NAIC BLANKS (E) WORKING GROUP Blanks Agenda Item Submission Form DATE: CONTACT PERSON: 02/15/2012 David Vacca, NAIC Staff TELEPHONE: FOR NAIC USE ONLY Agenda Item # 2012-25BWG Year 2012 Changes to Existing Reporting [X ] New Reporting Requirement [ ] EMAIL ADDRESS: REVIEWED FOR ACCOUNTING PRACTICES AND PROCEDURES IMPACT ON BEHALF OF: No Impact [ X ] Modifies Required Disclosure [ DISPOSITION NAME: Jim Mumford, Chair of RSAWG with the support of the Chairs of the E Committee, Financial Analysis Handbook Working Group, Financial Analysis Working Group, Life Actuarial Task Force, and the Separate Accounts Risk Working Group. TITLE: AFFILIATION: [ ] [ ] [ X ] [ ] [ ] [ ] [ ] ] Rejected For Public Comment Referred To Another NAIC Group Received For Public Comment Adopted Date Rejected Date Deferred Date Other (Specify) Iowa Insurance Division ADDRESS: BLANK(S) TO WHICH PROPOSAL APPLIES [X ] [X ] ANNUAL STATEMENT INSTRUCTIONS [ ] [X ] QUARTERLY STATEMENT CROSSCHECKS [ X ] Life and Accident & Health [ X ] Separate Accounts [ ] Other Specify [X ] [X ] Property/Casualty Fraternal [X ] [X ] [X ] BLANK Health Title Anticipated Effective Date: Annual 2012 IDENTIFICATION OF ITEM(S) TO CHANGE See comments on page 2 REASON, JUSTIFICATION FOR AND/OR BENEFIT OF CHANGE** See comments on page 2 NAIC STAFF COMMENTS Comment on Effective Reporting Date: Annual 2012 should not be a problem Other Comments: ___________________________________________________________________________________________________ ** This section must be completed on all forms. Revised 6/13/2009 © 2012 National Association of Insurance Commissioners 283 IDENTIFICATION OF ITEM(S) TO CHANGE Require insurers filing separate account statements to file separate statements for “Insulated Separate Accounts” and “Non-Insulated Separate Accounts”. The change results in multiple filings by insurers with both insulated and non-insulated separate account products and the creation of a new filing ID to differentiate the filings. Modify the separate accounts Jurat page by adding indicator of whether the separate accounts reported in the filing are insulated or non-insulated. Also modify the first question of the separate accounts general interrogatories to indicate reporting of “Product Mix”, deleting Question 1.1, renumbering Question 1.2 to 1, replace column 3 of the table with a column to indicate whether the product is guaranteed. Modify the separate account instructions in the Life and Fraternal Annual Statement instructions by adding paragraph to Separate Account General instruction regarding distinct filing for insulated and non-insulated separate accounts and add instructions for indicating which type of separate accounts are being reported in the filing to the Jurat Page instructions. Add a new code indicator to the Code column in investment Schedules A, Part 1; B, Part 1; BA, Part 1; D, Part, 1; D, Part 2, Section 1; D Part 2, Section 2; DA, Part 1; DL, Part 1; and E, Part 2 to identify assets that are comingled between an insulated product and a non-insulated product. NOTE: Property, Health and Title are included as part of the proposal due to the Investment Schedules being uniform schedules. REASON, JUSTIFICATION FOR AND/OR BENEFIT OF CHANGE** The Receivership and Insolvency Task Force has considered the reporting needs for the current separate accounts mix of products and assets, and determined that due to considerations with insulated and non-insulated products/assets in a troubled company situation as well as for active solvency monitoring purposes, information filed on the separate account should be clearly differentiated between insulated and non-insulated. The proposal will allow regulators to: Accurately assess whether insurers are in compliance with state investment laws as “non-insulated” assets are technically subject to general account investment limitations; Distinguish which assets belong to “insulated” and “non-insulated” products within S/A to help receivers in the event of a liquidation; Provides regulators more transparency that policyholders that hold non-insulated products within the S/A are appropriately informed that their product and related assets are not insulated from the general account; Provides regulators more transparency that investment returns (gains/losses) from specific assets are being appropriately allocated to the appropriate product holders (e.g. hedging losses across all S/A assets may be allocated at the discretion of the company among insulated and non-insulated products); Having separate books requires the issue of disclosure of expenses (transfers) of non-insulated S/As so they are not commingled with the true insulated accounts; By adding a new code to the Code column of the investment schedules, regulators will be able to identify those assets that are comingled between the insulated and non-insulated products, which might require more regulatory awareness. Separate account management has similarities to mutual fund management. Mutual funds are required to have certain assurance services performed by independent accountants. This proposal would provide efficiency in facilitating insurance regulators review of insulated and non-insulated asset activities. © 2012 National Association of Insurance Commissioners 284 ANNUAL STATEMENT INSTRUCTIONS – LIFE AND FRATERNAL INSTRUCTIONS FOR COMPLETING SEPARATE ACCOUNTS ANNUAL STATEMENT BLANK INDEX The annual statement shall contain an alphabetized index on the last page of the hard copy statement which references the title and page number of all of the pages that are required to be included in that filing. The NAIC shall maintain, and place on its Web Site at www.naic.org/committees_e_app_blanks.htm, the