Regulatory and Actuarial References#

Status: Draft, 2026-08-03; extended to cover individual annuities 2026-08-04; extended with the AP&P Manual’s formulaic appendices and actuarial guidelines 2026-08-06.

Curated reference library for the U.S. section of the reference-product library. It covers the regulatory, tax, experience-study, practice-note, standards, and accounting sources that the reference cash-flow-model implementations rely on, in three parts:

  • the six individual life products (term / whole life / UL / IUL / VUL / ULSG) at entries R1–R34;

  • the six individual annuity products (fixed deferred / fixed indexed / variable / registered index-linked / immediate / deferred income) at entries R35–R72;

  • the AP&P Manual texts behind the formulaic index — the appendices and actuarial guidelines that VM-A (R110) and VM-C (R41) incorporate by reference but do not print: AG 33, AG 35, A-820 (with A-821 and A-822), A-830, A-585, A-250 and A-255 — at entries R151–R157, carried in a subsection at the end of section 16.

Several R1–R34 entries also bind annuity models; they are not restated, and the annuity product-relevance matrix below therefore covers both halves of the numbering. Sections 1–6 carry the life entries, sections 7–13 the annuity entries, and section 14 records the annuity half’s gaps, fetch failures, and unverified points. Section 15 carries the ten entries retained from the retired statutory accounting and capital block, and section 16 the 2026-08-06 additions — R150 and, in its closing subsection, R151–R157.

Product folders cite entries on this page as [REG-R#] (e.g., [REG-R16]); the R1–R157 numbering below is frozen — do not renumber or reuse numbers, as product documentation already cites against it. Within this page, plain [R#] refers to the same entries. Facts drawn from a document that was actually retrieved carry its number; claims from general knowledge or secondary sources are tagged unverified; failed or unfetched links are disclosed per entry — no URL on this page is fabricated. R1–R34 were accessed 2026-08-03; R35–R72 were accessed 2026-08-04; the retained R73–R110 entries were accessed 2026-08-04; R150–R157 were accessed 2026-08-06, unless an entry notes otherwise.

Numbering gaps: most of R73–R149 is unused, not missing. R73–R142 carried the statutory accounting and capital research stream that has since been retired from the library; ten of its entries (R73, R78, R79, R81, R83, R92, R100–R102, R110) are retained in section 15 because the AP&P Manual extractions cite them, and the rest were removed with that framework. R114–R124 and R143–R149 were never assigned at all — blocks of numbers were allocated up front to parallel research streams that did not fill them. Unused is not the same as missing: the invariant is that a number, once allocated, is never reused for a different document and never renumbered, so these gaps stay permanently empty; new entries continue above the highest number in use — R150 when the PBR topic page was added, then R151–R157 in the 2026-08-06 AP&P Manual pass.

Retrieval note for R35–R72: many primary PDFs (NAIC model laws, the Valuation Manual, Academy papers) return raw compressed streams to the fetch tool. Where that happened the PDF was downloaded and its text extracted locally before reading; those entries are marked fetched: yes (local text extraction) and their annotations are first-hand. Domain blocks encountered on 2026-08-04: sec.gov returned HTTP 403 to automated clients; federalregister.gov and ecfr.gov redirect to a bot-block page; irs.gov returned 404 on the LB&I directive URLs surfaced by search. Where a working alternative existed (govinfo.gov, law.cornell.edu, gao.gov) it was used and is cited instead.

Product-relevance matrices#

x = directly relevant per the source annotation; (x) = qualified or peripheral relevance (e.g., “background”, “by analogy”, “to a lesser degree”) per the source annotation; blank = not indicated by the source.

Matrix A — individual life products (entries R1–R34)#

R#

Reference (short name)

term

whole-life

universal-life

indexed-ul

variable-ul

guaranteed-ul

R1

Standard Valuation Law (Model #820)

x

x

x

x

x

x

R2

Standard Nonforfeiture Law (Model #808)

x

x

R3

Valuation Manual, 2026 edition

x

x

x

x

x

x

R4

Illustrations Model Reg (Model #582)

x

x

x

x

R5

UL Model Regulation (Model #585)

x

x

(x)

x

R6

Model #830 (“Regulation XXX”)

x

x

R7

AG 38

x

x

x

R8

AG 49 (original)

x

R9

SOA AG 49 history article

x

R10

AG 49-A as revised 2023 (“AG 49-B”)

x

R11

AG 48

x

x

R12

Reserve Financing Model Reg (Model #787)

x

x

R13

IRC § 7702

(x)

x

x

x

x

x

R14

IRC § 7702A (MEC)

x

x

x

x

R15

IRC § 817 (variable contracts)

x

R16

IRC § 807 (tax reserves)

x

x

x

x

x

x

R17

2017 CSO Tables

x

x

x

x

x

x

R18

2015 VBT

x

x

x

x

x

x

R19

ILEC 2012–2019 mortality report

x

x

x

x

x

x

R20

2009–13 persistency study

x

x

x

x

x

R21

2015–21 UL persistency/lapse study

x

x

(x)

x

R22

Post-level term study (2021)

x

R23

AAA VM-20 practice note

x

x

x

x

x

x

R24

AAA illustrations practice note

x

x

x

x

R25

AAA PBR assumptions resource manual

x

x

x

x

x

x

R26

ASOP 2 (nonguaranteed elements)

x

x

x

x

x

R27

ASOP 7 (cash flow analysis)

x

x

x

x

x

x

R28

ASOP 15 (dividends)

x

R29

ASOP 22 (asset adequacy opinions)

x

x

x

x

x

x

R30

ASOP 24 (illustrations)

x

x

x

x

R31

ASOP 52 (PBR)

x

x

x

x

x

x

R32

ASOP 56 (modeling)

x

x

x

x

x

x

R33

NAIC AP&P Manual

x

x

x

x

x

x

R34

FASB ASU 2018-12 (LDTI)

x

x

x

x

x

x

Matrix B — individual annuity products (entries R1–R72)#

Covers both halves of the numbering: the R1–R34 entries insofar as they bind — or are expressly excluded from — annuity models, and the new R35–R72 entries. One extra marker is used in this matrix only: n/a = the source states the entry does not apply to annuities, listed so that a life-only rule is not mis-applied (blank still means “not indicated by the source”). Row-level qualifications are keyed by R# in the notes beneath.

R#

Reference (short name)

fixed-deferred-annuity

fixed-indexed-annuity

variable-annuity

registered-index-linked-annuity

immediate-annuity

deferred-income-annuity

R1

Standard Valuation Law (Model #820)

x

x

x

x

x

x

R2

Standard Nonforfeiture Law (Model #808)

n/a

n/a

n/a

n/a

n/a

n/a

R3

Valuation Manual, 2026 edition

x

x

x

x

x

x

R4

Illustrations Model Reg (Model #582)

n/a

n/a

n/a

n/a

n/a

n/a

R5

UL Model Regulation (Model #585)

(x)

R6

Model #830 (“Regulation XXX”)

n/a

n/a

n/a

n/a

n/a

n/a

R7

AG 38

n/a

n/a

n/a

n/a

n/a

n/a

R8–R10

AG 49 / AG 49-A family

n/a

n/a

n/a

n/a

n/a

n/a

R11–R12

AG 48 / Model #787

n/a

n/a

n/a

n/a

n/a

n/a

R13–R14

IRC § 7702 / § 7702A

n/a

n/a

n/a

n/a

n/a

n/a

R15

IRC § 817 (variable contracts)

x

x

R16

IRC § 807 (tax reserves)

x

x

x

x

x

x

R17–R19

2017 CSO / 2015 VBT / ILEC

n/a

n/a

n/a

n/a

n/a

n/a

R20–R22

Life persistency / post-level term

n/a

n/a

n/a

n/a

n/a

n/a

R23

AAA VM-20 practice note

n/a

n/a

n/a

n/a

n/a

n/a

R24

AAA illustrations practice note

n/a

n/a

n/a

n/a

n/a

n/a

R25

AAA PBR assumptions resource manual

(x)

(x)

(x)

(x)

(x)

(x)

R26

ASOP 2 (nonguaranteed elements)

x

x

x

x

R27

ASOP 7 (cash flow analysis)

x

x

x

x

x

x

R28

ASOP 15 (dividends)

(x)

(x)

(x)

(x)

(x)

(x)

R29

ASOP 22 (asset adequacy opinions)

x

x

x

x

x

x

R30

ASOP 24 (illustrations)

n/a

n/a

n/a

n/a

n/a

n/a

R31

ASOP 52 (PBR — life products only)

n/a

n/a

n/a

n/a

n/a

n/a

R32

ASOP 56 (modeling)

x

x

x

x

x

x

R33

NAIC AP&P Manual

x

x

x

x

x

x

R34

FASB ASU 2018-12 (LDTI)

x

x

x

x

x

x

R35

VM-21 (variable annuity PBR)

(x)

(x)

x

x

R36

VM-22 (non-variable annuity PBR)

x

x

(x)

x

x

R37

VM-V § 1 (income annuity valuation rates)

x

x

x

R38

AG 43 (CARVM for variable annuities)

x

x

R39

AG 33 (CARVM, elective benefits)

x

x

R40

AG 35 (CARVM, equity indexed)

(x)

x

R41

VM-C actuarial guideline index

x

x

x

x

R42

Model #805 (deferred annuity nonforfeiture)

x

x

n/a

(x)

n/a

n/a

R43

Model #250 (Variable Annuity Model Reg)

x

x

n/a

R44

AG 54 (ILVA nonforfeiture)

(x)

x

R45

Model #245 (annuity disclosure / illustrations)

x

x

(x)

(x)

(x)

(x)

R46

Model #275 (suitability / best interest)

x

x

x

x

x

x

R47

C-3 Phase II RBC instructions

x

x

R48

Oliver Wyman QIS II (VA reform)

x

x

R49

SEC RILA / Form N-4 final rule (2024)

(x)

x

x

R50

SEC Rule 498A adopting release (2020)

x

(x)

R51

17 C.F.R. § 230.498A

x

x

R52

SEC Form N-4

x

x

R53

CRS R40656 (Rule 151A / § 989J)

x

(x)

R54

FINRA Rule 2330

x

(x)

R55

IRC § 72

x

x

x

x

x

x

R56

IRC § 1035

x

x

x

x

(x)

(x)

R57

Treas. Reg. § 1.401(a)(9)-6 (QLAC)

(x)

(x)

x

x

R58

T.D. 10001 (RMD final regs, 2024)

(x)

(x)

(x)

x

x

R59

Model #821 + VM-M annuity mortality

(x)

(x)

x

x

x

R60

2012 IAR development report

(x)

(x)

(x)

x

x

R61

2020–24 payout annuity mortality study

(x)

(x)

(x)

x

x

R62

FIA policyholder behavior studies

(x)

x

R63

Fixed rate deferred surrender studies

x

R64

VA behavior / GLB utilization studies

(x)

x

x

R65

SOA annuity experience studies index

x

x

x

x

x

x

R66

AAA VM-21 practice note supplement

x

x

R67

AAA GLB utilization resource guide

(x)

(x)

x

x

R68

AAA FIA product mechanics paper

(x)

x

(x)

R69

AAA ILVA / RILA policy paper

(x)

x

R70

ASOP 54 (pricing)

x

x

x

x

x

x

R71

ASOP 10 (U.S. GAAP long-duration)

x

x

x

x

x

x

R72

IRS LB&I § 807 directive unverified

x

Notes on Matrix B

  • Life-only rows (n/a throughout) are listed to prevent mis-application, not as filler. In particular: annuity nonforfeiture runs through Model #805 (R42) and, for variable and index-linked contracts, Model #250 § 7 (R43) and AG 54 (R44) — never Model #808 (R2); annuity illustrations run through Model #245 (R45), so do not reuse AG 49 / AG 49-A logic (R8–R10) for FIA illustrations; annuitant longevity uses R59–R61, never the CSO/VBT/ILEC life tables (R17–R19); annuity surrender behavior uses R62–R64, not the life persistency and post-level-term studies (R20–R22); and ASOP 52 (R31) is scoped to VM-20 life products — there is no annuity-PBR ASOP covering VM-21 or VM-22.

  • R5: not applicable to annuities; the interest-indexed-UL provisions are the structural analogue of FIA crediting mechanics and are useful for a shared crediting-engine design [unverified as to any direct annuity effect].

  • R25: an assumption-governance framework written for life PBR but directly transferable to VM-21/VM-22 assumption setting and documentation [unverified as to explicit annuity scope].

  • R28: titled to include annuities, but relevant only to participating annuity forms — rare in the individual market [unverified as to current market relevance].

  • R29: binding in part because AG 35 expressly requires equity-indexed annuity reserves to be asset-adequacy tested R40, and because SPIA/MYGA/FIA blocks are the classic cash-flow-testing exposures.

  • R35: the deferred-annuity marks are qualified because VM-21’s scope includes a catch-all for any contract carrying GMDB/VAGLB-like guarantees that has no other explicit reserve requirement R35.

  • R36: excludes variable annuities (VM-21 governs), but the fixed account of a VA and the fixed payout stream after a VA’s funds are exhausted fall into VM-22 Reserving Categories R36.

  • R42: does not apply to a RILA if and only if AG 54 (R44) is satisfied; a non-compliant ILVA is not a variable annuity and falls back under Model #805 R44.

  • R43: § 7.A expressly excludes immediate annuities and deferred annuities already in payout R43.

  • R59 / R60 / R61: the deferred-annuity and variable-annuity marks are for the annuitization and GLWB payout phases; VM-21 prescribes percentages of the 2012 IAM Basic Table with Scale G2 for prudent-estimate mortality on contracts with VAGLBs and roll-up GMDBs R35.

1. NAIC statutory framework — valuation, nonforfeiture, illustrations, actuarial guidelines#

R1. Standard Valuation Law (Model #820)#

  • Publisher: National Association of Insurance Commissioners (NAIC)

  • URL: https://content.naic.org/sites/default/files/model-law-820.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (27-page PDF retrieved and read)

  • Annotation: The enabling statute for statutory reserve valuation: minimum standards by calendar year of issue, the Commissioners Reserve Valuation Method (CRVM), and deficiency-reserve treatment when the valuation net premium exceeds the gross premium, plus — via the 2009 amendments — the sections creating principle-based reserving (Sections 11–14: Valuation Manual applicability, requirements of a principle-based valuation, experience reporting, confidentiality) R1. It is the legal root of every statutory reserve a projection model must reproduce, for all six products. The Valuation Manual operative date was January 1, 2017 [unverified — widely documented but not stated in this print].

R2. Standard Nonforfeiture Law for Life Insurance (Model #808)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/model-law-808.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (13-page PDF retrieved and read)

  • Annotation: Sets minimum cash surrender values and paid-up nonforfeiture benefits: the 60-day default/election mechanics, the adjusted-premium method (ordinary/industrial variants and the nonforfeiture net level premium method), treatment of indeterminate premium plans, and the required smooth progression of cash values by duration R2. An implementer needs this for whole life’s guaranteed CSV scale and for why long-duration guaranteed-premium term may generate nonforfeiture values; UL/IUL/VUL nonforfeiture is instead governed via Model #585’s UL-specific adaptation (R5). This 2014 print ties its definitions to the Valuation Manual operative date R2; minimum nonforfeiture mortality/interest for new issues now comes through VM-02 (R3).

R3. Valuation Manual, Jan. 1, 2026 Edition (VM-01, VM-02, VM-20, VM-31, VM-M, VM-G, VM-C, VM-V, …)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (457-page PDF retrieved; cover, adoption history, and full table of contents read; “NAIC Adoptions through August 13, 2025”)

  • Annotation: The operative rulebook for statutory valuation of new business. For a cash-flow-model implementer the load-bearing sections are VM-20 (life PBR — the net premium reserve floor plus deterministic and stochastic reserves, with exclusion/exemption tests), VM-31 (the PBR Actuarial Report the model output must feed), VM-02 (minimum nonforfeiture mortality and interest), and appendices VM-M (mortality tables), VM-V (statutory maximum valuation interest rates for formulaic reserves), and VM-C (actuarial guidelines incorporated as an appendix) R3. Caution: this edition’s table of contents contains no VM-05 section — a full-text search of the PDF finds no “VM-05” at all R3; earlier editions (e.g., 2016) did reproduce the SVL as VM-05 unverified — use Model #820 (R1) directly for the statute.

R4. Life Insurance Illustrations Model Regulation (Model #582)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/model-law-582.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (14-page PDF retrieved and read)

  • Annotation: Governs sales illustrations for group and individual life policies except variable life, annuities, credit life, and policies with illustrated death benefits of $10,000 or less R4. The modeling-relevant machinery is the disciplined current scale and the self-support and lapse-support tests certified annually by an illustration actuary (the tests are defined in the regulation’s standards and in ASOP 24, R30) R4 [unverified as to section numbering detail]. IUL-specific rate limits are layered on top by the AG 49 family (R8–R10).

R5. Universal Life Insurance Model Regulation (Model #585)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/model-law-585.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (14-page PDF retrieved and read)

  • Annotation: Adapts the life-insurance regulatory framework to flexible-premium designs: definitions (flexible vs. fixed premium UL, interest-indexed UL), valuation (Section 5), nonforfeiture (Section 6), mandatory policy provisions, the periodic (annual) statement to policyowners, and extra requirements for interest-indexed UL R5. This is where the UL-pattern mechanics a model must honor — account value roll-forward disclosure, maturity/nonforfeiture treatment — get their regulatory definition. Drafting notes state it applies to individual UL except variable UL R5 per NAIC search summary; scope section read; VUL is carved out into variable-products rules and federal securities law.

R6. Valuation of Life Insurance Policies Model Regulation (Model #830, “Regulation XXX”)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/model-law-830.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (35-page PDF retrieved and read; print: October 2009; regulation adopted March 1999 R7)

  • Annotation: The pre-PBR reserve regime for term and secondary-guarantee UL, still operative for in-force blocks issued before PBR: tables of select mortality factors and rules for their use, Section 6 minimum standards for plans with guaranteed nonlevel gross premiums or nonlevel benefits (level-term segmentation — the “XXX” term reserves), and Section 7 minimum standards for UL with secondary guarantees (“AXXX” reserves) R6. Basic reserves under this regulation constitute CRVM for the policies in scope R6. Its conservatism drove captive reserve financing — hence AG 48 (R11) and Model #787 (R12).

R7. Actuarial Guideline XXXVIII — The Application of the Valuation of Life Insurance Policies Model Regulation (AG 38)#

  • Publisher: NAIC (PDF circulated with the NAIC CIPR newsletter, December 2012)

  • URL: https://content.naic.org/sites/default/files/inline-files/cipr_ag38_121212.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (13-page PDF retrieved and read; confirmed it contains the 2012 revision Sections 8D/8E and the pre-July-2005 / pre-2013 / post-2013 issue-date splits)

  • Annotation: Interprets Model #830 for products designed around it — above all ULSG with shadow accounts — on the principle that reserves must be established for the guarantees a policy actually provides, enumerating product designs and the reserving approach for each; the 2012 revisions (8D/8E) set separate standards for pre-2013 in-force ULSG versus post-2013 issues R7. Original guideline created 2003, revised 2005 and 2012 [unverified — consistent with the 2012 text but history stated from secondary sources]. The official current text lives in the NAIC AP&P Manual Appendix C / VM-C R3 [unverified as to AP&P pagination]. Fetch note: the NAIC CIPR topic page for AG 38 returned HTTP 403 to automated fetch.

