The NAIC posted new guidance this afternoon for implementing the provisions of SSAP 101 in the 2012 Quarterly Statements Note 9A. The document is available for download from the Blanks Working Group website and should serve as your guide in completing the Note 9A data entry piece and printed disclosures. Review the Guidance document before completing your Notes disclosures and you should be able to match up the printed disclosures with the data entry piece.

I did notice that Note 9.A.1. was not addressed in the document and is one of the significant differences between SSAP 10R and SSAP 101. To match up your data entry disclosures with the SSAP 101 disclosures on your printed Notes page complete Note 9A1A through 9A1G per the table below. Basically, you need to flip DTA Nonadmitted with Deferred Tax Liabilities. Remember that the Prior Year amounts will also need to be flipped.

A Dilemma of fitting a Square Peg in a Round Hole?

How are you to report the Note 9A DTA/DTL disclosures adopted in SSAP 101, which are effective beginning January 1. 2012, when the NAIC 2012 Quarterly Statement data capture table for Note 9A has not been updated but instead is the same table as the 2011 Annual Statement used for SSAP 10R reporting? Put another way, if SSAP 101 is a replacement of SSAPs 10R and 10, then should the Note 9A data capture table be replaced as well? This is certainly a dilemma for preparers of the Quarterly Statement as they wrestle with finding a solution to this irregularity in their 2012 Quarterly Filing.

The NAIC has adopted 2012 Annual Statement Instruction revisions to Note 9A occasioned by the replacement of SSAP of 10R with SSAP 101 but that is of little solace to Quarterly Statement preparers faced with the prospect of implementing SSAP 101 disclosures in their PDF hardcopy and SSAP 10R disclosures in their NAIC Filing data tables. Maintaining two sets of books as it were, is not an attractive alternative. Attempting to monkey wrench SSAP 101 disclosures into the data capture tables proves an unyielding exercise akin to the proverbial exercise of fitting a square peg in a round hole.

With the NAIC 2011 March Annual Statement Filing behind us and the April Filing winding down we can turn our focus to the 2012 Quarterly Statement. Although the revisions to the Quarterly Statement are limited this year, and have a relatively minor impact, some revisions intended to be addressed in this release fell through the cracks and will have to wait until the 2013 Quarterly Statement for implementation.  Unfortunately, circumstances are such that it is not uncommon for the final release of the NAIC Annual or Quarterly Statements to not agree with the items adopted effective with that particular release of the Statement.  

These inconsistencies can generate confusion which we can dampen by knowing the NAIC’s intention to correct the inconsistency in a subsequent filing period.  The following list of issues is minor in nature in light of the fact the NAIC adopted the revisions effective for this period albeit the corresponding Blank or Instruction change was missed.   

• For General Interrogatory Part 1, due to an NAIC oversight, the following instruction on the Blank for Interrogatory 3 was not removed, "If yes, complete the Schedule Y - Part 1 - Organizational Chart". Beginning with the 2012 Quarterly Statement Schedule Y - Part 1A should be completed and the organizational chart attached each Quarterly Statement Filing regardless of whether there have been any substantial changes.