| id |
5b798910-451b-406f-8275-63137716e085 |
| user_id |
8684964a-bab1-4235-93a8-5fd5e24a1d0a |
| job_id |
glmjcwsd-3961 |
| base_model_name |
xevyo |
| base_model_path |
/home/sid/tuning/finetune/backend/output/xevyo-bas /home/sid/tuning/finetune/backend/output/xevyo-base-v1/merged_fp16_hf... |
| model_name |
Longevity Risk |
| model_desc |
Longevity Risk |
| model_path |
/home/sid/tuning/finetune/backend/output/glmjcwsd- /home/sid/tuning/finetune/backend/output/glmjcwsd-3961/merged_fp16_hf... |
| source_model_name |
xevyo |
| source_model_path |
/home/sid/tuning/finetune/backend/output/xevyo-bas /home/sid/tuning/finetune/backend/output/xevyo-base-v1/merged_fp16_hf... |
| source_job_id |
xevyo-base-v1 |
| dataset_desc |
The document is a formal technical comment letter The document is a formal technical comment letter submitted by the American Academy of Actuaries’ C-2 Longevity Risk Work Group to the NAIC Longevity Risk (A/E) Subgroup on December 21, 2021. It provides actuarial analysis and recommendations regarding the treatment of longevity reinsurance within NAIC’s developing capital and reserving framework—specifically as it relates to the proposed VM-22 principle-based reserving (PBR) requirements for fixed annuities.
Purpose of the Letter
The Academy responds to NAIC’s request for input on how longevity reinsurance contracts should be incorporated into:
C-2 Longevity capital requirements
VM-22 reserve calculations
The broader Life Risk-Based Capital (LRBC) framework
The objective is to ensure consistent, risk-appropriate treatment of longevity reinsurance as its market expands.
Key Points and Insights
1. Longevity reinsurance now explicitly falls within VM-22’s scope
The draft VM-22 includes longevity reinsurance in its product definition, meaning:
The reinsurer assumes longevity risk linked to periodic annuity payments.
Premiums from direct writers are spread over time.
Contracts may use net settlement (one-way periodic payments).
This inclusion enables a straightforward approach for capital calculations.
2. Reserve aggregation under VM-22 may simplify capital treatment
The Academy notes that aggregating longevity reinsurance with other annuity products:
Allows the existing C-2 capital factors to remain applicable.
May produce counterintuitive but appropriate results—e.g., longevity reinsurance can reduce total reserves if future premiums exceed benefit obligations.
A numerical illustration in the letter shows how aggregation can lower the combined reserve relative to stand-alone immediate annuity reserves.
3. Calibrating a new factor for reinsurance is currently not possible
The Academy explains that:
The 2018 field study, which calibrated current C-2 Longevity factors, lacked enough longevity reinsurance data.
Therefore, no reinsurance-specific factor can be developed yet.
It is reasonable to assume reinsurance longevity risk is similar to that of the underlying annuity liabilities.
4. Capital treatment for pre-2024 reinsurance contracts remains unresolved
Because VM-22 applies only to contracts issued after January 1, 2024, existing longevity reinsurance treaties could require:
Different reserving methods
A revised capital approach
This issue affects fewer companies but still requires regulatory attention.
5. Two possible future capital approaches are outlined
If VM-22 aggregation is not adopted (or if pre-2024 treaties use different reserving rules), NAIC may consider:
A) Keep the current C-2 factor applied to the present value of benefits.
Simple and consistent with existing RBC practice
But may conflict with Total Asset Requirement (TAR) principles
B) Develop an adjusted capital factor for longevity reinsurance.
More precise but complex
Hard to calibrate consistently across different treaty structures
6. Longevity reinsurance differs from life insurance in ways relevant to capital design
Key distinctions include:
Longevity reinsurance premiums are contractual obligations, often collateralized.
Under a longevity “shock,” premiums continue whereas in life insurance, a death event ends the need to pay premiums.
These differences may justify including gross premiums in reserves or capital calculations.
7. Ceded longevity risk must also be properly recognized
The letter recommends clarifying RBC rules so that:
Longevity risk transferred via reinsurance
Is reflected in the C-2 calculation
Similar to existing adjustments for modified coinsurance (Modco) reserves
Overall Purpose and Contribution
The letter provides actuarial expertise to help NAIC:
Integrate longevity reinsurance into the C-2 Longevity capital framework
Align reserves and capital with the economic reality of longevity risk transfer
Maintain consistency across new and legacy contracts
Avoid regulatory gaps as the longevity reinsurance market grows
The Academy expresses strong support for VM-22’s direction and offers to continue collaborating as NAIC finalizes its approach.
If you'd like, I can create:
📌 a simplified one-page summary
📌 a presentation-style briefing
📌 a comparison of all longevity-risk documents you provided
📌 an integrated cross-document meta-summary
Just tell me!
Sources... |
| dataset_meta |
{"input_type": "file", "source {"input_type": "file", "source": "/home/sid/tuning/finetune/backend/output/glmjcwsd-3961/data/document.pdf", "num_examples": 37, "bad_lines": 0}... |
| dataset_path |
/home/sid/tuning/finetune/backend/output/glmjcwsd- /home/sid/tuning/finetune/backend/output/glmjcwsd-3961/data/glmjcwsd-3961.json... |
| training_output |
null |
| status |
queued |
| created_at |
1765050185 |
| updated_at |
1765050520 |
| source_adapter_path |
NULL |
| adapter_path |
/home/sid/tuning/finetune/backend/output/glmjcwsd- /home/sid/tuning/finetune/backend/output/glmjcwsd-3961/adapter... |
| plugged_in |
False |