R8. Actuarial Guideline XLIX (AG 49, original 2015; amended 2016)#

  • Publisher: NAIC

  • URL: none verified — no official standalone copy of the original AG 49 text was located on content.naic.org (only a 2019 exposure redline: https://content.naic.org/sites/default/files/inline-files/AG%2049%20-%202019%20edits%20-%201st%20exposure.pdf, not fetched); official text is in the AP&P Manual Appendix C / VM-C

  • Accessed: 2026-08-03 (search date; document not fetched)

  • Fetched: no (link failure disclosed; see R9/R10 for fetched successors and history)

  • Annotation: First uniform limits on illustrated IUL crediting rates under Model #582: a Benchmark Index Account (BIA) whose lookback average caps the illustrated scale, plus limits on illustrated policy-loan leverage and disciplined-current-scale earned-rate limits R9 R10. Adopted 2015, applying to policies sold on/after Sept. 1, 2015 R9 per SOA article; date detail unverified; superseded for new sales by AG 49-A for policies sold on/after Dec. 14, 2020 (R10). Still needed for in-force illustrations of pre-2021 IUL sales.

R9. “Actuarial Guideline XLIX (AG49): Past, Present and Future” (SOA Product Matters!, June 2023)#

  • Publisher: Society of Actuaries, Product Development Section newsletter

  • URL: https://www.soa.org/sections/product-dev/product-dev-newsletter/2023/june/pm-2023-06-hoffer/

  • Accessed: 2026-08-03

  • Fetched: yes

  • Annotation: Practitioner article (secondary source) tracing the three rounds of IUL illustration guidance: AG 49 (2015) capping illustrated index credits via the benchmark account; AG 49-A (2020) eliminating illustrated leverage from multipliers and fixed bonuses (charges funding enhancements must offset illustrated benefit equally); and the 2023 “quick fix” (industry shorthand “AG 49-B”) stopping volatility-controlled-index hedge-cost savings from funding bonuses that out-illustrate the benchmark R9. Explains why an IUL illustrated-scale module must be version-dependent by sale date.

R10. Actuarial Guideline XLIX-A — The Application of the Life Illustrations Model Regulation to Policies with Index-Based Interest Sold On or After December 14, 2020 (as revised; the “AG 49-B” changes)#

  • Publisher: NAIC (adopted by LATF 12/11/2022; adopted by Life Insurance and Annuities (A) Committee 2/24/2023)

  • URL: https://content.naic.org/sites/default/files/committees-pending-action-actuarial-guideline-xlix-a-230224.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (6-page PDF retrieved and read)

  • Annotation: The operative IUL illustration guideline: caps the illustrated annual rate of index credits by reference to the Benchmark Index Account, limits illustrated policy-loan leverage, and requires a side-by-side alternate-scale illustration plus added disclosures R10. This print embeds the 2023 revisions — tighter limits for non-BIA index accounts for policies sold on/after May 1, 2023 (the change the industry calls “AG 49-B”) R10. The NAIC formally adopted these as revisions to AG 49-A rather than a separately numbered guideline; treat “AG 49-B” as a colloquial label R9 R10.

R11. Actuarial Guideline XLVIII — Actuarial Opinion and Memorandum Requirements for the Reinsurance of Policies Required to be Valued under Sections 6 and 7 of the NAIC Valuation of Life Insurance Policies Model Regulation (AG 48)#

  • Publisher: NAIC (LATF adoption 12/1/2016 revision print)

  • URL: https://content.naic.org/sites/default/files/inline-files/committees_ex_pbr_implementation_tf_related_actuarial_guideline_ag48.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (12-page PDF retrieved and read)

  • Annotation: Response to XXX/AXXX captive reserve financing: the appointed actuary must issue a qualified opinion if the ceding insurer (or its holding-company system) has a XXX/AXXX reserve-financing arrangement that does not hold the Required Level of Primary Security, computed by the prescribed Actuarial Method, in qualifying Primary Security assets R11. Original AG 48 effective Jan. 1, 2015 R11; sunsets operationally into Model #787 (R12) as states adopt it unverified. Relevant to a model’s reinsurance/collateral module for reserve-financed term and ULSG blocks, not to base cash flows.

R12. Term and Universal Life Insurance Reserve Financing Model Regulation (Model #787)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/model-law-787.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (10-page PDF retrieved and read; print: Model Regulation Service, 1st Quarter 2017)

  • Annotation: Codifies the AG 48 framework as a regulation under the Credit for Reinsurance Model Law: uniform national standards for reserve-financing reinsurance of policies with guaranteed nonlevel gross premiums/benefits (XXX term) and ULSG (AXXX), requiring Primary Security and Other Security in prescribed forms and amounts, with an Actuarial Method for the required level, remediation mechanics, and an anti-avoidance prohibition R12. Reinsurance/reserve-financing side only.

2. Federal tax — product qualification and insurer tax#

Historical note [unverified, brief]: the definitional regime arrived in stages — TEFRA (1982) first imposed temporary corridor/guideline rules for flexible-premium contracts (former IRC 101(f)); DEFRA (1984) enacted IRC 7702 for all life contracts; TAMRA (1988) added IRC 7702A’s MEC/7-pay regime to curb single-premium tax shelters. The 2021 Consolidated Appropriations Act change is verified at R13.

R13. 26 U.S.C. § 7702 — Life insurance contract defined#

  • Publisher: Legal Information Institute, Cornell Law School (U.S. Code)

  • URL: https://www.law.cornell.edu/uscode/text/26/7702

  • Accessed: 2026-08-03

  • Fetched: yes

  • Annotation: The federal definition of life insurance: a contract must pass either the cash value accumulation test (CVAT — CSV may not exceed the net single premium for future benefits) or the guideline premium test plus cash value corridor (GPT/CVC) R13. Subsection (f)(11), added by the Consolidated Appropriations Act, 2021, replaces the fixed 4%/6% assumptions with the “insurance interest rate” — the lesser of the § 7702 valuation interest rate and the § 7702 applicable federal interest rate, with a 2% transition rate for 2021 issues R13. A product model needs CVAT/GPT logic to police premium limits, corridor death benefits, and funding patterns; for term, definitional compliance is trivial without cash value unverified.

R14. 26 U.S.C. § 7702A — Modified endowment contract defined#

  • Publisher: Legal Information Institute, Cornell Law School

  • URL: https://www.law.cornell.edu/uscode/text/26/7702A

  • Accessed: 2026-08-03

  • Fetched: yes

  • Annotation: A contract entered into after June 20, 1988 is a MEC if cumulative premiums in the first seven contract years exceed the 7-pay net level premiums, or if received in exchange for a MEC R14. Material changes restart the 7-pay test (with a cash-value adjustment); benefit reductions within the first seven years apply retroactively; exclusions exist (e.g., death benefit increases funded by the lowest-level death benefit premiums, reinstatement within 90 days) R14. MEC status changes distribution taxation (LIFO + penalty) unverified, so illustration and in-force systems must test it continuously against funding patterns (WL paid-up additions riders; UL/IUL/VUL premium flexibility).

R15. 26 U.S.C. § 817 — Treatment of variable contracts (esp. § 817(h) diversification)#

  • Publisher: Legal Information Institute, Cornell Law School

  • URL: https://www.law.cornell.edu/uscode/text/26/817

  • Accessed: 2026-08-03

  • Fetched: yes

  • Annotation: § 817(h): a variable contract based on a segregated asset account is not treated as life insurance/annuity unless the account is “adequately diversified” per Treasury regulations; safe harbor if it satisfies § 851(b)(3) with no more than 55% in one issuer or group of related issuers, with look-through rules for insurance-dedicated funds and a Treasury-securities special rule R15. For a VUL model this is background (fund eligibility), not cash-flow mechanics.

R16. 26 U.S.C. § 807 — Rules for certain reserves (tax reserves)#

  • Publisher: Legal Information Institute, Cornell Law School

  • URL: https://www.law.cornell.edu/uscode/text/26/807

  • Accessed: 2026-08-03

  • Fetched: yes

  • Annotation: Post-TCJA (tax years beginning after Dec. 31, 2017), the life insurance tax reserve is the greater of the contract’s net surrender value and 92.81% of the reserve computed under the NAIC-prescribed method (CRVM for life, CARVM for annuities), capped at the statutory reserve R16. Discounting uses the highest rates permitted by the NAIC as of the determination date, and § 807(e)(6) requires reserve reporting R16. This is why a statutory VM-20/CRVM engine is also the natural source for a model’s tax-reserve output (see group 6).

3. Mortality tables and experience studies#

R17. 2017 Commissioners Standard Ordinary (CSO) Tables#

  • Publisher: Society of Actuaries (developed jointly with the American Academy of Actuaries for NAIC adoption unverified)

  • URL: https://www.soa.org/resources/experience-studies/2015/2017-cso-tables/

  • Accessed: 2026-08-03

  • Fetched: yes (landing page; the linked development-report PDF at https://www.soa.org/globalassets/assets/files/research/exp-study/research-2017-cso-report.pdf was not separately fetched)

  • Annotation: The statutory valuation/nonforfeiture mortality basis for new issues: loaded and unloaded composite, smoker-distinct, and preferred-structure tables, plus gender-blended and ultimate variants, each in ANB/ALB forms R17. Prescribed via VM-20/VM-M for the net premium reserve and used in nonforfeiture calculations for post-2017 issues R3 [unverified as to exact VM-M table numbers]. Developed from ILEC experience showing significant mortality improvement over the 2001 CSO basis and adding a preferred structure [search summary; development detail in the linked report].

R18. 2015 Valuation Basic Table (VBT) — Report and Tables#

  • Publisher: Society of Actuaries

  • URL: https://www.soa.org/resources/experience-studies/2015/2015-valuation-basic-tables/

  • Accessed: 2026-08-03

  • Fetched: yes (landing page; the linked report PDF at https://www.soa.org/globalassets/assets/Files/resources/experience-studies/2018/2015-vbt-report.pdf — report updated Sept. 2018 — was not separately fetched)

  • Annotation: The industry experience (unloaded) basis underlying the 2017 CSO: primary tables (male/female, smoker/nonsmoker, composite; ANB/ALB) plus 10 nonsmoker and 4 smoker Relative Risk (RR) tables for preferred-class fit, with preferred wear-off and mortality-improvement factors in appendices, built on 2009–2013 ILEC individual life experience R18. In VM-20, company prudent-estimate mortality is credibility-blended toward industry tables of this family R3 [unverified as to current VM-prescribed VBT vintage]. The anchor for best-estimate/prudent-estimate mortality in PBR and pricing models.

R19. 2019 Individual Life Insurance Mortality Experience Report (ILEC, observation years 2012–2019)#

  • Publisher: Society of Actuaries Research Institute — Individual Life Experience Committee (ILEC)

  • URL: https://www.soa.org/resources/research-reports/2024/ilec-mort-2012-19

  • Accessed: 2026-08-03

  • Fetched: yes (landing page; published Oct. 2024; the main report PDF at https://www.soa.org/globalassets/assets/files/resources/research-report/2024/ilec-mort-main.pdf was not separately fetched)

  • Annotation: The latest full ILEC mortality study: actual-to-expected experience for 2012–2019 against standard industry tables, with trends by key policy characteristics, plus underlying data as pivot tables, text files, and Tableau dashboards R19. Data collection shifted from MIB (2012–17) to the NAIC as statistical agent (2018 on) R19. The A/E expected basis includes the 2015 VBT [search summary; stated expected basis 2015 VBT RR100 — noted on the report itself, not the landing page]. The source for mortality assumption setting and VM-20 experience justification.

R20. U.S. Individual Life Insurance Persistency Update (LIMRA/SOA, observation years 2009–2013)#

  • Publisher: LIMRA and Society of Actuaries (joint study)

  • URL: https://www.soa.org/resources/research-reports/2019/2009-13-us-ind-life-persistency-update/

  • Accessed: 2026-08-03

  • Fetched: yes (landing page)

  • Annotation: Lapse experience for whole life, term, UL, and VUL plans issued 1918–2012, from 16 companies, with analysis by major policy/product factors, joint-life plans, and a detailed look at UL with secondary guarantees R20. The standard public source for base lapse assumptions by product, duration, premium mode, and size band R20 [unverified as to full factor list]. The successor UL-focused study is R21; older editions (2003–04 through 2007–09) remain on soa.org.

R21. 2015–2021 Universal Life Premium Persistency and Lapse/Surrender Experience Study#

  • Publisher: LIMRA and SOA Research Institute (joint)

  • URL: https://www.soa.org/resources/experience-studies/2024/15-21-ulpp-ulls/

  • Accessed: 2026-08-03

  • Fetched: yes (landing page)

  • Annotation: Two-part flexible-premium UL study for calendar years 2015–2021: premium persistency (14 companies, ~50% of flexible-premium UL new-sales share, 11.9M policy-years, ~$4.0T face exposure) and lapse/surrender (24 companies, ~80% of market, ~33.5M policy-years, 1.3M lapse terminations) R21. Directly relevant to modeling flexible-premium payment behavior — the assumption unique to UL-type products — and modern surrender bases; VUL by analogy. The landing page does not break out IUL/VUL separately R21.

R22. U.S. Post-Level Term Lapse and Mortality Experience Report (2021)#

  • Publisher: Society of Actuaries (research by SCOR: Bradfield, Covington, Reppert, Tomas)

  • URL: https://www.soa.org/resources/experience-studies/2021/us-post-level-term-lapse-mortality/

  • Accessed: 2026-08-03

  • Fetched: yes (landing page)

  • Annotation: The current study of shock lapse at the end of the level premium period, post-level-term (PLT) lapse, and PLT mortality deterioration — the anti-selection that dominates late-duration term cash flows R22. Updates the 2010 and 2014 PLT studies; a predictive-modeling companion report exists, and an ILEC/LIMRA update covering 2009–2024 experience is in progress (data request issued 2025) R22 [search summaries]. Essential for term models with post-level premium structures (jump-to-ART, graded).

4. American Academy of Actuaries — practice notes#

R23. Life Principle-Based Reserves (PBR) Under VM-20 — Practice Note (April 2020)#

  • Publisher: American Academy of Actuaries, Life Principle-Based Approach Practice Note Work Group (Life Valuation Committee)

  • URL: https://www.actuary.org/sites/default/files/2020-04/VM-20_PN_2020_Version_0.pdf (301-redirects to http://actuary.org/…; same path)

  • Accessed: 2026-08-03

  • Fetched: yes (115-page PDF retrieved and read; title page and front matter verified)

  • Annotation: Q&A-format guidance on implementing VM-20: scope/exemptions, the net premium reserve, deterministic and stochastic reserves, prudent-estimate assumption setting (mortality credibility, lapse, premium persistency), asset modeling and reinvestment, exclusion tests, and the reporting interplay with VM-31 [R23 front matter; topic list partly unverified — not every chapter was read](#uslib-reg-r23). Explicitly not an ASB promulgation and not binding R23. The implementation companion to R3 and ASOP 52 (R31); updates the 2017 edition for VM changes since the 12/31/2019 valuation [search summary].

R24. Life Insurance Illustrations: Application of the NAIC Life Insurance Illustrations Model Regulation and ASOP No. 24 — Practice Note (September 2021)#

  • Publisher: American Academy of Actuaries, Life Illustrations Work Group

  • URL: https://actuary.org/wp-content/uploads/2021/09/Life_Illustrations_Practice_Note_Update.pdf

  • Accessed: 2026-08-03

  • Fetched: yes (137-page PDF retrieved and read; title page verified)

  • Annotation: Practitioner Q&A on illustration-actuary work under Model #582 and ASOP 24: disciplined current scale development, self-support and lapse-support testing, certification practice, and application to indexed products under the AG 49 family [R24 title/front matter; detailed topic list partly unverified](#uslib-reg-r24). The companion to R4/R30 for building illustration logic into product models. Not applicable to VUL (outside Model #582 scope R4).

R25. Life Principle-Based Reserves (PBR) Assumptions Resource Manual (January 2019)#

  • Publisher: American Academy of Actuaries, PBR Assumptions Resource Manual Work Group (Life Practice Council)

  • URL: https://www.actuary.org/sites/default/files/files/publications/PBR_Assumptions_Resource_Manual_012919.pdf (301-redirects to http://actuary.org/…; same path)

  • Accessed: 2026-08-03

  • Fetched: yes (86-page PDF retrieved and read; title page verified)

  • Annotation: “An actuary’s step-by-step sample framework for setting, updating, and governing life insurance assumptions for PBR and other valuation frameworks” R25 — assumption governance, documentation, and update-cycle patterns that a model library’s assumption architecture can mirror. Non-binding, non-ASB R25. Especially useful for ULSG/term assumption governance.

  • Note on UL practice notes: no current standalone Academy “universal life” practice note was located on actuary.org (search performed 2026-08-03); UL-specific practice content lives in R23–R25, ASOP 2 (R26), and the illustration materials. The Academy’s practice-note index is at https://actuary.org/practice-notes/ (not fetched).

5. Actuarial Standards of Practice (ASB)#

Current numbers/titles verified against the ASB standards list (fetched 2026-08-03).

R26. ASOP No. 2 — Nonguaranteed Elements for Life Insurance and Annuity Products#

  • Publisher: Actuarial Standards Board

  • URL: https://www.actuarialstandardsboard.org/asops/asop-no-2-nonguaranteed-elements-for-life-insurance-and-annuity-products/

  • Accessed: 2026-08-03

  • Fetched: yes (adopted Sept. 2021; effective June 1, 2022)

  • Annotation: Governs determination (and support of illustration) of nonguaranteed elements — credited rates, COI charges, expense loads, indeterminate premiums — for individual life and annuity forms where NGEs vary at insurer discretion, including UL and indeterminate-premium life R26. Excludes dividends (ASOP 15, R28) and illustrations under ASOP 24 (R30) R26. Defines the determination-policy/framework discipline a model’s NGE re-rating logic should reflect.

R27. ASOP No. 7 — Life or Health Cash Flow Analysis#

  • Publisher: Actuarial Standards Board

  • URL: https://www.actuarialstandardsboard.org/asops/life-or-health-cash-flow-analysis/

  • Accessed: 2026-08-03

  • Fetched: yes (revision adopted December 2025; effective June 1, 2026)

  • Annotation: The revised cash-flow-analysis standard (successor to “Analysis of Life, Health, or Property/Casualty Insurer Cash Flows”; P/C content moved to ASOP 20) R27. Applies to actuaries analyzing life/health cash flow risks — the general standard for asset/liability cash flow projection work of exactly the kind a reference model performs R27. Pairs with ASOP 22 (R29) for opinions and ASOP 56 (R32) for model governance.

R28. ASOP No. 15 — Dividends for Individual Participating Life Insurance, Annuities, and Disability Insurance#

  • Publisher: Actuarial Standards Board

  • URL: https://www.actuarialstandardsboard.org/asops/dividends-individual-participating-life-insurance-annuities-disability-insurance/

  • Accessed: 2026-08-03

  • Fetched: yes (adopted March 2006; effective Aug. 1, 2006)

  • Annotation: Guidance on establishing/modifying dividend frameworks and determining/illustrating dividends for individual participating business (stock, mutual, fraternal), including participating riders R28. Excludes divisible-surplus aggregate determination and ASOP-24 illustration compliance R28. The contribution-principle mechanics behind a par whole life model’s dividend module (and par riders on other products).