alphabetized index for all statement types that is required to be included in the hard copy of the statement. The above is only required on the March 1 filing, and specifically excludes any supplements. GENERAL The instructions for completing the general account are to be followed to the extent applicable. This supplement provides additional instructions that are unique to the Separate Accounts Blank as well as some that differ from those for the Life and Accident and Health Blank. Where there is a conflict with the Life Blank’s instructions, use these instructions. The reporting date must be plainly written or stamped at the top of all pages, exhibits and schedules (and duplicate schedules) and also upon all inserted schedules and loose sheets. Reinsurance of separate accounts business is subject to the same Transfer of Risk requirements for reinsurance accounting treatment as general account business. All reinsurance transactions involving separate accounts business, if any, must be reported as reinsurance transactions in the general account annual statement, including reinsurance premiums, deposits, benefits, withdrawals, Schedule S (for separate accounts modified coinsurance reserves), Schedule T and where applicable, the Notes to Financial Statements and Schedule Y, Part 2. If the assuming company does not receive funds to be invested, such as with modified coinsurance or coinsurance with funds withheld, the assuming company must account for such reinsurance in its general account statement. If the assuming company receives funds to be invested in support of the reinsured variable benefit reserves, the assuming company must use its separate accounts statement for such reinsurance assumed. The separate accounts statement reports only the operations of the separate accounts themselves. It assumes that the administration of the contracts is reflected in the general account statement – hence, administrative expense does not appear in the Separate Accounts Statement, premiums and considerations are net of loading, and the expenses and taxes are those associated with the separate account investment operations. A separate distinct filing should be made for separate account products that are insulated from the general creditors of the general account and for separate account products that are not insulated (i.e. an insurance company with both insulated and non-insulated products in the separate account would submit two complete and different filings).When completing the insulated blank, a reporting entity should only include those assets that are legally insulated by state law or statute. Legally insulated assets shall be equal to the reserves and supporting contract liabilities of the separate account. Such assets provide legal protection to the separate account contract holder from the general account liabilities. All other assets within the separate account that are not legally insulated by state law or statute shall be included in the non-insulated blank. © 2012 National Association of Insurance Commissioners 285 Examples: Scenario Scenario 1: Separate Account Insulated Assets = Separate Account Liabilities Insulated S/A Blank The $4,000 issue is associated with an insulated product, the entire $4,000 would be reported in the insulated blank. Non-insulated S/A Blank No amount $3,990 of the issue is associated with an insulated product, thus this amount would be included in the insulated blank. The remaining $10 is a due to the General Account, the $10 would then be reported under the non-insulated blank. No amount The $1,500 issue would be reported non-insulated blank. (For example, 100% of investment proceeds, net fees is attributed to the contract holder) 40 bonds at $100 par value = $4,000 Scenario 2: Separate Account Assets > Separate Account Liabilities resulting in a “due to” the General Account (For example, Contract specifies a ceiling on the investment return to contractholder, excess investment returns are retained by the reporting entity, the portion then retained by the general account is considered noninsulated) 40 bonds at $100 par value = $4,000 Max to contract holders is $3,990 Scenario 3: Separate Account Noninsulated Assets = Separate Account Liabilities (For example, the asset supporting the contract was not approved by the state as a legally insulated product.) The reporting entity owns 15 bonds at $100 par value that do not support an insulated product Receipts other than income from investments are handled as a transfer from the general account. Similarly, amounts providing for the payment of benefits, including surrender benefits and various other payments, appear as transfers from the separate account to the general account. When eventually paid, these items are reported in the general account statement. The assets and liabilities are strictly those which arise from the operations of the separate accounts themselves, i.e., policy and contract reserves and items related to the making of investments, including investment expenses and taxes due or accrued. Unpaid transfers due the general account, such as surplus, contractual benefits, or contractual charges, would also appear on the liability page. Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 286 JURAT PAGE Enter all information completely as indicated by the format of the page. NAIC Group Code Current Period Enter the NAIC Group Code for the filing being processed. Prior Period Enter the NAIC Group Code for the prior quarter. State of Domicile or Port of Entry Alien companies doing business in the United States through a port of entry should complete this line with the appropriate state. U.S. insurance entities should enter the state of domicile. Country of Domicile U.S. Branches of alien insurers should enter the two-letter identifier for the reporting company’s country of domicile from the Appendix of Abbreviations. Domestic insurers should enter US in this field. Type of Separate Accounts Indicate the type of separate accounts reported in the filing by choosing insulated or non-insulated, but not both Commenced Business Enter the date when the reporting entity first became obligated for any insurance risk via the issuance of policies and/or entering into a reinsurance agreement. Statutory Home Office As identified with the Certificate of Authority in domiciled state. Main Administrative Office Location of the reporting entity’s main administrative office. Mail Address Reporting entity’s mailing address, if other than the main administrative office address. May be a P.O. Box and the associated ZIP code. Primary Location of Books and Records Location where examiners may review records during an examination. Internet Web Site Address Include the Internet Web site address of the reporting entity. If none, and information relating to the reporting entity is contained in a related entity’s Web site, include that Web site. Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 287 ANNUAL STATEMENT INSTRUCTIONS – SEPARATE ACCOUNTS LIFE AND ACCIDENT AND HEALTH COMPANIES – ASSOCIATION EDITION – SEPARATE ACCOUNTS ............................................. Affix Bar Code Above ANNUAL STATEMENT For the Year Ended December 31, 2012 OF THE CONDITION AND AFFAIRS OF THE SEPARATE ACCOUNTS OF THE ____________________________________________________________________________________________________________________________________________________________ NAIC Group Code ______________, ______________ NAIC Company Code _________________________Employer's ID Number _______________________________________________ (Current Period) (Prior Period) Organized under the Laws of ____________________________________________________________, State of Domicile or Port of Entry ___________________________________________ Country of Domicile ___________________________________________________________________ Type of Separate Accounts Insulated [ ] Non-insulated [ ] Incorporated/Organized ________________________________________________________________ Commenced Business ____________________________________________________ Statutory Home Office ________________________________________________________________ , ______________________________________________________________________ (Street and Number) (City or Town, State and Zip Code) Main Administrative Office _____________________________________________________________________________________________________________________________________ (Street and Number) ____________________________________________________________________________________ ______________________________________________________________________ (City or Town, State and Zip Code) (Area Code) Mail Address ________________________________________________________________________ , (Telephone Number) ______________________________________________________________________ (Street and Number or P.O. Box) (City or Town, State and Zip Code) Primary Location of Books and Records ___________________________________________________________________________________________________________________________ (Street and Number) ____________________________________________________________________________________ ______________________________________________________________________ (City or Town, State and Zip Code) (Area Code) (Telephone Number) Internet Web Site Address ______________________________________________________________ Statutory Statement Contact _____________________________________________________________________________________________________________________________________ (Name) (Area Code) (Telephone Number) (Extension) _____________________________________________________________________________________________ (E-Mail Address) (Fax Number) OFFICERS 1. 2. 3. 4. Name ________________________________ , ________________________________ , ________________________________ , ________________________________ , Title ______________________________ ______________________________ ______________________________ ______________________________ Other Name ________________________________ ________________________________ ________________________________ ________________________________ , , , , Title _________________________________ _________________________________ _________________________________ _________________________________ DIRECTORS OR TRUSTEES ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ State of ............................................................................... County of ........................................................................... __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ _________________________________________________ _________________________________________________ _________________________________________________ _________________________________________________ _________________________________________________ _________________________________________________ ss The officers of this reporting entity being duly sworn, each depose and say that they are the described officers of said reporting entity, and that on the reporting period stated above, all of the herein described assets were the absolute property of the said reporting entity, free and clear from any liens or claims thereon, except as herein stated, and that this statement, together with related exhibits, schedules and explanations therein contained, annexed or referred