On May 22 the House passed the wide-ranging financial regulatory bill called the Economic Growth, Regulatory Relief, and Consumer Protection Act. This version of the legislation is unchanged compared to the bill that was passed by the Senate (S. 2155) on March 15. President Trump signed the bill into law on May 24.
As we have reported previously, the bill includes these noteworthy provisions:
On May 30 the Federal Reserve Board issued a press release requesting comment on proposed revisions to requirements relating to the Volcker rule. The proposed changes were jointly developed by the Federal Reserve Board, CFTC, FDIC, OCC, and the SEC, and include these changes:
The proposed revisions do not appear to impact the treatment or regulatory exemption applicable to separate account BOLI under the existing Volcker Rule regulations.
The comment period will be 60 days following publication in the Federal Register.
As a follow up to last month’s update, on May 14 the Social Security Administration (SSA) announced its schedule for release of additional death records to the publicly available Limited Access Death Master File (LADMF) during 2018. The records are for deaths currently maintained in SSA records that the SSA determined should be included in the LADMF. Two sets of records, totaling approximately 3 million records, were added in April. The additional 5 million records will be added according to the following schedule:
It is our understanding that the additional records are for deaths that were previously unreported due to missing or illegible information in the original paperwork. We also understand that the first set of 1 million records added had dates of death spanning from 1937 to 1976.
As you may recall, since November 1, 2011 the SSA has not included death records received through contracts with the states in the LADMF. It is unclear if any of the additional 8 million records will include records that may have been incorrectly excluded as being state reported records.
During a meeting held on May 24, the NAIC Statutory Accounting Principles (E) Working Group recommended the adoption of the previously exposed revisions to SSAP No. 56. This change will require insurers to separately disclose total separate account assets between products that are registered with the SEC and those that are not registered (i.e., “private placements). The change will also add a new disclosure table for non-registered policies, categorizing the amounts as 1) Private Placement Variable Annuity; 2) Private Placement Life Insurance; and 3) Other.
Separately, the NAIC staff exposed new proposed revisions to SSAP No. 21. Under this exposure, insurers that own ICOLI policies would need to meet two requirements in order to continue the current practice of recognizing the values fully as admitted assets. The two requirements proposed are
The exposure is open for public comment through June 22. Full details and a summary of previously received comment letters were included in the meeting materials.
As we previously noted, this topic is primarily of interest to insurers and agents. It does not directly impact BOLI owners.