R29. ASOP No. 22 — Statements of Actuarial Opinion Based on Asset Adequacy Analysis for Life Insurance, Annuity, or Health Insurance Reserves and Other Liabilities#

  • Publisher: Actuarial Standards Board

  • URL: https://www.actuarialstandardsboard.org/asops/asop-no-22-statements-of-actuarial-opinion-based-on-asset-adequacy-analysis-for-life-insurance-annuity-or-health-insurance-reserves-and-other-liabilities/

  • Accessed: 2026-08-03

  • Fetched: yes (adopted Sept. 2021; effective June 1, 2022)

  • Annotation: Standard for the appointed actuary’s asset adequacy opinion under the SVL/VM-30 framework (and analogous law) R29. Cash flow testing is the dominant technique [unverified — the standard admits multiple methods]; a liability projection model that will feed AAT/CFT must satisfy this standard’s analysis and documentation expectations, alongside ASOP 7 (R27) and ASOP 56 (R32). Applies at the company/block level for all products (ULSG and long-duration guarantees are typical stress points unverified).

R30. ASOP No. 24 — NAIC Life Insurance Illustrations Model Regulation#

  • Publisher: Actuarial Standards Board

  • URL: https://www.actuarialstandardsboard.org/asops/asop-24-naic-life-insurance-illustrations-model-regulation-024-217/

  • Accessed: 2026-08-03

  • Fetched: yes (standard’s page; Doc. No. 217; the PDF at https://www.actuarialstandardsboard.org/wp-content/uploads/2024/09/asop024_217.pdf was not separately fetched)

  • Annotation: Applies when actuaries certify that illustrated scales comply with Model #582 or with AG 49/AG 49-A R30. Covers illustrated-scale work only; currently-payable-scale determination belongs to ASOP 2 (R26) and ASOP 15 (R28) R30. The revision adopted September 2024 (effective December 1, 2024) is the current edition — it postdates and reflects the indexed-product guidelines R30.

R31. ASOP No. 52 — Principle-Based Reserves for Life Products under the NAIC Valuation Manual#

  • Publisher: Actuarial Standards Board

  • URL: https://www.actuarialstandardsboard.org/asops/principle-based-reserves-life-products-naic-valuation-manual/

  • Accessed: 2026-08-03

  • Fetched: yes (adopted Sept. 2017; effective Dec. 31, 2017)

  • Annotation: Standard for actuaries calculating or reviewing VM-20 reserves, extending to any actuary participating in the principle-based methodology R31. Notably, if the standard conflicts with the operative Valuation Manual, “the provisions of the Valuation Manual shall govern” R31. Sets expectations on assumptions, margins, model granularity, and documentation that flow into VM-31 reporting for all VM-20 products.

R32. ASOP No. 56 — Modeling#

  • Publisher: Actuarial Standards Board

  • URL: https://www.actuarialstandardsboard.org/asops/modeling-3/

  • Accessed: 2026-08-03

  • Fetched: yes (adopted Dec. 2019; effective Oct. 1, 2020)

  • Annotation: Cross-practice standard for designing, developing, selecting, modifying, using, reviewing, or evaluating models where reliance on model output has a material effect [R32 scope; component list partly unverified](#uslib-reg-r32). The governing standard for the reference implementation itself: intended purpose, model-risk mitigation, validation/testing, reliance on others’ models and data, and documentation R32.

6. Accounting frameworks — why one cash flow model serves several bases#

R33. NAIC Accounting Practices and Procedures Manual (statutory basis)#

  • Publisher: NAIC

  • URL: https://content.naic.org/publications

  • Accessed: 2026-08-03

  • Fetched: yes (publications page describing the manual; the manual itself is a paid publication and was not fetched)

  • Superseded in fact by R73 (2026-08-04): the “As of March 2026” edition was subsequently retrieved in full as a free download from the same publications page. The “paid publication and was not fetched” marker above records the 2026-08-03 retrieval attempt and is retained unaltered per the never-rewrite-a-frozen-entry rule; treat R73 as the governing record of availability. Consequence worth acting on: Appendix C (the actuarial guidelines, including AG 33 and AG 35) and Appendices A-820/A-830 are therefore obtainable, and the “AG 33/AG 35 text is paywalled” caveat carried in the annuity entries is a closable gap that no pass has yet closed. Closed 2026-08-06 (appended, nothing above reworded): that pass was made — AG 33 is now R151, AG 35 R152, A-820 (with A-821 and A-822) R153, A-830 R154, A-585 R155, A-250 R156 and A-255 R157, all read in full from the free download.

  • Annotation: The AP&P Manual “includes all statutory accounting guidance that has been adopted by the NAIC as of March of the current year,” including appendices with excerpts of applicable model laws, working-group interpretations, actuarial guidelines (Appendix C — where AG 38/48/49 officially live), and financial-reporting implementation guidance; updated annually R33. Statutory accounting is the conservative, solvency-oriented frame in which Models 820/830, the Valuation Manual, and the AGs operate; a liability model’s statutory outputs (reserves, nonforfeiture floors) plug into this basis.

R34. FASB ASU No. 2018-12 — Financial Services—Insurance (Topic 944): Targeted Improvements to the Accounting for Long-Duration Contracts (LDTI)#

  • Publisher: Financial Accounting Standards Board

  • URL: https://www.fasb.org (fasb.org blocked automated fetch — both https://www.fasb.org/insurance and a direct document URL returned HTTP 403; no working deep link is cited to avoid fabricating one. An accessible third-party full text is PwC Viewpoint: https://viewpoint.pwc.com/dt/us/en/fasb_financial_accou/asus_fulltext/2018/asu_201812financial_/asu_201812financial__US/asu_201812financial__US.html — fetch failed with redirect loop, likely auth-gated.)

  • Accessed: 2026-08-03 (fetch attempts on this date; document not retrieved)

  • Fetched: no (title, scope, and effective dates corroborated across multiple secondary sources: BDO, Deloitte, KPMG, PwC summaries via search)

  • Annotation: ASU 2018-12 rewrote U.S. GAAP for long-duration contracts: liability for future policy benefits with annually reviewed cash flow assumptions and discounting at an upper-medium-grade (single-A) rate through OCI, market risk benefits at fair value, simplified DAC amortization, and greatly expanded disclosures [unverified — consistent across the cited summaries]. Effective for large SEC filers Jan. 1, 2023 (2025 for others) [search summaries]. A GAAP valuation run needs the same projected cash flows as statutory but different assumption update/locking, discounting, and amortization overlays — a key reason to separate cash flow projection from measurement in model architecture. Product mapping — term/WL as traditional LFPB; UL/IUL/VUL/ULSG as universal-life-type contracts with additional liabilities/SOP 03-1-style features and MRBs — is unverified.

Tax reserves (cross-reference R16)#

IRC § 807 defines tax reserves off the NAIC-prescribed method: the greater of net surrender value and 92.81% of the CRVM/VM-computed reserve, capped at statutory, discounted at NAIC-permitted rates R16. The same statutory engine, with a scalar haircut and cap logic, therefore produces the tax basis, while the DEFRA/TEFRA/TAMRA definitional rules (group 2) decide whether the contract is life insurance at all. Together, statutory (R33), GAAP LDTI (R34), and tax (R16) explain why a single liability cash flow projection typically feeds at least three measurement wrappers.

7. NAIC valuation for annuities — VM-21, VM-22, and the CARVM guideline family#

Entries R35–R72 support the individual annuity products. Where an annuity-specific document is a section of a document already catalogued (VM-21 and VM-22 inside the Valuation Manual, R3), a separate entry is created because annuity models cite the section directly; the parent document is cross-referenced, not restated.

R35. VM-21: Requirements for Principle-Based Reserves for Variable Annuities (Valuation Manual, Jan. 1, 2026 Edition)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf (pages 21-1 to 21-79 of the 457-page PDF; same document as R3)

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; Sections 1, 2, 3 and the table of contents read in full; “NAIC Adoptions through August 13, 2025”)

  • Annotation: The statutory reserve standard for variable annuities, and it constitutes CARVM for every contract in its scope — variable deferred and variable immediate contracts with or without GMDB/VAGLB, group annuity contracts with similar guarantees, and any other contract with GMDB/VAGLB-like guarantees having no other explicit reserve requirement (reserved stand-alone and added to the base contract reserve) R35. Aggregate reserve = the stochastic reserve + the additional standard projection amount + any Alternative Methodology reserve, where the SR is CTE70 of the scenario reserves and each scenario contributes the greatest present value of accumulated deficiency from a stochastic asset/liability projection on prudent-estimate assumptions R35. Sections 9–13 carry the machinery an implementer needs — hedges under a Clearly Defined Hedging Strategy (§9), contract holder behavior (§10), prudent-estimate mortality (§11), allocation of the aggregate reserve to contract level (§13) — and it is effective for valuation dates on or after Jan. 1, 2020 with an elective 36-month phase-in (extendable to seven years with domiciliary approval) computed as Reserve = D − (B − A) × C / B, plus a separate 36-month economic scenario generator phase-in beginning Jan. 1, 2026 for the GOES requirements in VM-20 Appendix 1 R35. Architecturally decisive: VM-21 states its projections are anticipated to be used for RBC and that VM-21 §§4.A–4.E and the RBC requirements are identical except for the elective federal-income-tax treatment R35 — one projection, two outputs (see R47).

R36. VM-22: Requirements for Principle-Based Reserves for Non-Variable Annuities (Valuation Manual, Jan. 1, 2026 Edition)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf (pages 22-1 to 22-90; same document as R3)

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; Sections 1, 2, 3.A–3.F and the table of contents read in full)

  • Annotation: In the 2026 edition VM-22 is entirely the principle-based framework for non-variable annuities and “constitute[s] the Commissioners Annuity Reserve Valuation Method (CARVM) and, for some contracts and certificates, the Commissioners Reserve Valuation Method (CRVM)”; it applies for valuation dates on or after January 1, 2026, with an elective transition allowing business issued during the first three years after the effective date to stay on VM-A/VM-C/VM-M/VM-V, an irrevocable election once VM-22 PBR is chosen for a block, and mandatory prospective application three years after the effective date (i.e., Jan. 1, 2029 [unverified — the text states the rule as “three years after the effective date”; it does not print the date]) R36. Aggregate reserve = SR (CTE70) + DR for contracts passing the Single Scenario Test + the reserve for contracts passing the exclusion test and valued under VM-A/VM-C/VM-M/VM-V; the additional standard projection amount is disclosure-only under VM-31, and a LATF referral of April 3, 2025 directs the VM-22 Subgroup to add attribution analysis and to reiterate that “the SPA is not a safe harbor,” targeted at the 1/1/2027 Valuation Manual R36. Reserving Categories — which may not be aggregated except under §3.F.2 — are Payout Annuity (SPIA, DIA, structured settlements, annuitizations of host contracts, supplementary contracts with scheduled payments, Model #820 §5.C.2 certificates, pension risk transfer), Longevity Reinsurance, and Accumulation (everything else, including fixed income streams from guaranteed living benefits after account exhaustion); risks explicitly to be reflected include disintermediation, additional premium dump-ins under high guarantees in low-rate environments, annuitization risk, and GLB utilization risk R36. Caution: VM-22 was historically the home of maximum valuation interest rates for income annuities; in this edition that content is not in VM-22 — it is in VM-V Section 1 (R37), so a model citing “VM-22 income annuity interest rates” against a current Valuation Manual is citing the wrong section R36 R37.

R37. VM-V: Statutory Maximum Valuation Interest Rates for Formulaic Reserves, Section 1 — Income Annuities#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf (pages V-1 to V-3+; same document as R3)

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; §1.A Purpose and Scope and §1.B Definitions read)

  • Annotation: Defines, for SPIAs “and other similar contracts, certificates and contract features,” the statutory maximum valuation interest rate complying with Model #820 — the maximum interest assumption for CARVM (and for some contracts CRVM) on formulaic annuity reserves R37. For issues after Dec. 31, 2017 the scope covers immediate annuities; deferred income annuity contracts; structured settlements in payout or deferred status; fixed payouts from settlement options or annuitizations of host contracts; supplementary contracts with scheduled payments; fixed income streams from contingent deferred annuities and from guaranteed living benefits once contract funds are exhausted; and Model #820 §5.C.2 group annuity certificates R37. It applies to contracts not passing the SET covered by VM-22 — i.e., VM-V is the formulaic fallback where VM-22 PBR is excluded — with interest set by a “reference period” / Valuation Rate Bucket mechanic keyed to the premium determination date and the timing of the first life-contingent payment R37. Critically, VM-V §1 supersedes the interest-rate guidance in VM-A and VM-C, expressly including AG IX-B and the interest references in AG IX-C R37.

R38. Actuarial Guideline XLIII — CARVM for Variable Annuities (AG 43)#

  • Publisher: NAIC (this print is the VAIWG redlined working copy dated 2016-09-26, showing the 2009 text with the reform-era edits; the official text lives in the AP&P Manual Appendix C, R33)

  • URL: https://content.naic.org/sites/default/files/inline-files/cmte_e_va_issues_wg_related_redlined_ag43_160926.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; TOC, Section I Background, Section IV Reserve Methodology, and Section V Effective Date read)

  • Annotation: The predecessor regime to VM-21 and still operative for in-force, “codif[ying] the basic interpretation of the Commissioners Annuity Reserve Valuation Method (CARVM)” under the SVL for variable annuities and contracts with similar guarantees R38. Reserve structure: the Aggregate Reserve is the Standard Scenario Amount plus the excess, if any, of the Conditional Tail Expectation Amount over the Standard Scenario Amount — a floor-plus-excess construct materially different from VM-21’s SR + additional standard projection amount — with the CTE Amount being CTE(70), the average of the largest 30% of scenario greatest present values of accumulated deficiency, and twelve appendices carrying projections, reinsurance, standard scenario, Alternative Methodology, scenario calibration, hedging, certification, contract holder behavior, prudent-estimate mortality and general-account assets R38. The Guideline affects all contracts issued on or after January 1, 1981, effective Dec. 31, 2009 (the redline shows the reform-era change to 2018) R38. Not simply superseded: VM-21 states that contracts subject to VM-21 may be aggregated with AG 43 contracts, and that “through reference in AG 43, the reserve requirements in VM-21 also apply to those contracts issued prior to Jan. 1, 2017, that would not otherwise be encompassed by the scope of VM-21” — so AG 43 is the scoping shell that pulls pre-2017 VA business onto the VM-21 calculation, and if the two are aggregated VM-G corporate governance applies to the combined valuation R35.

R39. Actuarial Guideline XXXIII — Determining CARVM Reserves for Annuity Contracts With Elective Benefits (AG 33)#

  • Publisher: NAIC

  • URL: none — no free official standalone text was located. Title and current status verified from the Valuation Manual’s VM-C index (page C-1) R41; the authoritative text is in the AP&P Manual Appendix C (R33), a paid publication. A related Academy proposal document is public but is not the guideline: http://actuary.org/wp-content/uploads/2017/11/AG-33_Non-Elective_Incidence_Reserve_Proposal_8-22-13.pdf (not fetched)

  • Accessed: 2026-08-04 (search date; guideline text not retrieved)

  • Fetched: no — title and continued incorporation verified via R41; the substantive description below is from secondary sources and is tagged accordingly

  • Annotation: The interpretive core of formulaic CARVM for deferred annuities. CARVM sets the reserve as the greatest present value, over all elective benefit streams, of future guaranteed benefits; AG 33 specifies how to construct and value those integrated benefit streams, how elective benefits (surrender, partial withdrawal, annuitization at guaranteed purchase rates, nursing-home waivers) combine with non-elective benefits (death, and other non-mortality incidence), and what the “efficient policyholder selection” assumption means in practice [unverified — consistent across the Academy proposal document and the Journal of Actuarial Practice treatment of AG 33/34, neither fetched]. For an implementer this is the guideline that turns a deferred-annuity account-value roll-forward into a set of benefit streams and takes the maximum present value across them — the formulaic reserve any pre-VM-22 or VM-22-excluded fixed deferred annuity still requires. AG 35 (R40) layers the index feature onto this calculation R40 context.

  • Superseded in fact by R151 (2026-08-06) — appended, nothing above reworded. The guideline text has since been read in full from the AP&P Manual, which proved to be a free download (see the note on R33), so the “unverified … from secondary sources” annotation above is now closed by R151. Two of its substantive claims are wrong against the printed text and must not be relied on: (a) it lists nursing-home waivers among the elective benefits — AG 33’s own Definitions place nursing home benefits expressly in the non-elective enumeration; and (b) “efficient policyholder selection” is not AG 33’s language and appears nowhere in the guideline — the actual construction prohibits experience-based elective incidence, maximises over trial sets, and directs that elective benefits be “consider[ed], not necessarily test[ed]”. Both are corrected in R151. The wording above is retained unaltered because R1–R150 are frozen; cite R151 for anything substantive about AG 33.

R40. Actuarial Guideline XXXV — The Application of the Commissioners Annuity Reserve Method to Equity Indexed Annuities (AG 35)#

  • Publisher: NAIC

  • URL: none — no free official standalone text was located. Exact title verified from the Valuation Manual’s VM-C index (page C-2) R41; the authoritative text is in the AP&P Manual Appendix C (R33), a paid publication.

  • Accessed: 2026-08-04 (search date; guideline text not retrieved)

  • Fetched: no — title and continued incorporation verified via R41

  • Annotation: The CARVM treatment of the index feature in equity-indexed (now generally “fixed indexed”) annuities: it does not replace AG 33 but specifies how the index-linked benefit is brought into the AG 33 greatest-present-value calculation, offering alternative method families (industry shorthand “Type 1” / “Type 2”), imposing certification and notification requirements when a method is chosen or changed, and requiring that equity-indexed annuity reserves be asset-adequacy tested [unverified — from a practitioner presentation, not the guideline text]. The asset-adequacy requirement is the modelling consequence that matters most: an FIA block cannot rely on the formulaic reserve alone, so the same cash flow model must serve CARVM and ASOP 22 cash flow testing (R29).

R41. VM-C: Appendix C — Actuarial Guidelines (index of guidelines incorporated into the Valuation Manual)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf (pages C-1 to C-2; same document as R3)

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; the complete two-page index read)

  • Annotation: The authoritative, current list of which actuarial guidelines the Valuation Manual incorporates, with their exact titles — the cheapest way to verify a guideline number without buying the AP&P Manual (it “references the following requirements from Appendix C of the AP&P Manual”) R41. The annuity/CARVM family it lists: II (interest rate guarantees on active life funds under group annuity contracts); VIII (valuation of individual single premium deferred annuities); IX (form classification of individual SPIAs); IX-A and IX-C (substandard annuity mortality for impaired lives — structured settlements and SPIAs respectively); IX-B (methods under the SVL for individual SPIAs, associated deferred payments, some deferred annuities and structured settlements); XIII (guideline concerning CARVM); XXXIII (R39); XXXV (R40); XL (valuation rate of interest for funding agreements and GICs with bail-out provisions); and XLI (projection of guaranteed nonforfeiture benefits under CARVM) R41 — with IX-B and IX-C superseded on valuation interest rates by VM-V §1 for in-scope contracts R37. Verified negative finding: the VM-C index contains no AG XLIII, no AG XLIX/XLIX-A, and no AG LIV R41; AG 43 sits in AP&P Appendix C but outside VM-C because its remaining work is on pre-VM contracts R35, and AG 54 is a nonforfeiture guideline, not a valuation one R44. Do not infer a guideline’s non-existence from absence here, and do not infer its VM applicability from presence elsewhere.

