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NAIC May Cancel Shift to New Guaranteed Issue Life Table

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The National Association of Insurance Commissioners (NAIC) may roll back a move toward a new mortality table for guaranteed issue life insurance.

Some state insurance regulators say moving toward the new 2017 Commissioners Standard Guaranteed Issue Mortality Table, which was approved in 2018, would cause big problems for life insurers.

(Related: How Well Does Accelerated Life Underwriting Really Work?)

Regulators have proposed a canceling the shift to the 2017 table and moving back to the old 2001 Commissioners Standard Ordinary ultimate mortality table for guaranteed issue business issued after Dec. 31, 2019.


The NAIC is a Kansas City, Missouri-based group for state insurance regulators.

States often use NAIC models when developing their insurance laws, regulations and procedures.

“Guaranteed issue life insurance” is life insurance sold without use of medical underwriting. Many of the purchasers may be older people with health problems, who cannot qualify for ordinary life insurance but want to have modest amounts of life insurance available to pay for their funerals and help the beneficiaries with bills.

What Happened in Orlando

Concerns about the new guaranteed issue life mortality tables surfaced this week in Orlando, Florida, at the NAIC’s spring national meeting.

Members of the NAIC’s Life Actuarial Task Force agreed to seek public comments on Amendment Proposal 2019-38. The proposal would start the process of blocking the move to the 2017 mortality table and returning to the 2001 table.

Rhonda Ahrens, a regulator with the Nebraska Department of Insurance, proposed the amendment that would roll back the guaranteed issue life mortality table standard.

Ahrens acknowledges on the request form that the Life Actuarial Task Force approved the shift in 2018.

“Unfortunately, the original analysis of the table failed to consider all the issues associated with guaranteed issue products,” Ahrens says in the request form. “Additional analysis by companies trying to implement the table have shown that use of the table is likely to disrupt the guaranteed issue market by making the products less viable due to pricing, cross -subsidization, nonforfeiture, and other concerns.”

If the NAIC rolls back the mortality table standard, the Life Actuarial Task Force will continue to monitor the performance of guaranteed issue products and the appropriateness of using the 2001 mortality table for guaranteed issue business, Ahrens says.


Documents related to the Life Actuarial Task Force meeting are available here, under the Meeting Materials tab.

— Read Proposed 2001 CSO Table Can Impact The Life Policies You Sellon ThinkAdvisor.

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