Ref #2015-38
Statutory Accounting Principles (E) Working Group
Maintenance Agenda Submission Form
Form A
Issue: ASU 2015-12 – Plan Accounting
Check (applicable entity):
P/C
Life
Health
Modification of existing SSAP
New Issue or SSAP
Description of Issue:
In July 2015, the FASB issued ASU 2015-12 – Plan Accounting: Defined Benefit Pension Plans (Topic 960);
Defined Contribution Pension Plans (Topic 962); and Health and Welfare Benefit Plans (Topic 965). This
ASU reflects a consensus of the FASB Emerging Issues Task Force and includes three separate parts
addressing the following issues: I) Fully Benefit-Responsive Investment Contracts; II) Plan Investment
Disclosures; and III) Measurement Date Practical Expedient. In reviewing this ASU, the revisions are specific
to “plan accounting”, and not the accounting by the reporting entity for benefit obligations. In reviewing prior
actions for GAAP guidance pertaining to “plan accounting”, the Statutory Accounting Principles (E) Working
Group has previously rejected those standards as not applicable to statutory accounting.
Part I – Fully Benefit-Responsive Investment Contracts - Key prior GAAP Guidance: SOP 94-4, SOP 99-3,
SOP 92-6 and AICPA Audit & Accounting Guide for Employee Benefit Plans.
Part II – Plan Investment Disclosures - Key prior GAAP Guidance: FAS 35, FAS 110, SOP 99-2, SOP 92-6,
and AICPA Audit & Accounting Guide for Employee Benefit Plans
Part III – Measurement Date Practical Expedient - Key prior GAAP Guidance: FAS 35, FAS 110, SOP 92-6,
SOP 94-4, SOP 99-3, and Audit & Accounting Guide for Employee Benefit Plans
The ASU revisions add exclusions to the scope of derivative guidance for synthetic guaranteed investment
contracts that meet the definition of a fully benefit-responsive investment contract held by an employee
benefit plan, and exclude fully benefit-responsive investment contracts held by an employee benefit plan from
financial instrument disclosures. As noted, these exclusions pertain only if held by an employee benefit plan.
Existing Authoritative Literature:
 FAS 35, Accounting and Reporting by Defined Benefit Pension Plans – Rejected as Not Applicable.

FAS 110, Reporting by Defined Benefit Pension Plans of Investment Contracts – an Amendment of
FASB Statement No. 35 – Rejected as Not Applicable.

SOP 92-6, Accounting and Reporting by Health and Welfare Benefit Plans – Rejected as Not
Applicable.

SOP 94-4, Reporting by Investment Contracts Held by Health and Welfare Benefit Plans and Defined
Contribution Pension Plans – Rejected as Not Applicable.

SOP 99-2, Accounting and Reporting of Postretirement Medical Benefits (401(h)) Features of
Defined Benefit Pension Plans – Rejected as Not Applicable.
© 2015 National Association of Insurance Commissioners 1
Ref #2015-38

SOP 99-3, Accounting for and Reporting of Certain Defined Contribution Plan Investments and
Other Disclosure Matters – Rejected as Not Applicable.
Activity to Date (issues previously addressed by SAPWG, Emerging Accounting Issues WG, SEC,
FASB, other State Departments of Insurance or other NAIC groups): None.
Information or issues (included in Description of Issue) not previously contemplated by the SAPWG:
None
Recommendation:
Staff recommends that the Working Group move this item to the nonsubstantive active listing and
expose the intent to reject ASU 2015-12 in Appendix D as not applicable to statutory accounting.
As detailed in the summary, the revised guidance within the ASU is specific to “plan accounting” and is not
applicable to insurer reporting entities. Additionally, the scope exclusions for derivatives and financial
instrument disclosures are not considered necessary in statutory accounting as they only apply for employee
benefit plan accounting. Since those exclusions would not be relevant for insurer reporting entities, revisions
to include those exclusions within SSAP No. 86 and SSAP No. 100 are not considered necessary.
Staff Review Completed by:
Julie Gann – August 2015
Status:
On November 19, 2015, the Statutory Accounting Principles (E) Working Group moved this item to the
nonsubstantive active listing and exposed this agenda item noting the intent to reject ASU 2015-12 in
Appendix D as not applicable to statutory accounting.
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© 2015 National Association of Insurance Commissioners 2