NAIC Fall Meeting Update: Reinsurance (E) Task Force Discusses Implementation Of Actuarial Guideline LV For Testing Adequacy Of Reserves In Life Reinsurance

On December 9, 2025, the Reinsurance (E) Task Force, which reports to the Financial Condition (E) Committee, met to discuss, among other things, its ongoing projects at the NAIC that affect reinsurance. A key component of that discussion was the implementation of Actuarial Guideline LV (Application of the Valuation Manual for Testing the Adequacy of Reserves Related to Certain Life Reinsurance Treaties; "AG 55"; available here). AG 55 applies the NAIC Valuation Manual (VM-30) to future reinsurance transactions of domestic life insurers where (i) the insurance business substantially relies on asset returns, and (ii) the transaction materially lowers the amount of the domestic insurer's reserves. AG 55 was adopted by the NAIC's Life Insurance and Annuities (A) Committee on July 14, 2025, and the Life Actuarial (A) Task Force on June 5, 2025. Asset adequacy in reinsurance transactions will now be subject to required testing by the insurer's domestic regulator using Gross Premium Valuation (GPV) methodology. As reflected in the Task Force's August 11, 2025, Meeting Minutes, "several state insurance regulators proposed this project and recommends changes to the asset adequacy testing (AAT) methodology for the assets that support reinsurance transactions," and "one of the key aspects of AG 55 is an emphasis on disclosure rather than mandating additional reserves . . . companies may choose to bolster reserves based on their own evaluation, and that regulators retain the right to request further analysis . . . the guideline aims for greater transparency and consistency nationwide" (see those prior meeting minutes available here).

Benjamin Slutsker, Director of Life Actuarial Valuation at the Minnesota Department, noted that template reporting forms are being developed, including forms to list assets and assumptions made thereon, and current draft templates are available on the NAIC's Life Actuarial Task Force webpage. The first reports subject to AG 55 will be due in April 2026. Each report will automatically be sent to the insurer's domestic regulator by the Minnesota Department on behalf of the Working Group. AG 53 and 55 filing instructions will be distributed by Mr. Slutsker in the future, who is maintaining an email mailing list for this purpose. However, Missouri will receive reports directly, regardless of whether the insurer is domestic to Missouri. The Working Group plans to review filings as soon as they come in and will provide general findings starting at the Summer 2026 National Meeting.

As a minor note, the Task Force also noted that the NAIC plans to co-host Property & Casualty reinsurance education discussions with the California Department, which will include tours of the wildfire damage in California and discussions of the unique issues presented in the current context. The discussions are intended to include investigating public-private partnerships and working with industry to address the needs of insurers, regulators, and policyholders. Relatedly, the NAIC and the Reinsurance Association of America have arranged a two-day training for key regulators in Kansas City for training on the mechanics of reinsurance agreements, including the basics of reinsurance transactions, contracting, and management of catastrophe risk.