8. NAIC nonforfeiture and market conduct for annuities#

R42. Standard Nonforfeiture Law for Individual Deferred Annuities (Model #805)#

  • Publisher: NAIC (print: “NAIC Model Laws, Regulations, Guidelines and Other Resources—Fall 2020”)

  • URL: https://content.naic.org/sites/default/files/model-law-805.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; Sections 1–8 read in full)

  • Annotation: The floor under every fixed deferred annuity’s cash value, and the single most mechanically precise item in this library. The minimum nonforfeiture amount accumulates net considerations = 87.5% of gross considerations at the Subsection B interest rate, decreased by prior withdrawals and partial surrenders (accumulated at the same rates), an annual contract charge of $50 (accumulated), premium tax actually paid by the company, and any indebtedness with accrued interest R42. The indexed nonforfeiture rate (Subsection B) is the lesser of 3% and the five-year Constant Maturity Treasury Rate reported by the Federal Reserve as of a date, or averaged over a period, specified in the contract and no longer than 15 months before the issue or redetermination date, rounded to the nearest 1/20th of one percent, reduced by 125 basis points, and floored at 15 basis points (0.15%); Subsection C allows that 125bp reduction to be increased by up to an additional 100 basis points during a period in which the contract provides “substantive participation in an equity indexed benefit,” provided the present value of the additional reduction at issue and at each redetermination does not exceed the market value of the equity benefit, demonstrable on the commissioner’s demand R42. Cash surrender value must be at least the present value of the accrued paid-up annuity at a rate no more than 1% higher than the contract accumulation rate and never less than the minimum nonforfeiture amount, and the death benefit must be at least the cash surrender benefit R42. Section 2 scope exclusions: reinsurance; employer/employee-organization group annuities under retirement or deferred compensation plans other than those providing IRC §408 IRAs/individual retirement annuities; premium deposit funds; variable annuities; investment annuities; immediate annuities; deferred annuities after annuity payments have commenced; reversionary annuities; and out-of-state deliveries — and Sections 3–8 do not apply to contingent deferred annuities, for which the commissioner may prescribe nonforfeiture by regulation R42.

R43. Variable Annuity Model Regulation (Model #250)#

  • Publisher: NAIC (print: “NAIC Model Laws… — October 2007”)

  • URL: https://content.naic.org/sites/default/files/model-law-250.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; TOC and Section 7 read)

  • Annotation: #250 is the Variable Annuity Model Regulation, not the Annuity Disclosure Model Regulation — that is #245 (R45) — verified from both model-law prints and independently from AG 54, which cites “NAIC Model 250, Variable Annuity Model Regulation” R43 R44 R45. It covers insurer qualification to issue variable annuities, separate accounts, contract filing, required contract provisions, nonforfeiture benefits, required reports, and agent qualification, with Section 7 the load-bearing part for modelling: §7.A excludes the same categories as Model #805 (reinsurance, qualifying group retirement plans, premium deposit funds, investment annuities, immediate annuities, deferred annuities in payout, reversionary annuities, out-of-state deliveries) R43. §7.B is the boundary rule: “To the extent that a variable annuity contract provides benefits that do not vary in accordance with the investment performance of a separate account before the annuity commencement date, the contract shall contain provisions that satisfy the requirements of [Model #805] and shall not otherwise be subject to this section” — so the fixed account inside a VA is tested against Model #805, assuming 100% of considerations allocated to the fixed account; §7.C requires paid-up annuity benefits on cessation of considerations and lump-sum surrender provisions where offered R43. AG 54 (R44) exists precisely because Model #250 defines variable annuities by reference to separate-account investment experience and non-unitized ILVA accounts do not automatically satisfy it R44.

R44. Actuarial Guideline LIV — Nonforfeiture Requirements for Index-Linked Variable Annuity Products (AG 54)#

  • Publisher: NAIC (adopted by Life Actuarial (A) Task Force 12/11/2022; adopted by Life Insurance and Annuities (A) Committee 2/24/2023)

  • URL: https://content.naic.org/sites/default/files/committees-pending-action-actuarial-guideline-liv-230224.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; the complete 6-page guideline read, including project history)

  • Annotation: Its stated purpose is “to specify the conditions under which an Index-Linked Variable Annuity (ILVA) is consistent with the definition of a variable annuity and exempt from Model 805 and specify nonforfeiture requirements consistent with variable annuities”; the NAIC deliberately adopts ILVA over “RILA”/”structured annuity” to signal that compliant designs are variable annuities first R44. The mechanism a model must implement: because an ILVA account is not unitized, Interim Values must be materially consistent with a Hypothetical Portfolio = Fixed Income Asset Proxy + Derivative Asset Proxy, less a provision for reasonably expected or actual Trading Costs at the time the Interim Value is calculated — the Index Strategy Base equals the Strategy Value at term start, the Fixed Income Asset Proxy is a hypothetical bond whose book value starts at (Index Strategy Base − Derivative Asset Proxy value) and at unchanged yield accretes to the Index Strategy Base at term end, and Derivative Asset Proxy assumptions (implied volatilities, risk-free rates, dividend yields) must be consistent with observable market prices wherever possible and valued by Black-Scholes, Monte Carlo, or other market-consistent techniques R44. Non-Hypothetical-Portfolio methodologies are permitted only on a demonstration of material consistency across each Index Strategy / Index Strategy Term combination “under a reasonable number of realistic economic scenarios that include index changes that test crediting constraints and recognize initial option pricing market conditions,” and an actuarial memorandum with certifications is required with each ILVA product filing (equity between contract holder and company, market-consistency of derivative assumptions, material consistency of contractual Interim Values, reasonableness of Trading Costs); in-scope Index Strategies must comply with Model #250 Section 7 excluding §7.B R44. Effective for all contracts, riders, endorsements and amendments issued on or after July 1, 2024; whether an MVA is included or excluded, and any MVA formula, is left to the states under the equity principle; and an ILVA that fails this guideline is not a variable annuity and falls under Model #805 (R42) R44.

R45. Annuity Disclosure Model Regulation (Model #245)#

  • Publisher: NAIC (print: “NAIC Model Laws… — Summer 2021”)

  • URL: https://content.naic.org/sites/default/files/model-law-245.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; Sections 1 and 3 read; Section 6 and Appendix A structure confirmed from the TOC)

  • Annotation: The annuity counterpart to Model #582 — and the correct model number is #245, not #250 (R43) — setting minimum disclosure for annuity contracts and, in Section 6, standards for annuity illustrations, with Appendix A providing an annuity illustration example and Sections 5 (disclosure document and Buyer’s Guide) and 7 (report to contract owners) carrying the rest R45. Scope (Section 3) is what a modeller must read first: it applies to all group and individual annuity contracts and certificates except (A) immediate and deferred annuities containing no non-guaranteed elements; (B) annuities funding ERISA plans, 401(a)/401(k)/403(b), 414/457 governmental and church plans, and nonqualified deferred compensation arrangements — with a carve-back for employee-elective-contribution arrangements involving direct solicitation where two or more fixed annuity providers are offered; (C) non-registered variable annuities sold only to accredited investors/qualified purchasers in exempt transactions; and (D) transactions in variable annuities and other registered products complying with SEC and FINRA disclosure/illustration rules — though the Buyer’s Guide is still required in variable annuity sales R45. Do not reuse AG 49 / AG 49-A logic (R8–R10) for FIA illustrations: indexed-annuity illustration limits run through this regulation, and they are constructed differently from the IUL guidelines. A drafting note flags NSMIA preemption risk over the §3.D(1) sunset language R45.

R46. Suitability in Annuity Transactions Model Regulation (Model #275)#

  • Publisher: NAIC (print: “NAIC Model Laws… — Spring 2020”; this print is the 2020 best-interest revision)

  • URL: https://content.naic.org/sites/default/files/model-law-275.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; TOC and Section 1 read)

  • Annotation: The 2020 best-interest revision, adopted by the NAIC on February 13, 2020 [unverified as to the exact adoption date — the print carries “Spring 2020” and the best-interest text, which confirms the substance]. Section 1.A states the purpose plainly: to require producers “to act in the best interest of the consumer when making a recommendation of an annuity and to require insurers to establish and maintain a system to supervise recommendations,” and the structure is Purpose / Scope / Authority / Exemptions / Definitions / Duties of Insurers and Producers (Section 6) / Producer Training / Compliance Mitigation and Penalties / Recordkeeping / Effective Date, with three appendices (producer disclosure for annuities, consumer refusal to provide information, consumer decision to purchase not based on a recommendation) R46. Section 6 organises the best-interest obligation into four obligations — care, disclosure, conflict of interest, and documentation — aligned with SEC Regulation Best Interest [unverified — from NAIC and industry summaries, not read in the section text]. Modelling relevance is indirect but real: best-interest supervision changes exchange/1035 activity and therefore surrender and replacement assumptions, and the producer-disclosure appendix affects distribution cost structures; the requirements are intended to supplement, not replace, Model #245 disclosure unverified.

9. Capital — C-3 Phase II and the variable annuity framework reform#

R47. C-3 RBC Instructions and Appendices (incorporating the Academy’s C3 Phase II Report for variable annuities)#

  • Publisher: NAIC RBC instructions, transmitted with a memo from the American Academy of Actuaries C3 Life and Annuity Capital Work Group to the NAIC Life RBC Working Group dated November 24, 2009

  • URL: https://content.naic.org/sites/default/files/inline-files/committees_e_capad_lrbc_C3_RBC_instructions_package.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; transmittal memo, “Calculation of the Total Asset Requirement,” “Application of the Tax Adjustment,” and “Calculation of the Standard Scenario Amount” read)

  • Annotation: The mechanics of C-3 Phase II market-risk RBC for variable annuities as incorporated into the Life RBC instructions: Appendix 2 directly incorporates the Academy’s June 2005 “Recommended Approach for Setting Risk-Based Capital Requirements for Variable Annuities and Similar Products” and Appendix 3 the September 2009 C3 Phase III report for life products R47. The calculation a model must reproduce: run stochastic scenarios on prudent best-estimate assumptions with calibrated fund performance distributions; for each scenario compute accumulated statutory surplus including federal income tax and take the negative of the lowest present value as that scenario’s asset requirement, modelling statutory reserve as equal to the working reserve; set the Total Asset Requirement at CTE 90; and RBC = the excess of the TAR over statutory reserves, subject to the Standard Scenario and the smoothing/transition rules, then combined with C1CS for covariance R47. A Tax Adjustment is required where modelled tax reserves are set equal to Working Reserves but actual tax reserves exceed them at the start of the projection, correcting the understatement of modelled tax expense via a factor f derived from the reserve ratio at the worst duration; the Standard Scenario Amount is a floor — a single prescribed projection of account values with specified returns and prescribed assumptions — and where it exceeds the stochastic result it becomes the TAR before tax adjustment R47. Caveat for implementers: this print states a 35% federal income tax rate and predates both TCJA and the 2018–2020 VA framework reform R47; use it for structure, and R48 plus the current VM-21 (R35) and Life RBC instructions for parameters.

R48. Variable Annuity Statutory Reserve and Capital Reform — QIS II Public Report and Executive Summary#

  • Publisher: Oliver Wyman, for the NAIC Variable Annuity Issues (E) Working Group (VAIWG)

  • URL (public report): https://content.naic.org/sites/default/files/committee_related_documents/cmte_e_va_issues_wg_related_qis_ii_public_report.pdf

  • URL (executive summary): https://content.naic.org/sites/default/files/committee_related_documents/cmte_e_va_issues_wg_related_qis_ii_executive_summary.pdf

  • Accessed: 2026-08-04

  • Fetched: yes, both (local text extraction; background, purpose and recommendation sections read; both documents dated February 12, 2018)

  • Annotation: The adopting-era analytical documents behind the 2018–2020 NAIC variable annuity reserve and capital framework reform — the reform that produced the 2020 VM-21 and the revised C-3 Phase II R48. Diagnosed root causes: penalties for economic-based hedging (fully hedging fair value increased capital requirements and RBC ratio volatility); structural deficiencies in the Standard Scenario that prevented alignment with the stochastic calculation it governs; and lack of harmonization in scenario projection practice — while preserving principles-based reserving, a book-value statutory approach, the “time-to-worst” accumulated-deficiency measure, real-world capital markets scenarios, and a Standard Scenario construct to govern assumptions R48. Key parameterisation outcome: the C-3 charge is computed as the difference between a higher-confidence “CTE High” amount and the statutory reserve, both on the same distribution of projected deficiencies; CTE High was provisionally CTE 98, and QIS II recommended CTE 95 with a 25% scalar under the alternative equity scenarios, chosen so that hedging would reduce a company’s total funding requirement at a typical target RBC ratio, with equity scenario calibration tested over a 1926–2016 window R48. History as recorded: C3 Phase II enacted 2006 and AG 43 in 2009; Oliver Wyman engaged after captive reserve-financing pressure, preliminary report September 10, 2015; QIS I (fifteen companies, February–July 2016); recommendations to the VAIWG August 23, 2016 with redlined AG 43 and C3 Phase II guidance September 26, 2016 (R38 is that redline); a 60-day exposure from September 15, 2016; then QIS II in 2017 R48.

10. Federal securities regulation — registered annuity products#

R49. Registration for Index-Linked Annuities and Registered Market Value Adjustment Annuities; Amendments to Form N-4 for Index-Linked Annuities, Registered Market Value Adjustment Annuities, and Variable Annuities; Other Technical Amendments#

  • Publisher: U.S. Securities and Exchange Commission

  • URL: https://www.govinfo.gov/content/pkg/FR-2024-07-24/html/2024-14925.htm (89 Fed. Reg. 59978, July 24, 2024). The SEC’s own PDF, https://www.sec.gov/files/rules/final/2024/33-11294.pdf, returned HTTP 403 and was not fetched.

  • Accessed: 2026-08-04

  • Fetched: yes, via govinfo.gov R49; publication metadata independently corroborated by GAO’s rule report, https://www.gao.gov/products/b-336553 (fetched) R49b

  • Annotation: Release Nos. 33-11294; 34-100450; IC-35273; File No. S7-16-23; RIN 3235-AN30, published at 89 Fed. Reg. 59978 (July 24, 2024) and effective September 23, 2024 R49 R49b. The statutory driver is the Registration for Index-Linked Annuities Act, enacted as Division AA, Title I of the Consolidated Appropriations Act, 2023, which directed the Commission to adopt a new RILA registration form within 18 months R49. What it requires: RILA and registered MVA issuers must register on Form N-4 rather than S-1/S-3; provide tailored disclosure of cap rates, participation rates, buffers and floors, contract adjustments and surrender charges; use layered disclosure with a Key Information Table in prescribed format; optionally use summary prospectuses for continuous offerings; pay registration fees annually on net issuances; and comply with Rule 156 on sales literature R49. Compliance date: May 1, 2026 — initial registration statements filed on or after that date must comply with amended Form N-4, and RILAs previously registered on Forms S-1 or S-3 must file a Rule 485(a) post-effective amendment on Form N-4 by that date [unverified as to the mechanics — the date is consistently reported across filing-agent and law-firm summaries; the release’s section II.J was not read in full].

R50. Updated Disclosure Requirements and Summary Prospectus for Variable Annuity and Variable Life Insurance Contracts (Rule 498A adopting release)#

  • Publisher: U.S. Securities and Exchange Commission

  • URL: https://www.govinfo.gov/content/pkg/FR-2020-05-01/html/2020-05526.htm (the SEC’s own PDF at https://www.sec.gov/files/rules/final/2020/33-10765.pdf returned HTTP 403 and was not fetched)

  • Accessed: 2026-08-04

  • Fetched: yes, via govinfo.gov

  • Annotation: Release Nos. 33-10765; 34-88358; IC-33814; File No. S7-23-18; RIN 3235-AK60; effective July 1, 2020, with certain provisions effective January 1, 2022 R50. It adopted Rule 498A, an optional layered-disclosure framework letting variable contract issuers satisfy prospectus delivery through an Initial Summary Prospectus for new investors and an Updating Summary Prospectus for existing investors, with the full statutory prospectus and SAI available online free and on request in paper R50. The mandatory Key Information Table consolidates five topics — fees and expenses, risks, restrictions on access, taxes, and conflicts of interest — in standardized order to allow cross-product comparison, and Forms N-4 and N-6 were modernized to condense summary information, reflect the prevalence of optional benefit riders, and require Inline XBRL tagging of specified prospectus disclosures R50. The Commission’s stated rationale was that bundled variable contract prospectuses frequently exceed 100 pages R50.

R51. 17 C.F.R. § 230.498A — Summary prospectuses for separate accounts offering variable annuity and variable life insurance contracts and for offering registered non-variable annuity contracts#

  • Publisher: U.S. Government (Code of Federal Regulations), via Legal Information Institute, Cornell Law School

  • URL: https://www.law.cornell.edu/cfr/text/17/230.498A

  • Accessed: 2026-08-04

  • Fetched: yes

  • Annotation: The operative rule text, and the reason to cite it separately from R50: the current title has been extended to “and for offering registered non-variable annuity contracts”, reflecting the 2024 RILA rulemaking (R49) R51. It deems a compliant summary prospectus a prospectus under Securities Act §10(b) for delivery purposes R51. Delivery obligations are satisfied when the summary prospectus reaches the investor by the time the contract is delivered; the summary meets the content requirements; the registrant keeps current statutory prospectuses and related documents accessible on a specified website for at least 90 days; and paper copies are furnished on request within three business days R51. Applies to registrants on Forms N-3, N-4 and N-6 R51.

R52. SEC Form N-4 — Registration statement for separate accounts organized as unit investment trusts (as amended for RILAs and registered MVA annuities)#

  • Publisher: U.S. Securities and Exchange Commission

  • URL: https://www.sec.gov/files/formn-4.pdf

  • Accessed: 2026-08-04 (fetch attempted on this date; document not retrieved)

  • Fetched: no — sec.gov returned HTTP 403 to automated fetch on 2026-08-04. The URL is genuine (it appears in SEC search indexing), but the form text was not retrieved.

  • Annotation: The form itself is the disclosure schema a variable annuity or RILA product must populate, and its current content requirements are described first-hand only through the adopting releases that created and amended them — R50 for the post-2020 structure (condensed summary, optional benefits, Key Information Table, Inline XBRL) and R49 for the RILA/MVA extension (cap rates, participation rates, buffers, floors, contract adjustments, surrender charges) R49 R50. For a modelling library the value is mainly in reverse: the fee table and Key Information Table define the charge taxonomy — mortality and expense risk charge, administrative charge, contract maintenance fee, optional benefit rider charges, surrender charges — that a VA/RILA cash flow model must expose as parameters.

R53. SEC Rule 151A and Annuities: Issues and Legislation (CRS Report R40656)#

  • Publisher: Congressional Research Service (secondary, but authoritative on legislative history)

  • URL: https://www.everycrsreport.com/reports/R40656.html

  • Accessed: 2026-08-04

  • Fetched: yes

  • Annotation: The clean history of why fixed indexed annuities are not registered securities, which a product library needs in order to justify treating FIA and RILA as different regulatory animals. Rule 151A, finalized December 17, 2008 and published January 16, 2009 after roughly 4,800 comments, would have classified indexed annuities as securities where “the amounts payable by the insurer… are more likely than not to exceed” the guaranteed minimums, effective January 12, 2011; in American Equity Investment Life Insurance Co. v. SEC the U.S. Court of Appeals for the D.C. Circuit held on July 21, 2009 that the SEC’s classification was reasonable but its analysis of effects on efficiency, competition and capital formation inadequate, and vacated Rule 151A on July 12, 2010 R53. Dodd-Frank § 989J (P.L. 111-203, signed July 21, 2010 — the “Harkin amendment”) then directed the SEC to treat annuities meeting specified conditions as exempt securities, returning them to state insurance regulation R53. Net effect for a model library: FIAs are state-regulated non-registered products governed by Model #805 (R42), Model #245 (R45) and AG 33/35 (R39/R40); RILAs, which expose the contract holder to index losses, are registered and governed additionally by R49–R52 and AG 54 (R44).

