As we reported in the prior issue, the National Association of Insurance Commissioners ("NAIC") Valuation of Securities (E) Task Force ("Task Force") would be considering the recommendation from the Director of the NAIC Securities Valuation Office ("SVO") to require principal protected structured notes that are purchased by insurance companies to be submitted to the SVO for analysis.  The SVO's recommendation included the text of a proposed amendment to the Purposes and Procedures Manual of the NAIC Investment Analysis Office ("P&P Manual") to clarify that the existing filing exemption does not apply to such principal protected notes.  Since then, two updates have occurred:

  • The comment period for the proposed amendment to the P&P Manual is now open, and will close on September 20, 2019; and
  • On August 4, 2019, the Task Force adopted an amendment to the P&P Manual providing that "structured notes" are not within the filing exemption with the SVO but must be filed for review by  the SVO.1

We will continue to monitor and report on these activities.


1 The proposed amendment to the P&P Manual and the recently adopted amendment are both available at:

Originally published in REVERSEinquiries: Volume 2, Issue 8.
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