Comments on the Exposure Draft of SSAP No. 109—Asset Liability Management (ALM) Derivatives

The Academy’s Life Investment Analysis Subcommittee submitted the comments to the Life Actuarial (A) Task Force in response to an Oct. 1, 2026, presentation by the chair of the NAIC Statutory Accounting Principles (E) Working Group on the exposure draft and the related draft Statutory Issue Paper 1XX. The letter addresses the interest rate sensitivity metrics used to test hedge effectiveness, how the hedge effectiveness tests are structured, and the treatment of option-based hedges. It also covers the amortization period for deferred derivative gains and losses and the treatment of block reinsurance transactions.