Comments on the VM-22 Inforce Exposure

In this comment letter, the Annuity Reserves and Capital Subcommittee suggests a structured, optional path for retrospective adoption of VM-22 for certain in-force non-variable annuity business, with an emphasis on regulatory transparency, meaningful review, and appropriate safeguards. The Subcommittee recommended a new Section 14 within VM-22 along with conforming amendments and proposed a framework that would allow companies to elect retrospective adoption under defined conditions while providing regulators with supporting analysis and documentation. The Subcommittee also addresses reserve impact analysis, aggregation considerations, starting assets and asset allocation, reinsurance implications, and documentation and ongoing reporting expectations associated with the election.