R54. FINRA Rule 2330 — Members’ Responsibilities Regarding Deferred Variable Annuities#

  • Publisher: Financial Industry Regulatory Authority

  • URL: https://www.finra.org/rules-guidance/rulebooks/finra-rules/2330

  • Accessed: 2026-08-04

  • Fetched: yes

  • Annotation: Governs broker-dealer conduct in recommended purchases and exchanges of deferred variable annuities and recommended initial subaccount allocations; it does not reach reallocations among subaccounts, and excludes 401(k)/403(b)/457 tax-qualified plans unless an individual participant receives a personalized recommendation R54. Before recommending, a member must have a reasonable basis to believe the transaction is suitable under Rule 2111 and that the customer has been informed of the surrender period and surrender charge and the potential tax penalty on redemption before age 59½, and a registered principal must review and approve the application no later than seven business days after an OSJ receives a complete and correct application package, with written supervisory procedures, surveillance for inappropriate exchange rates among associated persons, and documented training programs required R54. Modelling relevance: the principal-review window and exchange surveillance are the proximate regulatory brake on 1035 exchange velocity (R56) and therefore on VA replacement-driven surrender assumptions. Whether FINRA applies Rule 2330 to RILAs specifically is unverified — the rule text says “deferred variable annuities.”

11. Federal tax — annuities#

R55. 26 U.S.C. § 72 — Annuities; certain proceeds of endowment and life insurance contracts#

  • Publisher: Legal Information Institute, Cornell Law School (U.S. Code)

  • URL: https://www.law.cornell.edu/uscode/text/26/72

  • Accessed: 2026-08-04

  • Fetched: yes

  • Annotation: The core annuity tax section, and the one an illustration or in-force system must implement. §72(b) exclusion ratio: the excluded portion of each annuity payment bears the same ratio to the payment as the investment in the contract (premiums paid less prior excludable distributions) bears to the expected return, capped at unrecovered investment; §72(e) applies the LIFO / income-first rule to pre-annuity-starting-date distributions from deferred annuities, in contrast to the ratable basis recovery of annuitized payments R55. The aggregation rule — “all annuity contracts issued by the same company to the same policyholder during any calendar year shall be treated as 1 annuity contract” — is a real modelling requirement for multi-contract policyholders, and §72(q) adds a 10% penalty on the includible portion of distributions from non-qualified annuity contracts (exceptions include age 59½, death, disability, substantially equal periodic payments, and amounts allocable to investment before August 14, 1982), with §72(t) the parallel 10% additional tax for qualified plans and IRAs R55. §72(s) requires that on the holder’s death after annuitization the remaining interest distribute at least as rapidly as under the pre-death method, and on death before annuitization the entire interest within five years subject to a beneficiary-life-expectancy exception — the provision that shapes death-benefit payout modelling — and §72(u) strips deferral from contracts held by non-natural persons, treating the primary annuitant as the holder R55.

R56. 26 U.S.C. § 1035 — Certain exchanges of insurance policies#

  • Publisher: Legal Information Institute, Cornell Law School

  • URL: https://www.law.cornell.edu/uscode/text/26/1035

  • Accessed: 2026-08-04

  • Fetched: yes

  • Annotation: Tax-free exchange relief, and the asymmetry matters. Permitted: life → life, endowment, annuity, or qualified long-term care; endowment → endowment (with payments beginning no later than under the original), annuity, or qualified LTC; annuity → annuity or qualified LTC; qualified LTC → qualified LTC — so an annuity cannot be exchanged tax-free for a life insurance contract, and relief does not apply to transfers having the effect of transferring property to a non-U.S. person R56. Modelling relevance: 1035 exchanges are the dominant source of both new-business premium and surrender activity in the deferred annuity market, so an exchange assumption is a first-class input, and the annuity→life prohibition constrains which replacement flows a model should even contemplate. Read with FINRA Rule 2330 (R54) and Model #275 (R46), which together throttle exchange velocity in the registered and best-interest channels.

R57. 26 C.F.R. § 1.401(a)(9)-6 — Required minimum distributions for defined benefit plans and annuity contracts (QLAC rules)#

  • Publisher: Legal Information Institute, Cornell Law School (CFR)

  • URL: https://www.law.cornell.edu/cfr/text/26/1.401(a)(9)-6

  • Accessed: 2026-08-04

  • Fetched: yes

  • Annotation: The regulation that makes qualifying longevity annuity contracts possible and constrains their design: QLAC distributions “must commence not later than a specified annuity starting date that is no later than the first day of the month next following the 85th anniversary” of the employee’s birth, and the contract may not offer “any commutation benefit, cash surrender right, or other similar feature” after the required beginning date, subject to a 90-day rescission exception R57. A QLAC is therefore modelled with no surrender value, which removes the entire lapse module from the liability; dollar limitations sit in paragraph (q)(2) R57 (see R58 for the current $200,000 figure and the elimination of the 25%-of-account-balance limit). More generally, distributions must be periodic annuity payments for life, joint lives, or a period certain, at uniform intervals not exceeding one year, and nonincreasing except as permitted — the rule that forbids most increasing-payment DIA designs in qualified money — with actuarial increases required for employees retiring after age 70½, from April 1 following that birthday until commencement, using reasonable actuarial assumptions R57.

R58. Required Minimum Distributions — Final Regulations (T.D. 10001)#

  • Publisher: Internal Revenue Service / U.S. Treasury (Federal Register, July 19, 2024)

  • URL: https://www.govinfo.gov/content/pkg/FR-2024-07-19/html/2024-14542.htm

  • Accessed: 2026-08-04

  • Fetched: yes, via govinfo.gov

  • Annotation: T.D. 10001; RIN 1545-BP82; published July 19, 2024; effective September 17, 2024; applicable for calendar years beginning January 1, 2025 (with §1.402(c)-2 applying to distributions on or after that date), finalizing regulations under IRC §§401(a)(9), 402(c), 403(b), 408, 457 and 4974 and incorporating SECURE and SECURE 2.0 changes R58. The annuity-relevant content: SECURE 2.0 §202 directed amendments to §1.401(a)(9)-6 that eliminate the 25%-of-account-balance limitation on QLAC premiums, raise the dollar cap from $125,000 to $200,000 (inflation-adjusted), permit joint-and-survivor benefits to survive divorce under qualified-domestic-relations-order conditions, and add a 90-day free-look rescission R58. The regulations also address bifurcation where an annuity is purchased with part of an individual account — the annuity payments satisfy §1.401(a)(9)-6 while the residual account satisfies §1.401(a)(9)-5 — and SECURE 2.0 §204 adds an elective partial annuitization alternative under which the required amount is the excess of the total required amount for the year over the annuity amount for that year, aggregating the annuity contract value with the remaining account balance R58. RMD timing is a behavioral input as well as a tax one: GLWB activation clusters at the RMD age (R64).

12. Annuitant mortality and annuity experience studies#

R59. NAIC Model Rule (Regulation) for Recognizing a New Annuity Mortality Table for Use in Determining Reserve Liabilities for Annuities (Model #821), with the corresponding VM-M definitions#

  • Publisher: NAIC (model print: “NAIC Model Laws… — January 2013”), plus the Valuation Manual appendix

  • URL (model): https://content.naic.org/sites/default/files/model-law-821.pdf

  • URL (VM-M definitions): https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf (VM-M §1.I–§1.M, §2.C; same document as R3)

  • Accessed: 2026-08-04

  • Fetched: yes, both (local text extraction)

  • Annotation: The statutory annuity mortality basis. Model #821 recognizes, for the minimum standard of valuation of annuity and pure endowment contracts, the 1983 Table “a”, the 1983 GAM Table, the Annuity 2000 Mortality Table, the 2012 Individual Annuity Reserving (2012 IAR) Mortality Table, and the 1994 GAR Table, with Appendices I–IV printing the 2012 IAM Period Table (female and male, age nearest birthday) and Projection Scale G2 R59. The 2012 IAR is a generational table: VM-M §1.J prints qx2012+n = qx2012 × (1 − G2x)n, with the result rounded to three decimal places per 1,000 and — an implementation trap the manual calls out explicitly — the rounding applied from the 2012 period rate each time, never by compounding an already-rounded prior-year rate; worked example: male age 30, q2012 = 0.741 → q2014 = 0.741 × 0.99² = 0.7262541 → 0.726 (not 0.727) R59. VM-M §2.C defines the 2012 IAM Basic Table as the unloaded table underlying the Period Table, developed from the 2002 experience table projected to 2012, and records that the underlying 2000–2004 Payout Annuity Mortality Experience Study covered immediate annuities, annuitizations and life settlement options from 16 companies, excluding substandard annuities, structured settlement annuities and variable payout annuities R59 — an exclusion that matters when the modelled block includes those. The 2012 IAM/Scale G2 tables themselves live in AP&P Manual Appendix A-821 R59 R33.

R60. 2012 Individual Annuity Reserving Table — Report of the joint American Academy of Actuaries / Society of Actuaries Payout Annuity Table Team#

  • Publisher: American Academy of Actuaries and Society of Actuaries (joint subgroup of the Life Experience Subcommittee), presented to the NAIC Life Actuarial Task Force; September 2011 (chair: Mary Bahna-Nolan)

  • URL: http://actuary.org/wp-content/uploads/2017/11/Payout_Annuity_Report_09-28-11.pdf (https:// redirects to http:// on the same path)

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; title page, TOC, and the margin/loading sections read)

  • Annotation: The development report behind R59 — what a modeller needs when justifying or stress-testing the valuation basis. LATF’s charge was to produce a new annuity valuation mortality table “including projection scales and margins necessary to make the table suitable for standard valuation purposes for individual annuities,” and the IAR Table is the composition of three pieces: the 2012 IAM Basic Table, the margin, and Projection Scale G2 R60. The margin, as recommended by the Team and agreed by LATF, is 10% at all ages up to and including 100, grading down 1% per year above age 100 until the ultimate mortality cap of 0.40000 is invoked, producing a zero margin at the cap; LATF concluded there was no compelling reason to depart from the approach or level used for the a2000 Table R60. The report also covers graduation, younger-age and older-age adjustments (Kannisto-form extrapolation at the oldest ages), the derivation of improvement from 2002 to 2012, A/E analysis against the unloaded 2012 IAM adjusted to January 1, 2007 (the midpoint of the underlying experience), and tabulated reserve-impact comparisons against the a2000 Table R60.

R61. 2020–2024 Individual Payout Annuity Mortality Experience Study#

  • Publisher: LIMRA and the Society of Actuaries Research Institute (joint)

  • URL: https://www.soa.org/resources/experience-studies/2026/2020-24-individual-payout/

  • Accessed: 2026-08-04

  • Fetched: yes (landing page; the free public report PDF and the paid Standard Data Package were not separately fetched)

  • Annotation: The current annuitant-longevity experience basis: 23 parent company groups covering 26 individual companies, over 80% of industry sales during the study period, 3.1 million contract-years and $33 billion of annual-income-years of exposure, and 143,190 deaths over five years R61. Results are presented against the 2012 IAM Table, the prior study, and U.S. population mortality R61 — i.e., it is directly usable as the A/E evidence for a prudent-estimate or best-estimate deviation from R59. Deliverables are a free public PDF plus a purchasable Standard Data Package with executive summary, in-depth analysis and interactive dashboards; the predecessor is the 2014–2019 Individual Payout Annuity Mortality Experience Study (December 2022; 25 companies, ~80% of market, ~4.3 million contract-years, ~236,000 deaths) R61 R65.

R62. Fixed Indexed Annuity Policyholder Behavior Experience Studies (2021–2022, with 2019–2020 predecessor)#

  • Publisher: LIMRA and the Society of Actuaries Research Institute (joint)

  • URL (2021–22): https://www.soa.org/resources/experience-studies/2024/21-22-fia/

  • URL (2019–20): https://www.soa.org/resources/experience-studies/2023/19-20-fia/

  • Accessed: 2026-08-04

  • Fetched: yes, both landing pages (free public report PDFs and paid data packages not separately fetched)

  • Annotation: The public basis for FIA surrender and withdrawal assumptions. The 2021–2022 study covers 12 companies, ~4.8 million contracts of surrender exposure by count, $526 billion of contract value exposure, over 227,000 surrenders and $15.9 billion of withdrawals, with comparisons “to several expected bases of policyholder behavior, including the current valuation standard”; the 2019–2020 study covers 17 parent company groupings / 20 individual companies, roughly two-thirds of industry new sales and assets, ~4.9 million contracts valued at $503 billion, over 195,000 surrenders and $13.7 billion of withdrawals R62. The headline finding a model must encode is the interaction between surrender-charge expiry and the GLWB rider: in the year the surrender charge expires, the surrender rate was about 10% for contracts with a GLWB rider versus about 33% without [unverified — reported consistently in LIMRA/SOA press coverage of the 2019–20 study, not read in the report PDF]. That is the difference between a shock-lapse assumption and a rider-suppressed one, and it is product-design-dependent, not a single industry number.

R63. Fixed Rate Deferred Surrender Experience Studies (2023–24, with 2015–2022 predecessor)#

  • Publisher: LIMRA and the Society of Actuaries Research Institute (joint)

  • URL (2023–24): https://www.soa.org/resources/experience-studies/2025/2023-24-fixed-rate-deferred/

  • URL (2015–2022 report PDF): https://www.soa.org/49c0c1/globalassets/assets/files/resources/experience-studies/2024/15-22-frds.pdf (not fetched)

  • Accessed: 2026-08-04

  • Fetched: partially — both titles, dates and URLs verified from the SOA’s Individual Annuity Experience Studies index (R65) R65; neither the landing page nor the report PDF was fetched individually

  • Annotation: The surrender basis for MYGA / fixed-rate deferred annuities, where the shock at surrender-charge expiry is far more violent than in FIA because there is no living-benefit rider anchoring the contract holder. Reported surrender rates by contract count in the year the surrender charge expired were roughly 51.7% for 2020 and 55.7% for 2021 [unverified — from trade-press coverage of the 2015–2022 study, not read in the report]. Compare with the ~10%/~33% FIA figures at R62: the same event, three very different assumptions, driven by rider presence and rate-differential dynamics.

R64. Variable Annuity Contract Holder Behavior and Guaranteed Living Benefit Utilization Studies (2022–2024, with the 2019–2021 and the 2013–2018 GLB utilization series)#

  • Publisher: LIMRA and the Society of Actuaries Research Institute (joint)

  • URL (2022–24): https://www.soa.org/resources/experience-studies/2025/2022-24-va-livingbenefit/

  • URL (2019–21): https://www.soa.org/resources/experience-studies/2023/19-21-va/ (not fetched; verified via R65)

  • URL (2015-experience GLB utilization report PDF): https://www.soa.org/globalassets/assets/Files/resources/research-report/2018/variable-annuity-guaranteed-utilization.pdf (not fetched)

  • Accessed: 2026-08-04

  • Fetched: yes (2022–24 landing page) R64; the others verified via R65 only

  • Annotation: The public basis for VA and RILA behavior assumptions. The 2022–2024 study covers 17 companies representing approximately 48% of new premium for VAs and RILAs, about 11.5 million contracts valued at $1.5 trillion, with over 625,000 surrender events and 4 million withdrawal transactions ($56.7 billion of contract value withdrawn) R64 — note the explicit inclusion of RILAs in the premium-share denominator. What a GLWB model needs from the utilization series (from the earlier reports): roughly 79% of owners taking withdrawals withdrew at or near the maximum permitted amount (up to 110%), about 55% withdrew between 90% and 110% of the maximum, most withdrawals run through systematic withdrawal plans which keep owners inside the guaranteed maximum, owners rarely add premium after contract year two, and activation clusters at the RMD age [unverified — these figures come from SOA/LIMRA summaries of the 2013/2015-experience utilization studies, not read in the report PDFs]. The RMD clustering is the reason R58 is a behavioral input to a GLWB model, not merely a tax one.

R65. SOA Individual Annuity Experience Studies — index#

  • Publisher: Society of Actuaries Research Institute

  • URL: https://www.soa.org/research/topics/indiv-ann-exp-study-list/

  • Accessed: 2026-08-04

  • Fetched: yes (complete list read)

  • Annotation: The authoritative index of publicly available individual annuity experience studies, and the cheapest way to check whether an assumption source has been superseded R65. It catalogues, by year: payout annuity mortality (2000–04, 2005–08, 2009–13, 2014–19, 2020–24); fixed indexed annuity behavior (2013–15, 2016–18, 2019–20, 2021–22); fixed rate deferred surrender (2015–22, 2023–24); variable annuity contract owner behavior (2019–21) and the VA guaranteed living benefits utilization series (2011 through 2018 experience); deferred annuity mortality (2011–2015); structured settlement mortality (1997, 2000–08, 2009–13, 2005–17); a Deferred Annuity Persistency Report (2006); and “Analysis of Mortality Experience Under Variable and Fixed Individual Annuities During the Deferred Period” (2006) R65. The last two are the only public sources located for deferred-period (pre-annuitization) annuitant mortality — a distinct and much under-served assumption relative to payout mortality.

13. Professional standards and practice notes — annuities#

R66. Implementation of Requirements for Principle-Based Reserves for Variable Annuities — 2022 Edition of VM-21 (Practice Note Supplement)#

  • Publisher: American Academy of Actuaries, Variable Annuity Reserves & Capital Work Group of the Life Practice Council (chair: Connie Tang); February 2022, 34 pages

  • URL: https://actuary.org/wp-content/uploads/2022/02/VA_PN_Supplement_Final.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; title page, introduction, acronym list and full table of contents read)

  • Annotation: The implementation companion to VM-21 (R35), written specifically for the 2020 revisions to VA principle-based reserves and capital. Its eight sections map almost exactly onto the decisions a VA cash flow model has to make: 1. Transition; 2. Standard Projection (including product/contractual conflicts); 3. Asset Modeling & Discount Rates; 4. Scenarios; 5. Hedging; 6. C-3 Phase 2 RBC; 7. Disclosures; 8. Miscellaneous, and its acronym list is itself a useful glossary (CDHS, Company-Specific Market Path, CTE with Prescribed Assumptions, Direct Iteration Method, Guarantee Actuarial Present Value, GPVAD, IMR) R66. Explicitly not binding: it “is not a promulgation of the Actuarial Standards Board, is not an actuarial standard of practice, is not binding upon any actuary” R66. Two cautions it states directly: readers must check differences between the VM-21 edition the note was written against and the edition applicable to the current valuation, since the Valuation Manual is a living document; and the note does not cover state variations such as New York Regulation 213 R66.

R67. Utilization Assumptions of Guaranteed Living Benefits for Deferred Annuities — A Resource and Discussion Guide#

  • Publisher: American Academy of Actuaries, Life Experience Committee (chair: Donna Claire); May 2024

  • URL: https://actuary.org/wp-content/uploads/2024/05/life-paper-GLBs.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; title page and front matter read)

  • Annotation: The profession’s assembled thinking on the single hardest assumption in the deferred annuity model — when and how intensely contract holders use a guaranteed living benefit. The Academy is explicit about its status: it “is not a promulgation of the Actuarial Standards Board, is not an actuarial standard of practice (ASOP), is not binding upon any actuary… This document should not be treated as guidance but rather it should be read and utilized as a list of considerations and resources on a particular topic” R67. Treat it as a checklist of drivers — moneyness, age and RMD timing, qualified versus non-qualified, distribution channel, systematic withdrawal plan enrolment, rider type — to test a utilization assumption against, and as the bridge from the experience data in R64 to a prudent-estimate assumption that will satisfy VM-21 §10 (R35) or VM-22 §10 (R36).

