Coronavirus Policy Comment Letters
Business Coalition Requests Extension of Modification Period under March 27, 2020 RBC Guidance
The Real Estate Roundtable along with nine industry organizations wrote to Commissioner White and Superintendent Cioppa of the National Association of Insurance Commissioners (NAIC) requesting the Financial Condition (E) Committee of the National Association of Insurance Commissioners (NAIC) extend the modification period under the risk-based capital guidance issued on March 27, 2020, to conform it to a related NAIC accounting interpretation issued April 15, 2020 and to section 4013 of the CARES Act.
To accommodate such a measured multi-step approach, we request that the Committee adopt the modification period specified in section 4013 of the CARES Act and adopted in INT 20-03: the modification period ending on the earlier of 60 days after the national declaration of emergency is terminated, or December 31, 2020, and that the Committee issue that extension as soon as possible. Alternatively, the Committee could extend the modification period under the RBC Guidance to September 30, 2020, with a decision on an extension beyond September 30, 2020.