Issues & Trends | July 2020



NAIC accounting calls

KPMG reports on the latest accounting actions taken on conference calls by the National Association of Insurance Commissioners.

Alan Goad

Alan Goad

Partner, Dept. of Professional Practice, KPMG US

+1 212-872-3340

Jennifer Austin

Jennifer Austin

Partner, Dept. of Professional Practice, KPMG US

1 212-872-2946

Olga Roberts

Olga Roberts

Managing Director, Dept. of Professional Practice, KPMG US

+1 212-909-5015


  • All insurance companies

Relevant dates

  • Effective immediately, unless otherwise indicated

Key impacts

The Statutory Accounting Principles Working Group (SAPWG) adopted the following guidance:

  • SSAP No. 2R to clarify the types of cash pooling structures and the investments required to be maintained in those structures for the cash pools to qualify as other cash equivalents. 
  • SSAP Nos. 2R and 103R to provide a principle about when related party or affiliated investments, other than qualifying cash pooling structures, can be classified as cash equivalents or short-term investments, and to add disclosures.
  • SSAP No. 26R to clarify that after a modification under SSAP Nos. 36 or 103R, future assessments of other-than-temporary impairment (OTTI) are based on the post-modification contractual terms of the debt instrument.
  • INT 20-05 to provide an exception to the collectability and nonadmittance guidance in SSAP No. 34 for investment income due and accrued for certain financial instruments modified in response to COVID-19. It also provides guidance on how investment income is recognized when a payment holiday is given and investment income is not accrued.
  • INT 20-07 to provide certain practical expedients in assessing whether modifications to debt instruments in response to COVID-19 are insignificant under SSAP No. 36 and whether a change is substantive under SSAP No. 103R.
  • INT 20-08 stating that premium refunds issued in response to COVID-19 that are not required under policy terms are recorded as a reduction of premium (rather than expense). It also provides guidance about how to account for refunds required under policy terms, rate reduction on inforce and renewal business, and policyholder dividends. It requires an aggregate disclosure of all items related to COVID-19 addressed in INT 20-08. Although SAPWG’s parent committee, the AP&P Task Force, also adopted the INT, the AP&P Task Force’s parent committee did not and sent it back for further discussions. The AP&P Task Force scheduled a call on July 22, 2020 to further discuss the INT.

Subscribe to our newsletter

Receive timely updates on accounting and financial reporting topics from KPMG.


Use our Accounting Research Online for financial reporting resources.