CANNEX Research Team Submits Follow-Up Comments to NAIC Working Group

Toronto, ON – May 28, 2026: CANNEX Research has submitted a response to the NAIC Life Insurance and Annuities Illustrations Working Group regarding the following question:

What should be the starting point of a short-term solution: Model 245 language or something else (such as AG 49-A, other guidance, or starting anew)?

• If language similar to Model 245 or other existing guidance, what types of modifications do you believe are necessary to address current regulatory concerns regarding illustrated rates and transparency (i.e., which sections/parts do you believe need to be added or modified)?
• If starting anew, then how can the scope be limited to ensure progress towards a short-term solution before a longer-term solution is developed?

Read the full response here; the executive summary is provided below.

In response to the Working Group’s follow-up question, CANNEX recommends Model 245 (Annuity Disclosure Model Regulation)[1] as the starting point for a short-term regulatory solution. The two short term approaches described in our March 2026 comment — enhanced renewal rate disclosures and a supplemental “Reduced Rate” scenario — map to identifiable provisions within Model 245, and targeted modifications to those provisions can be implemented near-term without a comprehensive overhaul of the regulation.

We recommend modifications to:

• Sections 6-G(4)(b) and 6-J(3): to require enhanced disclosure of renewal rate risk and the economic trade-offs
  embedded in premium bonus products
• Section 6-F(9): to mandate a supplemental “Reduced Rate” scenario

We do not recommend AG 49-A as the starting point, nor do we recommend starting anew.