settlement Amount That
is Based on the Stock o an Entity’s Consolidated
Subsidiary (EITF 08-8). The Working Group exposeda tentative consensus rejecting EITF 08-8 as notapplicable to statutory accounting.
This summary was prepared by Matt Wangard and Carolyn Estrada.
For your comments and suggestions please contact the authors -
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Contributors
Eleanor Barrett
Senior ManagerDeloitte LLP
+1 (212) 436 2954
Carolyn Estrada
Senior ManagerDeloitte & Touche LLP
+1 (212) 436 2954
Matt Wangard
PartnerDeloitte & Touche LLP
+1 (312) 486 3224
For further information, visit our website at www.deloitte.com/us/insurance
ContactsFor more information, please contact:
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Vice Chairman
U.S. Insurance Leader
Deloitte LLP
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Steve Foster
Director
Deloitte & Touche LLP
+1 (804) 697 1811
Howard Mills
Director & Chief Advisor
Insurance Industry Group
Deloitte LLP
+1 (212) 436 6752
Naru Navele
Partner
Deloitte & Touche LLP
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Deloitte & Touche LLP+1 (212) 436 4761
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