R68. Fixed Indexed Annuities — Product Mechanics and Risk Management#

  • Publisher: American Academy of Actuaries, Life Experience and Assumptions Committee (chair: Kyle Wan); February 2026

  • URL: https://actuary.org/wp-content/uploads/2026/02/life-FIA-policypaper.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; title page, table of contents and the crediting-method sections read)

  • Annotation: The most current and most directly implementable public description of FIA mechanics, structured as Introduction; Examples of Index Crediting Methods; investment strategy, ALM and hedging considerations; and Reserves and Regulations R68. It defines the crediting levers precisely — participation rate (the percentage of index return credited: 10% index return at 80% participation with a 6% cap), cap, and spread (a percentage deducted from the index return) — and works a full annual point-to-point example against the S&P 500 showing a 7% cap and 0% floor binding in a year when the normalized index rose 25%, while noting the industry shift toward custom indices with built-in volatility control and covering averaging and monthly point-to-point variants R68. It explains the option budget framing — the insurer allocates a portion of premium to derivatives to hedge the index-linked credits — and links crediting design back to nonforfeiture limits and the nonforfeiture rate R68, i.e., to R42.

R69. Index-Linked Variable Annuity (ILVA) / Registered Index-Linked Annuity (RILA) Policy Paper#

  • Publisher: American Academy of Actuaries, Index-Linked Variable Annuity Subcommittee (chair: Elizabeth Keith); December 2025

  • URL: https://actuary.org/wp-content/uploads/2025/12/Life-PolicyPaper120225.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; title page, table of contents and the interim-value sections read)

  • Annotation: The bridge between AG 54’s legal text (R44) and an actual RILA implementation. It describes the product family — downside protection via a buffer, dual-direction buffer, or floor, and upside parameters of cap rate, participation rate, buffer and floor, with more complex strategies adding trigger rates, dual-direction buffers and performance locks — noting that design complexity constrains the company’s ability to hedge and value the strategy R69. It restates the two AG 54 guiding principles (interim values provide equity between contract holder and company; interim values are consistent with the Hypothetical Portfolio over the Index Strategy Term) and explains the consequence: a compliant ILVA is exempt from Model #805 and subject instead to variable annuity nonforfeiture under Model #250 R69. It covers interim values under AG 54 and separately under the Interstate Insurance Compact standards, addresses U.S. statutory risk-based capital for ILVAs, and treats practical valuation issues such as hedge-cost inference and bid/mid/ask spread treatment in Trading Costs R69.

R70. ASOP No. 54 — Pricing of Life Insurance and Annuity Products#

  • Publisher: Actuarial Standards Board

  • URL: https://www.actuarialstandardsboard.org/asops/pricing-of-life-insurance-and-annuity-products/

  • Accessed: 2026-08-04

  • Fetched: yes (adopted June 2018; effective December 1, 2018)

  • Annotation: Not in R1–R34 and squarely applicable to annuity work: it applies when actuaries perform pricing services for life insurance and annuity products at initial development or when charges or benefits change for future sales, covering individual policy forms and group master contracts with individually-priced certificates, and excluding the pricing of reinsurance contracts R70. It requires the actuary to consider the principal’s profitability criteria, risk-capital approach and risk-management policies; select profitability metrics (it lists IRR, ROE, profit margin, ROA, value of new business, and break-even year); develop or select models accommodating product design, time horizon, granularity, dynamic assumptions, economic scenarios, asset returns, accounting bases, risk capital frameworks, taxes and risk-mitigation strategies; set internally consistent assumptions with margins where credible data is lacking; perform sensitivity and stochastic risk evaluation; and implement governance controls including model validation and independent review R70. For an annuity reference model this is the standard that justifies a pricing-mode output (profit metrics, dynamic lapse, hedge cost) alongside the valuation outputs.

R71. ASOP No. 10 — U.S. GAAP for Long-Duration Life, Annuity, and Health Products (Revised Edition)#

  • Publisher: Actuarial Standards Board (Revised Edition, adopted by the ASB December 2022, Doc. No. 207)

  • URL: http://www.actuarialstandardsboard.org/wp-content/uploads/2023/01/asop010_207.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; title page, full table of contents, §§1.1–1.4 read)

  • Annotation: Not in R1–R34, and the professional-standards counterpart to the LDTI accounting standard already catalogued at R34. Effective for actuarial services related to the preparation or review of insurance company GAAP financial statements applicable to fiscal periods ending on or after May 1, 2023, with scope covering long-duration life, annuity, or health products and yielding to applicable law and to authoritative GAAP guidance (ASC, SEC Staff Accounting Bulletins) where they conflict R71. Its definitions section is the working vocabulary an LDTI-capable annuity model must implement — Best-Estimate Assumption, Cohort, Deferred Policy Acquisition Cost, Deferred Sales Inducements, GAAP Net Premiums, Liability for Future Policy Benefits, Lock-In, Market-Estimate Assumption, Market Risk Benefit, Net GAAP Liability, Policy Benefit Liability, Premium Deficiency, Risk of Adverse Deviation, and Value of Business Acquired — and Section 3 covers classification of contracts, features and benefits and the best-estimate versus market-estimate assumption split R71, the classification decision that determines whether a GLWB is an MRB or an insurance liability. Caution: two ASB pages carry ASOP 10 exposure drafts (an April 2022 proposed-revision page was fetched and is clearly labelled an exposure draft, not adopted R71b: https://www.actuarialstandardsboard.org/asops/asop-no-10-ssun-u-s-gaap-for-long-duration-life-annuity-and-health-products/); cite the Doc. No. 207 PDF above, which states adoption on its title page.

14. Annuity half (R35–R72) — gaps, fetch failures, and unverified points#

Verified findings that correct assumptions a reader may bring

  1. Model numbers. #245 is the Annuity Disclosure Model Regulation (R45) and #250 is the Variable Annuity Model Regulation (R43) — verified against both model-law prints and AG 54’s own citation R43 R44 R45.

  2. VM-22’s scope in the current edition. In the Jan. 1, 2026 edition VM-22 is entirely the principle-based framework for non-variable annuities; the maximum valuation interest rates for income annuities are in VM-V Section 1 (R37), not VM-22 R36 R37.

  3. AG 54 exists and is a nonforfeiture guideline. Actuarial Guideline LIV, effective for contracts issued on or after July 1, 2024, and it does not appear in the VM-C index R41 R44.

  4. AG 43 is not simply superseded by VM-21. Through reference in AG 43, VM-21’s requirements also apply to pre-2017 contracts outside VM-21’s own scope, and the two populations may be reserved as a single aggregated group R35 — any statement that AG 43 is “replaced” is wrong in a way that changes in-force model scope.

  5. There is no ASOP for principle-based reserves for annuities. ASOP 52 (R31) is scoped to life products under VM-20 and no VM-21 or VM-22 analogue exists (verified against the full ASB standards list, fetched 2026-08-04). The nearest professional guidance is the non-binding Academy practice note supplement (R66).

What could not be verified

  • AG 33 and AG 35 full texts (R39, R40) — CLOSED 2026-08-06. When this section was written no free standalone copy had been located and the authoritative text was believed to sit behind a paid publication, so every substantive statement about their mechanics was tagged unverified and this was recorded as “the single largest hole in the annuity half”. Both guidelines have now been read in full from AP&P Manual Appendix C, which is part of a free download (R73): AG 33 is R151 (printed AG33-1 to AG33-8, PDF 1496–1503) and AG 35 is R152 (printed AG35-1 to AG35-10, PDF 1505–1514). Formulaic CARVM for fixed and indexed deferred annuities no longer rests on unread guidelines; cite R151 and R152 for the mechanics instead of carrying unverified. R39 and R40 are frozen and are preserved unaltered — their annotations are superseded in fact, and the specific corrections (nursing home benefits are non-elective; “efficient policyholder selection” is not AG 33’s phrase; “Type 1”/”Type 2” are AG 35’s own defined terms; AG 35’s asset adequacy sentence is conditional) are recorded inside R151 and R152.

  • What the two guidelines still leave unsettled. AG 33 prints no amendment history, so the December 31, 1998 effective date it carries cannot be reconciled here with the December 31, 1995 date the fixed-deferred-annuity documents take from IRS Rev. Rul. 2002-6 under a differently titled instrument — record both, and treat the obvious “it was revised” reading as an inference. AG 35 prints no effective, adoption or operative date at all, so any date attached to it in this library is from outside the text. Neither guideline resolves RILA/ILVA: AG 35 defines no term “equity indexed annuity” and never mentions separate accounts or registered products, and AG 33 reaches a RILA only through the general “any elective benefits” trigger. And AG 35 points the valuation interest rate at “AG XXXIII or Actuarial Guideline IX-B” three times — AG IX-B has not been read, and is indexed in this library only through VM-C (R41).

  • SEC primary documents. sec.gov returned HTTP 403 on every attempt (press release 2024-81, /files/rules/final/2024/33-11294.pdf, /files/formn-4.pdf). Release metadata and substance were recovered from govinfo.gov (R49, R50) and GAO (R49b), which is why those entries are marked fetched. Form N-4 itself (R52) was never retrieved — its requirements are described only through the adopting releases.

  • The RILA compliance date of May 1, 2026 is consistently reported by filing agents and law firms, but section II.J of Release 33-11294 was not read, so the date carries unverified in R49 even though the effective date (September 23, 2024) is verified twice R49 R49b.

  • federalregister.gov and ecfr.gov both 302-redirect to a bot-block page; govinfo.gov and law.cornell.edu were substituted throughout.

  • IRS LB&I directives (R72). irs.gov returned HTTP 404 on both directive URLs surfaced by search; the control number, date and substance are unverified.

  • A successor to the 2012 IAR valuation table could not be confirmed to exist. The LATF charges page (fetched 2026-08-04) states generally that the Task Force works “with the American Academy of Actuaries and the Society of Actuaries… to develop new mortality tables for valuation and minimum nonforfeiture requirements,” and lists active subgroups (VM-22, Experience Reporting, GOES, Longevity Risk, Variable Annuities Capital and Reserve) — but it names no annuity mortality table project and no IAR replacement. No such project is asserted here. The 2012 IAR (R59) remains the recognized valuation table, while the experience underneath it has moved materially; the 2020–2024 payout study (R61) measures against the 2012 IAM basis directly, which is the right place to look for evidence of drift.

  • Quantitative behavior figures. The FIA shock-lapse split (~10% with GLWB vs ~33% without), the fixed-rate-deferred shock lapse (~52%/~56%), and the GLWB withdrawal-efficiency distribution (~79% at or near maximum) all come from press summaries and landing pages, not from the study PDFs, which sit behind paid data packages. They are tagged unverified in R62, R63 and R64 and should be treated as order-of-magnitude anchors, not calibration targets.

  • VM-22 mandatory date. VM-22 §2.B states the rule as “three years after the effective date” without printing a date R36; Jan. 1, 2029 is arithmetic, not quotation, and is tagged accordingly in R36.

  • C-3 Phase II parameters are stale in R47. The instructions package read carries a 35% federal income tax rate and predates both TCJA and the 2018–2020 reform R47. Its structure (CTE 90 TAR, RBC = TAR − statutory reserve, Standard Scenario floor, tax adjustment) is reliable; its numbers are not. Current parameters must come from the in-force Life RBC instructions, which were not located as a current standalone document.

  • Deferred-period annuitant mortality is served publicly by only two dated sources — a 2011–2015 deferred annuity mortality study and a 2006 analysis — both identified via the SOA index (R65) but neither fetched. This assumption is materially under-evidenced relative to payout mortality.

15. Retained statutory-basis entries (from the retired R73–R142 block)#

Entries R73–R142 carried a statutory accounting and capital research stream whose framework documents have been removed from the library. The ten entries below are retained because the AP&P Manual extraction files (_research/appp-*.md) and the product documents still cite them; every other number in R73–R149 is permanently retired — never reuse or renumber. Retired numbers still named inside the annotations below (e.g. R89/R90, R103/R105, R112, or spans such as R74–R97 and R100–R113) are historical record from when the block was whole; they no longer resolve to entries on this page.

R73. NAIC Accounting Practices and Procedures Manual, As of March 2026 (Volumes I and II)#

  • Publisher: National Association of Insurance Commissioners

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf (catalogue entry “APPM-2026 … Free Download” on https://content.naic.org/publications)

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; 2,117 pages; front matter, the full SSAP index, and the SSAPs catalogued at R74–R97 read directly)

  • Annotation: The complete authoritative statutory accounting text and the source-of-record for every SSAP paragraph cited in this half of the page — Volume I: Preamble, all SSAPs, Appendix A (excerpts of NAIC model laws: A-820 valuation, A-822 asset adequacy, A-830, A-791 life reinsurance conditions, A-695 synthetic GICs, A-200 group life separate accounts), Appendix B (interpretations, including INT 23-01); Volume II: Appendix C (actuarial guidelines — AG 33, 35, 38, 43, 48, 49-A, 51, and per R103/R105 also AG 53 and AG 55), Appendix D (GAAP-to-SAP cross-reference), Appendix E (issue papers), Appendix F (policy statements), Appendix G (implementation guide for the Annual Financial Reporting Model Regulation) R73. Completely superseded SSAPs are moved out to Appendix H, posted separately on the SAPWG web page R73. The per-SSAP entries that follow exist so product documentation can cite a specific statement rather than the whole manual.

  • Retrieval note — read together with R33, do not conflate. R33 (frozen) describes the manual from the publications landing page and records it as “a paid publication and was not fetched”; this edition is offered on that same catalogue as a Free Download and was retrieved in full. R33’s annotation is preserved verbatim and is superseded in fact, not amended. R73 is a different document (the manual) from R33 (the catalogue page). Note also that the statutory-reserves work catalogued at R100–R113 proceeded on the basis that the manual is paid, so A-820 and A-830 as printed in the manual were not retrieved — see section 22. Closed 2026-08-06: a later pass read the appendices out of this same download and gave them appendix-level numbers, so a reserve document can cite a paragraph rather than the whole manual — R151 AG 33 and R152 AG 35 from Volume II Appendix C; R153 A-820 with A-821 and A-822, R154 A-830, R155 A-585, R156 A-250 and R157 A-255 from Volume I Appendix A.

  • Licence caution (applies to R73 and everything drawn from it): personal and non-commercial use only; redistribution or integration “into any software or other publication” is prohibited without written NAIC permission R73. Product documentation must therefore paraphrase SSAP mechanics and cite the paragraph, never paste SSAP text. R89 and R90 carry the same notice.

  • Note on SSAP numbering: the “R” suffixes are gone. This edition prints and indexes the statements as SSAP No. 5, No. 43, No. 51, No. 54, No. 61; a full-text search finds no occurrence of “51R”, “54R” or “86R”, and “5R”/”61R”/”43R” survive only inside historical issue-paper and interpretation text R73. Cite the unsuffixed numbers for current guidance and keep the “R” form only when quoting pre-2024 material. The edition in which the suffix was removed was not located unverified.

R78. SSAP No. 50 — Classifications of Insurance or Managed Care Contracts (As of March 2026)#

  • Publisher: NAIC (in R73, statement pages 50-1 onward)

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; ¶¶1–20 read)

  • Annotation: The classification gate, and therefore the first branch in a statutory model. Four categories — life, accident and health, property and casualty, deposit-type — where a contract in which the entity “does not assume any mortality, morbidity, health benefit costs incurred, or casualty risk and which act[s] exclusively as [an] investment vehicle” is deposit-type, and critically “[s]uch classification shall be made at the inception of the contract and shall not change” R78 ¶5. Life contracts are enumerated to include whole life, endowment, term, supplementary contracts, group life, universal life type, variable life, limited payment, credit life and annuity contracts [¶9], with the generic reserve at ¶8 as PV(future benefits) − PV(future net premiums) on the valuation interest and mortality basis. ¶¶10–20 carry the statutory product definitions that the annual statement’s line-of-business columns key off R78.

R79. SSAP No. 51 — Life Contracts (As of March 2026; historically cited as SSAP No. 51R)#

  • Publisher: NAIC (in R73, statement pages 51-1 to 51-13)

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; status block and ¶¶1–16 read; section index read)

  • Annotation: Income recognition and policy reserves for everything SSAP No. 50 classifies as a life contract, except credit contracts (SSAP No. 59) and separate account products (SSAP No. 56, R83) R79 ¶1; conceptually revised June 9, 2016 with the revisions effective January 1, 2017, i.e. aligned to the Valuation Manual operative date R79. The mechanics a projection must honour: premium recognised gross, when due, with single and flexible premiums when received [¶5]; dividends applied to buy paid-up additions are premium income [¶6]; the change in loading on deferred and uncollected premium is an expense, not a reduction of premium [¶11]; a flexible-premium UL “waiver of monthly deductions” benefit is “not to be considered revenue nor a benefit paid” [¶14]; and ¶15 now expressly contemplates that formulaic reserves “will be supplemented for some policies with more advanced deterministic and/or stochastic reserve methodologies” for post-operative-date issues R79. Later sections cover mean-reserve and mid-terminal methods, the deferred-premium asset, advance premiums, dividend liability, change in valuation basis, accelerated benefits and the disclosure set — read for this library through Issue Paper No. 51 (R81), whose paragraph numbers differ.

R81. Statutory Issue Papers Nos. 50, 51, 52 and 110 — the codification record behind SSAP Nos. 50/51/52/56#

  • Publisher: NAIC (AP&P Appendix E; IP 50 finalized June 23, 1998; IP 51 and IP 52 finalized March 16, 1998; IP 110 finalized September 12, 2000)

  • URLs:

    • IP 50: https://content.naic.org/sites/default/files/inline-files/050_y.pdf

    • IP 51: https://content.naic.org/sites/default/files/inline-files/051_A.pdf

    • IP 52: https://content.naic.org/sites/default/files/inline-files/052_y.pdf

    • IP 110: https://content.naic.org/sites/default/files/inline-files/110_d.pdf

  • Accessed: 2026-08-04

  • Fetched: yes, all four (local text extraction; 22 / 26 / 14 / 3 pages)

  • Annotation: Free-standing, freely available companions to R78–R80 that carry the mechanical detail a model builder needs and that can be quoted more comfortably than the licensed manual. IP 51 is the source for the mean-reserve and mid-terminal methods and the deferred-premium asset: under the mean reserve method the reserve is the average of the terminal and initial reserves, assuming the whole annual net premium is collected at the start of the policy year, so because premiums actually arrive modally a deferred premium asset is set up equal to gross modal premiums from the next modal due date to the next anniversary, less those collected, less loading [R81/IP51 ¶21.a]; the mid-terminal method averages the surrounding terminal reserves and adds an unearned premium reserve [¶21.b]. IP 51 ¶19 states CARVM in plain terms as the greatest present value of guaranteed benefit streams computed at the end of each contract year, and IP 51 ¶28 / IP 52 ¶17 enumerate the “additional reserves not included elsewhere” bucket; IP 51 ¶30 / IP 52 ¶19 give the withdrawal-characteristics disclosure taxonomy in full (with MVA / at book less current surrender charge ≥5% / at market / at book without adjustment, sub-split by settlement form) R81. IP 110 records the amendments pulling Appendices A-200, A-695 and A-830 into SSAP Nos. 51, 52 and 56, effective January 1, 2001 with pre-2001 contracts on domiciliary-state law [R81/IP110 ¶10].