to, is a full and true statement of all the assets and liabilities and of the condition and affairs of the said reporting entity as of the reporting period stated above, and of its income and deductions therefrom for the period ended, and have been completed in accordance with the NAIC Annual Statement Instructions and Accounting Practices and Procedures manual except to the extent that: (1) state law may differ; or, (2) that state rules or regulations require differences in reporting not related to accounting practices and procedures, according to the best of their information, knowledge and belief, respectively. Furthermore, the scope of this attestation by the described officers also includes the related corresponding electronic filing with the NAIC, when required, that is an exact copy (except for formatting differences due to electronic filing) of the enclosed statement. The electronic filing may be requested by various regulators in lieu of or in addition to the enclosed statement. ____________________________________ (Signature) ____________________________________ (Printed Name) 1. ____________________________________ ____________________________________ (Signature) (Signature) ____________________________________ ____________________________________ (Printed Name) 2. (Printed Name) 3. ____________________________________ ____________________________________ ____________________________________ (Title) (Title) (Title) Subscribed and sworn to before me this ............... day of. ..................., 2013 a. Is this an original filing? b. If no: 1. State the amendment number 2. Date filed 3. Number of pages attached .................................................................. © 2012 National Association of Insurance Commissioners 288 Yes [ ] No [ ] ............................. ............................. ............................. GENERAL INTERROGATORIES Product Mix 1. Identify the product types in the separate account, quantify the assets associated with those products and indicate if there are any guarantees associated with those products: 1 Product Identifier 2 Separate Account Assets 3 Guarantees Associated with the Product Yes/No $ Totals $ XXX Separate Account Products with General Account Guarantees 2.1 Does the reporting entity have products with guarantees provided by the general account? Yes 2.2 If yes, what is the current total maximum guarantee the general account would provide to the separate account? $______________________ 2.3 Has the separate account collected amounts from the general account within the past five years related to separate account guarantees? Yes [ ] No [ ] 2.4 If yes, provide detail on these guarantees paid by the general account: Yes [ ] No [ ] 1 2 Year Amount 2.401 As of December 31, 2012 $ ________________ 2.402 As of December 31, 2011 $ ________________ 2.403 As of December 31, 2010 $ ________________ 2.404 As of December 31, 2009 $ ________________ 2.405 As of December 31, 2008 $ ________________ 2.5 To compensate the general account for the risk taken, for any separate account products with general account guarantees, does the separate account remit risk charges to the general account related to separate account guarantees? 2.6 If yes, identify the separate account products with risk charges that are remitted to the general account and whether the risk charge for that product is reviewed and opined upon: 1 Product Identifier with Risk Charges 2.7 2 Risk Charge Reviewed and Opined Upon 3 Name and Title of Individual Who Provided Opinion on Risk Charges Provide detail on the risk charges paid to the general account related to separate account guarantees for the past five years: 1 2 Year Amount 2.701 As of December 31, 2012 $ ________________ 2.702 As of December 31, 2011 $ ________________ 2.703 As of December 31, 2010 $ ________________ 2.704 As of December 31, 2009 $ ______XXX______ 2.705 As of December 31, 2008 $ ______XXX______ Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 289 [ ] No [ ] ANNUAL STATEMENT INSTRUCTIONS – LIFE, HEALTH, PROPERTY, FRATERNAL AND TITLE SCHEDULE A – PART 1 REAL ESTATE OWNED DECEMBER 31 OF CURRENT YEAR Detail Eliminated To Conserve Space Column 2 – Code Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If real estate is not under the exclusive control of the company as shown in the General Interrogatories, it is to be identified by placing one of the symbols identified in the Investment Schedules General Instructions located at the beginning of this section in this column. If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). Detail Eliminated To Conserve Space SCHEDULE B – PART 1 MORTGAGE LOANS OWNED DECEMBER 31 OF CURRENT YEAR Detail Eliminated To Conserve Space Column 2 – Code Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If mortgage loans are not under the exclusive control of the company as shown in the General Interrogatories, it is to be identified by placing one of the symbols identified in the Investment Schedules General Instructions located at the beginning of this section in this column. If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 290 SCHEDULE BA PART 1 OTHER LONG-TERM INVESTED ASSETS OWNED DECEMBER 31 OF CURRENT YEAR Detail Eliminated To Conserve Space Column 3 – Code Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If long-term invested assets are not under the exclusive control of the company as shown in the General Interrogatories, it is to be identified by placing one of the symbols identified in the Investment Schedules General Instructions located at the beginning of this section in this column. If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 291 SCHEDULE D – PART 1 LONG-TERM BONDS OWNED DECEMBER 31 OF CURRENT YEAR Detail Eliminated To Conserve Space Column 3 – Code Enter “*” in this column for all Class One Bond Mutual Funds. Enter “#” in this column for all Exchange Traded Funds. Enter “@” in this column for all Principal STRIP Bonds or other zero coupon bonds. Enter “$” in this column for Certificates of Deposit under the FDIC limit. Enter “&” in this column for TBA (To Be Announced) securities. Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If bonds are not under the exclusive control of the company as shown in the General Interrogatories, they are to be identified by placing one of the codes (identified in the Investment Schedules General Instructions located at the beginning of this section) in this column. If the security is a Class One Bond Mutual Fund, an Exchange Traded Fund, a Principal STRIP bond or other zero coupon bond, Certificates of Deposit under the FDIC limit or a TBA (To Be Announced) security and is not under the exclusive control of the company, the “*”, “#”, “@”, “$” or “&” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions) and may be used simultaneously with the “*”, “#”, “@”, “$” or “&” with the “^” preceding the other characters (“*”, “#”, “@”, “$” or “&”) depending on the asset being reported. Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 292 SCHEDULE D – PART 2 – SECTION 1 PREFERRED STOCKS OWNED DECEMBER 31 OF CURRENT YEAR Detail Eliminated To Conserve Space Column 3 – Code Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If preferred stocks are not under the exclusive control of the company as shown in the General Interrogatories, they are to be identified by placing one of the codes (identified in the Investment Schedules General Instructions located at the beginning of this section) in this column. If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). Detail Eliminated To Conserve Space SCHEDULE D – PART 2 – SECTION 2 COMMON STOCKS OWNED DECEMBER 31 OF CURRENT YEAR Detail Eliminated To Conserve Space Column 3 – Code Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If common stocks are not under the exclusive control of the company as shown in the General Interrogatories, they are to be identified by placing one of the codes (identified in the Investment Schedules General Instructions located at the beginning of this section) in this column. If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 293 SCHEDULE DA – PART 1 SHORT-TERM INVESTMENTS OWNED DECEMBER 31 OF CURRENT YEAR Detail Eliminated To Conserve Space Column 3 – Code Enter “@” in this column for all Principal STRIP Bonds or other zero coupon bonds. Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If short-term investments are not under the exclusive control of the company as shown in the General Interrogatories, they are to be identified by placing one of the codes (identified in the Investment Schedules General Instructions located at the beginning of this section) in this column. If the security is a Principal STRIP bond or other zero coupon bond and is not under the exclusive control of the company, the “@” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions) and may be used simultaneously with the “*”, “#”, “@”, “$” or “&” with the “^” preceding the “@”depending on the asset being reported. Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 294 SCHEDULE DL – PART 1 SECURITIES LENDING COLLATERAL ASSETS Reinvested Collateral Assets Owned December 31 Current Year Detail Eliminated To Conserve Space Column 3 – Code Enter “*” in this column for all Class One Bond Mutual Funds. Enter “#” in this column for all Exchange Traded Funds. Enter “@” in this column for all Principal STRIP Bonds or other zero coupon bonds. Enter “$” in this column for Certificates of Deposit under the FDIC limit. Enter “&” in this column for TBA (To Be Announced) securities. Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If assets are not under the exclusive control of the company as shown in the General Interrogatories, they are to be identified by placing one of the codes (identified in the Investment Schedules General Instructions located at the beginning of this section) in this column. If the security is a Class One Bond Mutual Fund, an Exchange Traded Fund, a Principal STRIP bond or other zero coupon bond, certificates of deposit under the FDIC limit or a TBA (To Be Announced) security and is not under the exclusive control of the company, the “*”, “#”, “@”, “$” or “&” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions) and may be used simultaneously with the “*”, “#”, “@”, “$” or “&” with the “^” preceding the other characters (“*”, “#”, “@”, “$” or “&”) depending on the asset being reported. Detail Eliminated To Conserve Space © 2012 National Association of Insurance Commissioners 295 SCHEDULE E – PART 2 – CASH EQUIVALENTS Detail Eliminated To Conserve Space Column 2 – Code Enter “^” in this column for all assets that are bifurcated between the insulated separate account filing and the non-insulated separate account filing. If a cash equivalent is not under the exclusive control of the company as shown in the General Interrogatories, it is to be identified by placing one of the codes identified in the Investment Schedules General Instructions located at the beginning of this section in this column. If the asset is a bifurcated asset between the insulated separate account filing and the non-insulated separate account filing, the “^” should appear first, immediately followed by the appropriate code (identified in the Investment Schedules General Instructions). Detail Eliminated To Conserve Space W:\QA\BlanksProposals\2012-25BWG.doc © 2012 National Association of Insurance Commissioners 296