Hot Topic | April 2020



SAPWG adopts LIBOR and COVID-19 guidance

Adopted interpretations include accounting relief in response to COVID-19 and adoption of FASB LIBOR guidance.

Jennifer Austin

Jennifer Austin

Partner, Dept. of Professional Practice, KPMG US

1 212-872-2946

Alan Goad

Alan Goad

Partner, Dept. of Professional Practice, KPMG US

+1 212-872-3340

Olga Roberts

Olga Roberts

Managing Director, Dept. of Professional Practice, KPMG US

+1 212-909-5015

The Statutory Accounting Principles Working Group has adopted an INT adopting FASB LIBOR guidance and three INTs in response to the COVID-19 outbreak.


  • All insurance companies preparing financial statements in accordance with statutory accounting principles

Relevant dates

  • INTs adopted April 15, 2020
  • Effective immediately

Report contents

  • INT 20-01 adopts, with modification, FASB guidance for transitioning from LIBOR. It gives waivers from derecognizing hedging transactions and some exceptions for assessing hedge effectiveness as a result of transitioning from LIBOR. This INT sunset provision mirrors the US GAAP guidance.
  • INT 20-02, which applies to financial reporting for Q1 and Q2 2020, allows an optional extension of the 90-day rule for the following amounts due that were current prior to March 13, 2020 and for policies written or renewed on or after March 13: 
    • Uncollected premium balances, bills receivable for premiums and amounts due from agents and policyholders (SSAP No. 6) 
    • Life premiums due and uncollected (SSAP No. 51R) 
    • Amounts due from non-government uninsured plans (SSAP No. 47)
    • Amounts due from policyholders for high deductible policies (SSAP No. 65). 
  • INT 20-03 adopts the guidance from the CARES Act and the April 7, 2020 joint statement of the federal and state banking regulators on the approach to accounting for certain loan modifications in response to COVID-19.
  • INT 20-04, which applies to financial reporting for Q1 and Q2 2020, provides limited time exceptions to defer impairment assessments for bank loans, mortgage loans, and investments that predominantly hold underlying mortgage loans that are affected by forbearance or modifications in response to COVID-19.

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