Comments on the NAIC Annuity Illustrations Exposure

The Annuity Products Subcommittee of the American Academy of Actuaries offered high-level comments to the NAIC Life Insurance and Annuity Illustration Working Group in response to its Sept. 15, 2026, request for comment, with the shared goal of helping provide appropriate and helpful information to consumers. The letter addresses the scope of the revisions, illustration length, the Disclosure Document, and what standardized and supplemental illustrations might include. It also covers a signed attestation by a company officer, illustrating indices that lack sufficient historical data, and concerns about relying on or adjusting non-guaranteed elements. Other topics include supplemental charts for consumers and additional items for the Model 245 revisions, such as rebalancing between strategies and market value adjustments.