AAA NAIC LATF Comment Letter: AG 55 Guidance Document

The American Academy of Actuaries’ Life Valuation Committee generally supports the NAIC’s proposed year-end 2026 AG 55 disclosure requirements for offshore reinsurance but recommends also addressing items such as cliff risk associated with complex assets. The letter argues that risk-based capital information belongs in RBC reporting—not AG 55—and raises concerns that the proposed product-level self-support demonstration for multi-year guaranteed annuities is inconsistent with asset adequacy testing and relies on an ambiguous definition of the “richest guarantee.