R83. SSAP No. 56 — Separate Accounts (As of March 2026)#

  • Publisher: NAIC (in R73, statement pages 56-1 to 56-14)

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; ¶¶1–31 and the glossary read)

  • Annotation: How variable and index-linked business splits across two balance sheets, and the entry that decides where a RILA’s assets sit. Sales, underwriting, contract administration, premium collection, premium tax, claims and benefits are general account functions [¶4]; for separate account life contracts, premiums are general account income and simultaneously a transfer to the separate account, with separate account charges and net gain from operations also general account income and benefits, surrenders, net transfers, commissions and premium taxes general account expenses [¶5]; a GMDB reserve on a variable annuity or variable life contract is held in the general account [¶7]; separate account surplus may not become negative [¶8]; and seed money is separate account surplus until repatriated [¶10]. ¶¶17–18 are the measurement rule: separate account assets are at fair value except the ¶18 categories, carried “as if the assets were held in the general account” (book value) — ¶18.a employer-plan fixed-rate fund accumulation GICs, and ¶18.b, with state regulator approval, insulated or non-insulated contracts similar to general account contracts that do not pass all investment experience through, where the general account “may serve as an overall backstop or may provide an implied guarantee”, naming pension risk transfer, bank-owned life insurance and registered index-linked annuity contracts as expected examples R83 ¶18.b. ¶¶19–22 govern inter-account asset transfers (book-value separate accounts take the seller’s BACV with the fair-value difference to IMR in the purchasing account, so the two accounts’ IMR nets to zero); ¶¶23–28 are the separate account AVR/IMR rules — an IMR is required only where assets are at book value, applied account by account, and an AVR is required where the reporting entity rather than the policyholder bears default or fair-value loss, so traditional VA and VL separate accounts need neither except AVR on seed money, while book-value, modified guaranteed, MVA and book-value-guarantee contracts do R83 ¶¶23–27. ¶30 requires the liability basis to follow the asset basis — A-820 valuation interest rates on a general-account basis, current market-based rates where assets are at fair value — and ¶45 rejects ASU 2018-12, ASU 2022-05 and SOP 03-1 R83.

R92. SSAP No. 61 — Life, Deposit-Type and Accident and Health Reinsurance (As of March 2026; historically 61R)#

  • Publisher: NAIC (in R73, statement pages 61-1 to 61-29 plus glossary)

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; ¶¶1–20, 36–38, 54–59 read; full section index read)

  • Annotation: The statutory accounting for ceded and assumed business, scoped to life, deposit-type and A&H contracts as classified by SSAP No. 50 [¶1]. ¶17 is the risk-transfer gate: an agreement that limits or diminishes risk transfer, or contains “any contractual feature that delays timely reimbursement”, follows Deposit Accounting instead; ¶17.b requires multiple contracts to be evaluated together where consideration under one depends on performance of another and they “achieve one overall planned effect”; and ¶17.c treats each leg of a combined YRT-plus-coinsurance structure satisfying risk transfer on its own basis as “necessary but not sufficient”, with the aggregate also required to avoid the Appendix A-791 prohibited conditions R92. ¶¶36–38 govern the reserve credit: computed with the same methodology and assumptions as the direct reserve and reported as a reduction of reserves, not an asset; YRT credit is the one-year term mean reserve on the amount ceded on the original policy’s basis; non-proportional credit only where the attachment point has been penetrated or on a demonstrated PV test R92. ¶54 sends interest-related gain or loss on reinsuring a block of liabilities to the IMR per the annual statement instructions, ¶¶55–57 recognise indemnity reinsurance losses immediately with initial-year gains on in-force blocks following A-791 ¶3, and ¶58 unwinds recaptures and commutations through the original accounts with the required IMR adjustment R92. Note: A-791 itself was not read (section 22); it is in R73 Appendix A.

R100. VM-30: Actuarial Opinion and Memorandum Requirements (Valuation Manual, Jan. 1, 2026 Edition)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf (pages 30-1 to 30-15; same document as R3)

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; Sections 1, 2 and 3 read in full, including the prescribed opinion wording and the Regulatory Asset Adequacy Issues Summary contents; copyright line “© 2025 National Association of Insurance Commissioners”)

  • Annotation: The operative U.S. requirement for the annual statement of actuarial opinion and supporting actuarial memorandum, issued under Section 3 of Model #820 (R1) and collectively called the AOM requirements — three sections and fifteen pages that turn a liability cash flow model into a regulatory deliverable R100. It requires the opinion to apply to all in-force business on the annual statement date, whether directly issued or assumed, regardless of when or where issued; requires any shortfall found by asset adequacy analysis to be established as an additional reserve, releasable in later years with disclosure; prescribes the exact wording of the identification, scope, reliance and opinion sections plus a table of key indicators (adverse / qualified / inconclusive) that must be ticked whenever the wording is changed; prescribes the asset-adequacy-tested amounts table, whose columns split every annual statement line into Formula Reserves, Principle-Based Reserves, Additional Reserves, Other Amount and Total with a per-line Analysis Method symbol; and prescribes the memorandum and RAAIS contents, an IMR/AVR allocation rule, an equity-return-volatility requirement and seven-year documentation retention R100. Verified negative finding: VM-30 contains no exemption clause and no prescribed interest scenarios — the word “exempt” does not appear in it at all, and the New York seven appear in the Valuation Manual only as an example inside a VM-20 §6 guidance note R100 R3. It expressly makes AG 48 (R11) and AG 51 applicable for VM-30 purposes R100.

R101. Actuarial Opinion and Memorandum Regulation (Model #822)#

  • Publisher: NAIC (print: “NAIC Model Laws, Regulations, Guidelines and Other Resources—April 2010”; © 2010)

  • URL: https://content.naic.org/sites/default/files/model-law-822.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; 16-page PDF, Sections 1–7 read). A direct WebFetch of the same URL failed — the tool received raw PDF streams — which is why local extraction was used.

  • Annotation: Model #822 is confirmed to exist, to be numbered 822, and to be titled “Actuarial Opinion and Memorandum Regulation”, with seven sections: Purpose / Authority / Scope / Definitions / General Requirements / Statement of Actuarial Opinion Based On Asset Adequacy Analysis (§6) / Description of Actuarial Memorandum Including an Asset Adequacy Analysis and Regulatory Asset Adequacy Issues Summary (§7) R101. It is the pre-Valuation-Manual instrument: for companies subject to the Valuation Manual its requirements are carried into VM-30, and VM-30 itself acknowledges the continuity — a guidance note states that appointment under #822 “qualifies as being in accordance with the Valuation Manual”, so an appointed actuary need not be re-appointed R100. Do not treat #822 as dead text: it remains the vehicle through which many states adopted asset adequacy analysis, and the state adoptions (R102) are what a company actually complies with where the Valuation Manual is not operative. The latest NAIC print located is April 2010, consistent with the model having been frozen once VM-30 took over.

  • Differences from VM-30 that matter to an implementer R100 R101: RAAIS due March 15 under #822 versus April 1 under VM-30; #822 uses “recommended language” while VM-30 uses prescribed wording plus a table of key indicators; #822 has no formal taxonomy of opinion outcomes while VM-30 defines adverse / qualified / inconclusive; VM-30 adds the IMR/AVR allocation rules, the equity-return-volatility requirement and seven-year retention, none of which #822 contains; #822’s memorandum-review mechanism survives in VM-30 §3.B.3.

R102. NAIC Model #822 State Page — Actuarial Opinion and Memorandum Regulation#

  • Publisher: NAIC Legal Division (print: “NAIC Model Laws, Regulations, Guidelines and Other Resources—Fall 2024”; © 2024; pages ST-822-1 to ST-822-7)

  • URL: https://content.naic.org/sites/default/files/model-law-state-page-822.pdf

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; key and state chart read)

  • Annotation: The state-by-state adoption chart for Model #822, and the cheapest public evidence that the model is still tracked. Two things an implementer needs from it: most listed state citations are annotated “does not include 2009 amendment” — many states’ AOMR predates the PBR-enabling amendments, which is exactly why VM-30 rather than #822 governs where the Valuation Manual is operative R102; and, decisive for scenario design, New York’s entry is “N.Y. COMP. CODES R. & REGS. tit. 11, §§ 95.1 to 95.12 (Regulation 126)” R102, so New York Regulation 126 is New York’s AOMR and the “New York seven” are a state requirement layered on top of VM-30, not a Valuation Manual requirement (R112). The chart carries an explicit disclaimer that it “does not reflect a determination as to whether a state meets any applicable accreditation standards” R102.

R110. VM-A: Appendix A — Requirements (Valuation Manual, Jan. 1, 2026 Edition)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf (pages A-1 to A-2; same document as R3)

  • Accessed: 2026-08-04

  • Fetched: yes (local text extraction; the complete two-page index read)

  • Annotation: The counterpart to VM-C (R41) and, like it, an index rather than a text: “Unless otherwise noted, this appendix references the following requirements from Appendix A of the AP&P Manual” R110. This is where the formulaic requirements the Valuation Manual still relies on are carried. The index as printed: A-200 separate accounts funding guaranteed minimum benefits under group contracts; A-235 interest-indexed annuities; A-250 variable annuities; A-255 modified guaranteed annuities; A-270 variable life; A-585 universal life; A-588 modified guaranteed life; A-620 accelerated benefits; A-641 long-term care; A-695 synthetic GICs; A-785 credit for reinsurance; A-791 life and health reinsurance agreements; A-812 smoker/nonsmoker mortality tables; VM-A-814 recognition of the 2001 CSO; A-815 preferred mortality tables; A-817 preneed life minimum standards; A-820 minimum life and annuity reserve standards; A-821 annuity mortality table; A-830 valuation of life insurance policies including new select mortality factors R110. Why an implementer must care: VM-20 §3.B.6 sends the NPR for the entire All Other reserving category — and for IUL policies where no DR or SR is computed — to “applicable methods in VM-A and VM-C for the basic reserve” R3, so a VM-20 engine cannot be built without also building a CRVM formulaic engine driven by A-820 and A-830. A-820 and A-830 as printed in the AP&P Manual were not retrieved for this library; the formulaic CRVM detail here comes from the Standard Valuation Law itself (R1) and Model #830 (R6) — see section 22.

16. The PBR topic page and the AP&P Manual formulaic texts (R150–R157)#

R150. NAIC — Principle-Based Reserving (insurance topic page)#

  • Publisher: National Association of Insurance Commissioners

  • URL: https://content.naic.org/insurance-topics/principle-based-reserving

  • Accessed: 2026-08-06

  • Fetched: yes (HTML topic page; the page itself shows “Last Updated: 8/1/2025”)

  • Annotation: The only source in this library that prints the PBR timeline dates, which the Standard Valuation Law (R1) and the Valuation Manual (R3) do not. Two statements are verbatim and are what this entry is cited for: “Effective Jan. 1, 2017, the Valuation Manual became operative.” and “PBR which became an accreditation standard Jan. 1, 2020.” It also states of VM-22 that the amendment “was adopted by LATF and is expected to be effective January 2026 with a three-year implementation period before becoming mandatory for all new issues in January 2029” — the only retrieved source giving the 2029 endpoint, which VM-22 itself (R36) leaves to arithmetic. Two things this page does NOT support, checked explicitly on fetch: it says nothing about a 2017–2019 elective transition during which a company could choose between the formulaic basis and VM-20, and it does not state when VM-20 became mandatory for new issues — the Jan. 1, 2020 date it gives is the accreditation standard, a requirement on states, which is not the same claim. Both remain unverified in this library. Note also the page’s vintage: the VM-22 sentence is forward-looking (“is expected to be”) as of an August 2025 update, so its 2026 and 2029 dates should be re-checked against the Valuation Manual (R36) before being relied on.

  • Numbering note: R143–R149 were left unused when the R125–R149 capital block was allocated; this entry takes R150 rather than back-filling a gap, keeping the never-reuse invariant visually obvious.

The AP&P Manual texts behind the formulaic index — read 2026-08-06 (R151–R157)#

R110 above indexes the formulaic requirements the Valuation Manual still relies on, and R41 does the same for the actuarial guidelines, but both are indexes rather than texts. Seven of the indexed items were read on 2026-08-06 out of the NAIC Accounting Practices and Procedures Manual, As of March 2026 — the same physical 2,117-page document as R73, and a free download, not the paid publication R33 recorded on 2026-08-03. They take appendix-level numbers rather than being folded into R73 so that a reserve or product document can cite A-820 ¶15 or AG 33 Text 4 instead of a 2,117-page manual.

What this supersedes, and what stays frozen. R39 and R40 record that the AG 33 and AG 35 texts could not be obtained; R110 closes with “A-820 and A-830 as printed in the AP&P Manual were not retrieved”. All three statements were accurate when written and are superseded in fact by R151–R157. Those entries are frozen and are preserved unaltered, exactly as R33 was preserved when R73 superseded it; the specific corrections the new texts make to R39 and R40 are recorded inside R151 and R152 rather than by editing R39 and R40.

Licence caution, inherited from R73 and applying to all of R151–R157. Personal and non-commercial use only; redistribution or integration “into any software or other publication” requires written NAIC permission R73. Product documentation must paraphrase the mechanics below and cite the paragraph, section or page, never paste the printed text.

Edition line, stated once for all seven. None of these items prints “As of March 2026” on its own pages. Every extracted page carries only the footer “© 1999-2026 National Association of Insurance Commissioners”, which is a copyright span, not an adoption, effective or revision date for any of these instruments — do not cite it as one. The “As of March 2026” designation is the manual’s own, carried in its front matter and recorded at R73.

R151. Actuarial Guideline XXXIII — Determining CARVM Reserves for Annuity Contracts With Elective Benefits (AG 33), as printed in AP&P Manual Appendix C#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Appendix C — Actuarial Guidelines, printed pages AG33-1 to AG33-8 = PDF pages 1496–1503 of the 2,117-page consolidated download; same physical document as R73. (The running heads confirm Appendix C; the Volume II placement is R73’s record, as the guideline’s own pages carry no volume statement.)

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; all eight printed pages read in full — Background Information, Purpose, Definitions, Text 1–7 and Effective Date)

  • Annotation: Applies to every annuity contract subject to CARVM “where any elective benefits … are available to the contract owner” — the trigger is the benefit, not the product, so a life-only SPIA with no elective option sits outside it — and it interprets CARVM rather than replacing it, expressly yielding to any product-specific guideline or regulation. The obligation it puts on a model is a per-benefit elective/non-elective flag followed by enumeration: one integrated benefit stream is a chosen set of elective incidence rates (leg A) plus the non-elective benefits computed on the contract state that elective path leaves behind (leg B), both discounted for survivorship on SVL-prescribed annuity mortality, and the reserve is the greatest present value over those streams — with cash-value streams accumulated at the guaranteed credited rate and discounted at the valuation rate, and annuitization streams driven by the guaranteed purchase rates applied to the accumulation fund, a value that may exceed the cash value and so needs its own state variable. Experience-based lapse, withdrawal and annuitization assumptions are prohibited on the elective side, where incidence is a decision variable maximised over trial sets between 0% and 100% (in practice usually 0% or 100%), while the non-elective side uses SVL-prescribed tables, falls back to company or industry experience “with margins for conservatism” where none is prescribed, and forces non-mortality waiver-type incidence to zero after the earlier of the first-premium surrender-charge period and cash-value depletion. Two structural facts a model must carry: SVL §4b parameters A, B and C are set at contract level but D (guarantee duration) and E (Plan Type) at benefit level, so the discount rate varies within one stream and, for annuitization, moves across guarantee-duration bands with the assumed election date; and where the contract guarantees future unknown (e.g. then-current) purchase rates, or additional amounts during the payout period, the reserve is floored at the accumulation fund less an expense allowance not exceeding 7% — a floor that binds on ordinary “better of guaranteed and current” MYGA and FIA language.

  • Corrections to R39, which is frozen and is not amended here. (i) The printed Effective Date block reads “effective on December 31, 1998, affecting all contracts issued on or after January 1, 1981”, against the December 31, 1995 date the fixed-deferred-annuity documents carry from IRS Rev. Rul. 2002-6 under a different title; the extracted pages carry no amendment history, so record both and do not silently swap. (ii) Nursing home benefits are non-elective — R39’s annotation lists “nursing-home waivers” in the elective set, but AG 33’s Definitions 1 places nursing home benefits expressly in the non-elective list. (iii) The phrase “efficient policyholder selection” does not appear in AG 33; the guideline’s own standard is the trial-set maximisation above, tempered by Text 7’s requirement that the actuary “consider, not necessarily test” all potential streams and its blessing of a “CARVM ignoring non-elective benefits plus an add-on reserve” decomposition as an approximation requiring demonstration. (iv) AG 33 names no other guideline anywhere — not AG 35, not AG 43 — so the AG 33/AG 35 pairing at R39/R40 stays inferential even though the general “product-specific guideline takes precedence” principle is now sourced.

  • What AG 33 does not supply. No algebra, no tables and no factors beyond the 7% allowance and the 1998–2000 phase-in percentages; no citation of SVL §5a by number (only §4b and §4b.C(1)(c)(vi), the latter reproduced nowhere); no restatement of the “end of each respective contract year” indexing or of the deduction of future valuation considerations, both of which stay with the statute (R1) and A-820 ¶15 (R153); and no mention of the Valuation Manual, VM-21 or VM-22.

R152. Actuarial Guideline XXXV — The Application of the Commissioners Annuity Reserve Method to Equity Indexed Annuities (AG 35), as printed in AP&P Manual Appendix C#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Appendix C — Actuarial Guidelines, printed pages AG35-1 to AG35-10 = PDF pages 1505–1514; same physical document as R73. (Appendix C confirmed from the running heads; Volume II per R73.)

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; all ten printed pages read in full, including Attachment 1 — the four computational methods, Attachment 2 — the “Hedged as Required” criteria, and the Attachment 3 and 4 certification forms)

  • Annotation: Scope is one sentence — “This Actuarial Guideline applies to all equity indexed annuity contracts, regardless of the date of issue, that are subject to CARVM” — making it a valuation-date requirement that reaches the whole in-force block, and its Background covers equity indexed immediate designs as well as deferred ones, which the library had never recorded. AG 35 does not perform the CARVM maximisation: every one of its four constructions ends with the same step 4, handing deterministic guaranteed benefit amounts to AG XXXIII (R151); its job is converting an unknown future index path into guaranteed benefit amounts at each duration. The four are CARVM with Updated Market Values (the market value of the option that exactly hedges each benefit floor, accumulated at the valuation rate to expiry and added to the floor, benefit by benefit), MVRM (solve for the end-of-term index level that reproduces guarantee-plus-accumulated option value, then project “assuming equal annual percentage increases in the index”), the Black-Scholes Projection Method (the one sanctioned MVRM adaptation, for annually redetermined designs — it accumulates the option cost at the risk-free rate, projects the account value first and inverts the crediting formula to back out the index), and EDIM (Type 1: a fixed component accreted from an initial reserve to the terminal benefit floor, plus an equity component measured at discounted intrinsic value only, no time value) — with variations from MVRM and EDIM declared unacceptable, and EDIM’s initial reserve required to be at least a CARVM-UMV or MVRM result, so a model cannot implement EDIM alone. Two directly implementable rules the library had nowhere: design features unique to equity indexed annuities may not be used to assign Plan Type, and “change in … asset values” in the Plan Type A/B definitions “does not include changes in policy values due to changes in the equity index”; and Type 1 use is gated on the Attachment 2 criteria, whose option-replication limb prescribes an at-least-weekly retrospective correlation test with 10% / 25% / 35% escalation thresholds against the beginning-of-period value of the embedded options, and a hedge-sizing floor of SP% = (1 − d)^n with d capped at 3% per year of elective decrements and n the length of the option guarantee (1 year for an annual-ratchet design).

