Request for Clarifications and Modifications to Risk-Based Guidance
April 9, 2020
On April 10, The Roundtable along with ten other organizations wrote to the National Association of Insurance Commissioners requesting that the Financial Condition (E) Committee (E Committee) of the National Association of Insurance Commissioners (NAIC) expand the Guidance for Troubled Debt Restructurings for March 31-June 30 Statutory Financial Statements and Related Interim Risk-Based Capital Filings (where required) (RBC Guidance), issued March 27, 2020.
While we understand from NAIC staff that the RBC Guidance was intended only for companies at Authorized Control Level RBC (ACL RBC), we request that it be expanded to apply to all insurance companies on an optional basis. Although our comments discuss risk-based capital, we also believe the same approaches should apply to Asset Valuation Reserve (AVR) implications from insurers providing relief to borrowers.