The Reinsurance Working Group submitted comments to the NAIC Statutory Accounting Principles (E) Working Group on the SAPWG 2025‑22 exposure draft regarding IMR impacts on reinsurance collateral. The letter stresses aligning collateral requirements with the economics of reinsurance while protecting policyholders and proposes allowing limited use of negative IMR—supported by actuarial analysis—to ensure collateral remains sufficient under moderately adverse conditions.