  • Corrections to R40, which is frozen and is not amended here. (i) “Type 1” and “Type 2” are the guideline’s own printed section headings and defined terms, not “industry shorthand”. (ii) R40’s asset-adequacy claim is conditional in the printed text: AG 35 says only that “[t]o the extent required by law, regulation, or regulatory requirements, reserves established for equity indexed annuity policies must be tested for adequacy using appropriate methods and assumptions” — it presupposes the obligation rather than creating it, so the binding authority for FIA asset adequacy testing is the Standard Valuation Law and VM-30 R1 R100, with AG 35 as corroboration. The modelling conclusion R40 draws from it — that an FIA block cannot rely on the formulaic reserve alone and one cash flow model must serve CARVM and ASOP 22 (R29) — survives intact; only its authority moves. (iii) AG 35 prints no effective, adoption or operative date, no transition, no grandfathering and no sunset; the only temporal language in the document is “regardless of the date of issue”. (iv) It supersedes the valuation guidance in Sections 5 and 6 of the NAIC Interest-Indexed Annuity Contracts Model Regulation, an instrument not otherwise in this library and recorded here as a cross-reference only.

  • What AG 35 leaves open. It defines no term “equity indexed annuity”, never mentions separate accounts, registered products, buffers, floors, AG 54 or the Valuation Manual, so it neither includes nor excludes a RILA: the RILA caveat narrows from “AG 35 was not retrieved” to “AG 35 was read and does not address this design”. It prescribes no volatility, dividend yield, risk-free curve or option pricing model — assumption discipline runs through appointed-actuary certification (Attachments 3 and 4, filed with each quarterly and annual statement) rather than prescription. And it points the valuation interest rate at “Actuarial Guideline XXXIII or Actuarial Guideline IX-B” three times: AG IX-B has not been read and is indexed only through VM-C (R41), so an FIA CARVM run has an unresolved cross-reference.

R153. Appendix A-820 — Minimum Life and Annuity Reserve Standards (with Appendix A-821, Annuity Mortality Table for Use in Determining Reserve Liabilities for Annuities, and Appendix A-822, Asset Adequacy Analysis Requirements)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; A-820 printed pages A820-1 to A820-13 = PDF pages 1186–1198, A-821 printed A821-1 to A821-6 = PDF pages 1199–1204, A-822 printed A822-1 = PDF page 1205; same physical document as R73.

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; A-820 ¶¶1–28 read in full, A-821 read in full including the 2012 IAM Period Table and Projection Scale G2, A-822’s four paragraphs read in full)

  • Annotation: The codified Standard Valuation Law as the manual prints it, and the library’s first-hand source for both formulaic engines: CRVM at ¶¶11–13 — modified net premiums as “the uniform percentage of the respective contract premiums”, an expense allowance of a over b with a capped at the nineteen-year premium whole life net level annual premium at age x+1, the reserve taken as “the excess, if any” and so floored at zero, and ¶13 extending the same principles to varying-benefit and varying-premium designs (which is what makes CRVM reach universal life at all) — and CARVM at ¶¶14–15, the greatest of the excesses, at the end of each respective contract year, of the guaranteed benefits including guaranteed nonforfeiture benefits over the future valuation considerations payable before that year end, with the guaranteed benefits projected on the contractual mortality and interest basis and the valuation basis entering only through the discounting. ¶¶7–10 carry the entire valuation-interest-rate machinery an implementer should hold as configuration rather than code — the life formula `I = .03 + W(R1 − .03)

    • (W/2)(R2 − .09)and the annuity formulaI = .03 + W(R − .03)`, the routing rules that decide which applies, life weighting factors .50/.45/.35, the Plan Type A/B/C issue-year table, change-in- fund increments +.15/+.25/+.05 and the further +.05 where interest is not guaranteed on later considerations, Moody’s composite yield on seasoned corporate bonds as the reference rate R with an express NAIC-alternative provision if Moody’s stops publishing, the half-of-1% life stability rule and rounding to the nearer quarter of 1% — together with ¶8.c.vi’s rule that the issue-year versus change-in-fund basis is a per-contract election made at issue, that contracts with no cash settlement options must use issue year, and that a change-in-fund valuation rate is a per-layer attribute keyed to the year each increment of fund arose, not a per-contract scalar. ¶¶19–20 give the deficiency-reserve construction as a floor on the policy reserve rather than a separate quantity: where the gross premium in any contract year falls below the valuation net premium computed by the method actually used but on the minimum mortality and interest standards, hold the greater of the reserve as actually computed and a re-run on those minimum standards with the actual gross premium substituted only in the deficient years. Scope splits at ¶¶3–4 — ¶¶5–22 govern contracts issued before the January 1, 2017 operative date of the Valuation Manual and ¶¶23–27 those issued on or after, with ¶24.a still requiring the Valuation Manual to specify CRVM for life and CARVM for annuities, ¶24.d.i allowing the non-PBR standard simply to be “consistent with the minimum standard of valuation prior to the operative date”, and ¶27 confirming in one sentence that “[a] principle-based valuation may include a prescribed formulaic reserve component” — which is A-820’s own account of why a CRVM engine is still required equipment in

  • A-821 and A-822, printed alongside A-820 and covered by this same entry. A-821 recognizes four annuity valuation tables and prints their application rules: Annuity 2000 for individual annuity and pure endowment contracts issued 1/1/2001 through 12/31/2014; the 2012 IAR generational table for issues on or after 1/1/2015, built as q_x^(2012+n) = q_x^2012 · (1 − G2_x)^n with the rounding to three decimals per 1,000 taken from the 2012 period rate every time and never from an already-rounded prior year (the guideline prints the wrong method explicitly, to rule it out); 1983 Table “a” without projection for the structured-settlement carve-out (tort and workers’ compensation settlements, and long-term disability claims commuted into an annuity); and the 1994 GAR for annuities purchased under a group annuity or pure endowment contract, with no effective date printed for that last rule. The 2012 IAM Period Table and Projection Scale G2 are printed in full, and the two sexes’ improvement scales differ — do not share one array. A-822 is four paragraphs and nothing else: it defines asset adequacy analysis, requires reserves considered with the assets supporting them to make adequate provision “according to presently accepted actuarial standards of practice”, requires the additional reserve where the analysis says one is needed, and provides that releasing it “would not be deemed an adoption of a lower standard of valuation” — which, read with A-820 ¶18’s mirror proviso, keeps the asset-adequacy additional reserve outside change-in-valuation-basis accounting in both directions.

  • Naming trap, and a header asymmetry worth knowing. AP&P Appendix A-822 is an excerpt of the Standard Valuation Law’s asset adequacy provisions and is not NAIC Model #822, the Actuarial Opinion and Memorandum Regulation carried at R101 — same number, different instrument. Note also that A-820, which is the codified SVL, does not list Model #820 in its own “Relevant NAIC Model Laws/Regulations” header; A-822 is the item that names Model #820.

  • Supersession and one upgrade. R110’s closing statement that “A-820 and A-830 as printed in the AP&P Manual were not retrieved” is superseded in fact by this entry and R154; R110 is frozen and is not amended. Separately, the January 1, 2017 operative date of the Valuation Manual is printed twice in operative text here (¶3 and ¶4), which makes R153 a materially stronger citation than the NAIC topic page (R150) that had been the library’s only source for it.

  • Two printed ambiguities, recorded and not resolved. ¶12’s 15% reduction is expressed with a singular/plural mismatch (“that paragraph” / “those paragraphs”) that is a renumbering artefact of the model law, under which the reduction attaches specifically to the net level annual premium; A-820 as printed does not disambiguate it. And ¶22 posits an A&H window “on or after January 1, 2017, and prior to the operative date of the Valuation Manual” while ¶¶3–4 fix that operative date at January 1, 2017, leaving the window empty.

R154. Appendix A-830 — Valuation of Life Insurance Policies (Including the Introduction and Use of New Select Mortality Factors)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws, printed pages A830-1 to A830-27 = PDF pages 1206–1232; operative text A830-1 to A830-14 (PDF 1206–1219), the Attachment’s heading and explanatory note at A830-15 (PDF 1220), and the six select-mortality-factor tables at A830-16 to A830-27 (PDF 1221–1232). Same physical document as R73.

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; ¶¶1–32 and the Attachment read in full, all six factor tables transcribed)

  • Annotation: The instrument the library calls Model #830 / Regulation XXX, as the manual prints it, and ¶2 makes its own construction “the Commissioners’ Reserve Valuation Method for policies to which this appendix is applicable” — the printed scope is all life insurance policies subject to six exceptions, not “term and ULSG”. The engine is the contract segmentation method at ¶5: a segment ends at the smallest t for which G(t) = GP(x+k+t)/GP(x+k+t−1) exceeds R(t) = q(x+k+t)/q(x+k+t−1), with t reset to 1 at each segment start, R(t) movable by ±1% per policy year at the company’s option but never below 1, and printed conventions that force G = 1000 where a premium restarts after a zero-premium year and G = 0 while premiums are zero (so zero-premium years never break a segment); basic reserves for nonlevel non-UL policies are then the greater of the segmented and the unitary reserve (¶21), where the segmented version scopes the CRVM expense allowance to the first segment while the unitary version runs it to mandatory expiration, and present values inside a segmented calculation cover “the current segment and all subsequent segments” (¶11.d). Deficiency reserves are not “valuation net premium over gross”: ¶17 defines quantity A as a full re-run of the basic reserve with the guaranteed gross premium substituted for the net premium only in the durations where the gross is the smaller, the deficiency being A less the basic reserve, computed on whichever basis won the ¶21 maximum with ties broken toward segmented (¶22.a) and on segment lengths taken from the basic-reserve segmentation, not re-derived (¶22.d); the X-factor relief at ¶17.c is a two-limb test — an aggregate present-value limb and a year-by-year floor over the first five years after the valuation date — select factors may be used only in the first segment (¶18, with a ten-year carve-back), and X below 100 at any duration triggers an annual A-822 asset adequacy opinion and memorandum, a Regulatory Asset Adequacy Issues Summary disclosure, and a supporting actuarial report. For ULSG the whole construction is ¶¶29–32: set gross premiums equal to the specified premiums, or failing those the minimum premiums, run the ¶5 segmentation on them, take segmented reserves only for the secondary guarantee period — there is no unitary leg — value each unexpired secondary guarantee stand-alone and take the greatest, add the ¶31 deficiency reserve, and floor the result at “the minimum reserves required by other appendices governing universal life plans” (an unnamed cross-reference; do not resolve it to A-585 on this text).

  • Citation form — this changes existing cites. The appendix is a flat sequence of paragraphs 1–32 plus an unnumbered Attachment. It has no Sections, so a citation of the form “Model #830 Section 7”, which this library uses for the secondary-guarantee rules, does not resolve against this print; the corresponding material is at ¶¶29–32. Cite as [REG-R154 ¶N], adding the PDF page where a reader would need it. Note also that the words “Model #830” and “Regulation XXX” appear nowhere in the appendix, and its “Relevant NAIC Model Laws/Regulations” header names the Standard Valuation Law (#820) and the Actuarial Opinion and Memorandum Regulation (#822) — not Model #830 itself, not the Standard Nonforfeiture Law and not AG 38.

  • Dates, and why a model needs two branches. The appendix nowhere prints a calendar effective date for itself — every applicability sentence uses “the effective date of this appendix” as an unresolved placeholder, and there is no effective-date, authority or severability paragraph. The only calendar dates in the whole appendix are January 1, 2004, all marking the same cutover from the 1980 CSO basis (with elective select mortality factors) to the 2001 CSO Table, and the pre-2004 text is retained in full rather than deleted, so a model valuing pre-2004 issues needs that branch and a model valuing later issues needs only the 2001 CSO branch. Three further applicability mechanics an in-force model must carry: the reentry carve-out propagates down chains of policies descending from a pre-effective-date original (¶3.a.i), so the applicability flag is inherited at issue rather than derived from the issue date; the attained-age-based YRT exemption is an all-or-nothing company-level election (¶26.g); and guarantees the insurer adds unilaterally after issue take a triple maximum — ignoring the guarantee, assuming it was made at issue, and assuming the policy was issued on the date of the guarantee (¶20).

R155. Appendix A-585 — Universal Life Insurance#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws, printed pages A585-1 to A585-4 = PDF pages 1102–1105; same physical document as R73.

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; ¶¶1–13 read in full, with the three printed footnotes)

  • Annotation: The universal life adaptation of CRVM, and it is a different engine from the modified-net-premium construction the library’s formulaic notes carry: the terminal reserve for the basic policy and any riders not separately premium-rated is V(t) = ((A) − (B))·r − (C) − (D), where (A) is the present value of all future guaranteed benefits at the valuation date, (B) is (PVFB/ä_x)·ä_{x+t} with PVFB fixed at issue on the assumption that future guaranteed maturity premiums are paid, (C) is the expense allowance ((a) − (b))·(ä_{x+t}/ä_x)·r whose (a) − (b) is delegated to “paragraph 9 of Appendix A-820” — a printed pointer that does not resolve against R153; see the caveats below — and (D) accumulates analogous quantities arising from structural changes. Three objects a UL model must build that the library’s formulaic section did not define: the guaranteed maturity premium — a solve for the level gross premium, payable over the allowed premium-paying period, that matures the policy at the latest permitted maturity date (or the highest age in the valuation mortality table), computed on guarantees at issue excluding guarantees linked to an external referent, which is the item’s only index-specific rule and sends indexed UL’s crediting out of the GMP solve entirely, and adjusted for death-benefit corridors; the guaranteed maturity fund path implied by it; and the ratio r, which is 1 unconditionally for a fixed premium policy and min(1, policy value / GMF) only for a flexible premium one. The projection rule at ¶8.i is the design logic that pairs with r: future guaranteed benefits are projected on the greater of the guaranteed maturity fund and the policy value, so an underfunded flexible-premium contract is valued as though fully funded and the resulting net level premium reserve is then scaled down by r. Note finally the Alternative Minimum Reserve at ¶¶12–13, which is not a deficiency reserve: its comparator is the guaranteed maturity premium against the valuation net premium (PVFB/ä_x on a net level basis, PVFB/ä_x + ((a)−(b))/ä_x on a CRVM basis), and the remedy is the greater of the reserve as actually computed and a re-run on minimum mortality and interest with the GMP substituted for the valuation net premium in each policy year where the latter is larger.

  • Caveats. A-585 prints no effective date, operative date, transition or grandfathering language and no numbers at all — every mortality table and interest rate is delegated to A-820 “for policies issued in the same year” (¶¶8.j, 10) — so its temporal reach comes entirely from outside the item and must not be inferred from it. It also does not cite Model #585: its “Relevant NAIC Model Laws/Regulations” header names only the Standard Valuation Law (#820), so statements of the form “A-585 is Model #585 §5” should be softened, and UL nonforfeiture, the mandatory policy provisions and the interest-indexed UL filing requirements are not in this appendix — those remain Model #585 (R5). The item is also silent on VM-20, VM-A and PBR; the routing that makes it matter to a post-operative-date net premium reserve is asserted by VM-20 §3.B.6 and VM-A (R3)(R110), not here. The ¶8.f pointer to “paragraph 9 of Appendix A-820” does not resolve against the A-820 print read at R153, where ¶9 is the reference-interest-rate paragraph; the quantities labelled a. and b. sit at A-820 ¶11.a and ¶11.b. That identification is structural, not textual — it is what (a) − (b) must be for the A-585 reserve to be a CRVM reserve — and it is recorded here as an unresolved pointer rather than silently repaired. One extraction artefact to respect: the PDF text layer loses fraction bars, so the placement of r inside (C) is read from layout rather than from a bar character — re-open PDF p. 1103 before hard-coding it.

R156. Appendix A-250 — Variable Annuities#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws, printed page A250-1 = PDF page 1095; same physical document as R73. (The extraction quotes a two-line printed title block for A-585 only; for this item the title is as carried in the appendix listing and the extraction’s heading.)

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; the whole item — three paragraphs on one printed page — read in full)

  • Annotation: One printed page and three paragraphs, and the finding an implementer needs is negative: A-250 is a pointer, not a reserve method. ¶1 defines a variable annuity as a policy or contract, individual or group, providing annuity benefits that vary with the investment experience of a separate account; ¶2 requires the insurer to maintain in each such separate account “assets with a value at least equal to the reserves and other contract liabilities with respect to the account”; and ¶3 sends the reserve itself to Appendix A-820 (R153), “in accordance with actuarial procedures that recognize the variable nature of the benefits provided and any mortality guarantees”. It contains no formula, symbol, factor or table, no CARVM adaptation, no elective-path enumeration rule and no interim-value rule — the word CARVM does not appear — so nothing in it changes a variable-annuity or RILA formulaic run beyond the separate-account asset-coverage floor. (All three paragraphs sit under the heading “Definitions”; unlike A-255 and A-270 the item has no “Valuation Requirements” heading, which does not change ¶3’s effect.)

R157. Appendix A-255 — Modified Guaranteed Annuities#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws, printed page A255-1 = PDF page 1096; same physical document as R73. (Title as carried in the appendix listing and the extraction’s heading; see the note at R156.)

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; the whole item — seven paragraphs on one printed page — read in full)

  • Annotation: Like A-250 this is a pointer to A-820 (R153) for the reserve method — ¶4, in procedures recognising that separate account assets are at market value, the variable nature of the benefits, and any mortality guarantees — but it adds three operative rules a model can use. ¶5 floors the separate account liability at the surrender value produced by the market-value adjustment formula contained in the contract (A-255 prescribes no MVA formula and no parameters for one), requires a transfer of assets into the separate account wherever that liability exceeds the market value of the assets held, and requires that “[a]ny additional reserve that is needed to cover future guaranteed benefits shall be established”; ¶6 requires the MVA formula, the interest guarantees and the degree of asset/liability cash-flow matching to be considered, with an affirmative company determination that the separate account assets are adequate for all guaranteed benefits; ¶7 repeats the asset-coverage floor. ¶1’s definition is separately load-bearing: it is the test applied when VM-21 §2.A.2 excludes contracts falling under VM-A item A-255 (R35), and its elements are a deferred annuity, individual or group, with underlying assets held in a separate account, values guaranteed if held for specified periods, nonforfeiture values on an MVA formula for shorter holdings, and the assets in the separate account throughout any period in which the holder can surrender. Like A-250, it prints no formula, symbol, factor or table and never mentions CARVM.

  • What R156 and R157 together close. The open question recorded in the RILA technical notes — whether A-250 and A-255, described there as “the VM-A index’s two closest formulaic items”, would change a RILA formulaic run once read — is now answered: they would not. A RILA CARVM run still rests on the Standard Valuation Law text (R1) and, where elective benefits are present, on AG 33 (R151); A-255’s MVA-surrender-value floor and the two asset-coverage floors are the only additions. Calling them “the closest formulaic items” is defensible only as nearest by subject matter.

  • Related item read but not numbered. A-270 (variable life insurance, printed A270-1 to A270-3 = PDF pages 1097–1099) was read in the same extraction and carries the one genuine reserve mechanic in this group — the ¶16 guaranteed-minimum-death-benefit reserve, a maximum of a one-year term-cost floor computed after “an immediate one-third depreciation in the current value of the assets in the separate account” and an “attained age level” reserve recursion. No reference id has been allocated to A-270, so nothing from it may be cited from a product file until one is; see section 22.

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