VM-20_090612_004



Life Actuarial (A) Task Force/ Health Actuarial (B) Task Force

Amendment Proposal Form*

1. Identify yourself, your affiliation and a very brief description (title) of the issue.

Brian Bayerle, ACLI. Identifies in Section II – Reserve Requirements that for certain deposit-type contracts VM-22 is applicable for the maximum valuation interest rates.

2. Identify the document, including the date if the document is “released for comment,” and the location in the document where the amendment is proposed:

2019 Valuation Manual adopted September 10, 2018; Section II – Reserve Requirements for Deposit-Type Contracts.

3. Show what changes are needed by providing a red-line version of the original verbiage with deletions and identify the verbiage to be deleted, inserted or changed by providing a red-line (turn on “track changes” in Word®) version of the verbiage. (You may do this through an attachment.)

See attached.

4. State the reason for the proposed amendment? (You may do this through an attachment.)

Last year, updates to VM-22 included an expansion of products within scope. Some of these products fall under “Deposit-Type Contracts” rather than “Annuities”. In Section II – Reserve Requirements, the Annuities section makes clear that for certain products VM-22 is applicable for the maximum valuation interest rates. This APF would port this language to the Deposit-Type Contract section.

* This form is not intended for minor corrections, such as formatting, grammar, cross–references or spelling. Those types of changes do not require action by the entire group and may be submitted via letter or email to the NAIC staff support person for the NAIC group where the document originated.

NAIC Staff Comments:

|Dates: Received |Reviewed by Staff |Distributed |Considered |

|03/27/19 | | | |

|Notes: APF 2019-36 rev. 4/4/19 |

W:\National Meetings\2010\...\TF\LHA\

II. Reserve Requirements

Annuity Products

A. This subsection establishes reserve requirements for all contracts classified as annuity contracts as defined in SSAP No. 50 in the AP&P Manual.

B. Minimum reserve requirements for variable annuity contracts and similar business, specified in VM-21, Requirements for Principle-Based Reserves for Variable Annuities, shall be those provided by VM-21. The minimum reserve requirements of VM-21 are considered PBR requirements for purposes of the Valuation Manual.

C. Minimum reserve requirements for fixed annuity contracts are those requirements as found in VM-A and VM-C as applicable, with the exception of the minimum requirements for the valuation interest rate for single premium immediate annuity contracts, and other similar contracts, issued after Dec. 31, 2017, including those fixed payout annuities emanating from host contracts issued after Jan. 1, 2017, and on or before Dec. 31, 2017. The maximum valuation interest rate requirements for those contracts and fixed payout annuities are defined in VM-22, Maximum Valuation Interest Rates for Income Annuities.

Deposit-Type Contracts

A. This subsection establishes reserve requirements for all contracts classified as deposit-type contracts defined in SSAP No. 50 in the AP&P Manual.

B. Minimum reserve requirements for deposit-type contracts are those requirements as found in

VM-A and VM-C as applicable., with the exception of the minimum requirements for the valuation interest rate for deposit-type contracts, and other similar contracts, issued after Dec. 31, 2017, including those deposit-type contracts emanating from host contracts issued after Jan. 1, 2017, and on or before Dec. 31, 2017. The maximum valuation interest rate requirements for those contracts and fixed payout annuities are defined in VM-22, Maximum Valuation Interest Rates for Income Annuities.

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