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SEC Lets Symetra Put Insurance-Style Financial Statements in Annuity Filings

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The staff at the U.S. Securities and Exchange Commission is pushing forward with a policy shift that may help life insurers save some money on variable annuity accounting.

The SEC staff put out a “no-action letter” ruling Thursday that gives two life insurers permission to use the financial statements they have prepared for state insurance regulators, rather than the accounting rules that usually apply to “publicly traded” companies, in the registration statement forms for indexed annuities that are filed as variable annuities.

(Related: Annuity Issuers Are Using This Move to Save MILLIONS)

The insurers are Symetra Life Insurance Company and a sister company, First Symetra National Life Insurance Company of New York. Both are now part of Sumitomo Life Insurance Company of Osaka.

The Background

Life insurers prepare many different types of financial statements for state insurance regulators using the regulators’ own Statutory Accounting Principles (SAP).

“Publicly traded companies,” or companies that have sold stock to large number of investors, use Generally Accepted Accounting Principles (GAAP).

The SEC does not require life insurers to file documents related to specific life insurance or annuity products that are classified as fixed products. Life insurers submit filings for those products to state insurance regulators.

Life insurers do have to file registration forms, which are comparable to mutual fund registration forms, for products classified as variable products.

The SEC posts the variable product filings here.

In the past, the SEC required insurers to include GAAP financial statements with their registration statements.

Life insurers have argued that SAP accounting is at least as rigorous as GAAP accounting, and better-suited to the nature of insurance products than GAAP accounting. Life insurers have also argued that, in many cases, the SEC has developed policies that shows the SEC recognizes the value of the SAP accounting rules and state insurance company oversight.

The SEC began allowing the use of SAP financial statements in variable products in a no-action letter issued in November 2016.

The SEC issued a collection of four similar letter rulings in September 2018.

Lincoln Benefit Life Company received a no-action letter allowing the use of SAP financial statements in registration statements for the market-value-adjusted (MVA) account investment options available with the fixed options inside variable annuity contracts in March.

MONY Life Insurance Company of America also received a no-action letter in March. In that letter, the SEC allowed the use of SAP financial statements in registration statements for both index-linked options available with variable life products and MVA options available with the fixed options inside variable annuity contracts.

Alison Staloch, the chief accountant at the SEC’s Division of Investment Management, signed the Symetra letter, as well as the Lincoln Benefit and MONY letters.


A copy of the new SEC accounting method letter ruling is available here.

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