In May 2018, the NAIC Statutory Accounting Principles (E) Working Group continued its deliberations on the regulatory treatment of Private Placement Life Insurance (PPLI) and Private Placement Variable Annuities (PPVA) products owned by insurers. Under the 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: 1) The policies must comply with IRC §7702; and 2) The owner of the policy must not be subject to investment risk (meaning the net realizable value does not change as a result of market fluctuations). MBSA submitted a comment letter to the NAIC recommending a more comprehensive review of ICOLI as an asset class owned by insurers. We drew several references to bank regulatory guidance and ultimately recommended that the NAIC evaluate both the risk-based capital framework as well as whether or not the products qualify as admitted or non-admitted assets for statutory accounting purposes.