NAIC Exposes INT 23-01T — Net Negative (Disallowed) Interest Maintenance Reserve (IMR) for Public Comment

On July 5, 2023, the Statutory Accounting Principles (E) Working Group (“SAPWG”) of the National Association of Insurance Commissioners (the “NAIC”) exposed INT 23-01T — Net Negative (Disallowed) Interest Maintenance Reserve (IMR) (“INT 23-01T”) for a public comment period ending Friday, July 21. The exposure follows SAPWG’s June 28 discussion of comments received on a prior exposure of the same and is expected to be considered for possible adoption at the upcoming 2023 NAIC Summer National Meeting in August 2023 (the “Summer National Meeting”).

We previously reported on SAPWG’s new agenda item relating to statutory accounting treatment for negative interest maintenance reserve (“IMR”) in our reports of the 2022 NAIC Fall National Meeting and 2023 NAIC Spring National Meeting, available here and here, respectively, and provide below a brief background on the issue and an update on the NAIC’s current exposure.

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