Comments Due By August 22 on National Association of Insurance Commissioners Reinsurance Task Force Revisions to XXX/AXXX Credit for Reinsurance Model Regulation

The National Association of Insurance Commissioners’ (“NAIC”) Reinsurance Task Force has advised that public comments are due by August 22, 2016 on a draft of recent revisions to the XXX/AXXX Credit for Reinsurance Model Regulation.  This comment deadline was established to allow for discussion of any comments received at the upcoming 2016 Summer National Meeting.

The following revisions were made: 

• Removed recapture as a remediation option in Section 7(B)(2).
• Added a drafting note in Section 7 pertaining to commissioner discretion in relation to the Model Regulation’s consequence option and remediation provisions.
• Removed references to “before the operative date of the valuation manual” as well as the associated definition and drafting note.  This language is expected to be obsolete by the time the Model Regulation is adopted in any state. 
• Changed references to reinsurance “contracts,” “arrangements” and “treaties” to “treaties” throughout the Model Regulation.
• Removed the drafting note that followed Section 6(A)(1) and 6(A)(2).  This language is expected to be obsolete by the time the Model Regulation is adopted in any state. 
• Revised Section 6(A)(1) to address the comments provided by New York Life and Northwestern Mutual on the Model Regulation’s “synchronization with the Valuation Manual.”
• Revisions to Section 4(A) and Section 6 to reflect recommendations provided by the LATF Drafting Group. 

Hyperlinks to the draft, a redline and the NAIC Staff Memorandum detailing the revisions are below:

XXX/AXXX Credit for Reinsurance Model Regulation Draft (August 2016 Draft)

XXX/AXXX Credit for Reinsurance Model Regulation Draft (August 2016 Draft-Redlined)

NAIC Staff Memorandum on Revisions to the XXX/AXXX Credit for Reinsurance Model Regulation Draft

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