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Separate Accounts

Background

Last Updated: 9/3/2025 
 

A 鈥渟eparate account鈥 is an administratively distinct financial account maintained by a life insurance company to report and record assets and liabilities of specific products separate from the insurer's general account.  

Separate accounts are commonly used to support the investment features of products such as a variable annuity or life insurance product. While the assets and liabilities of separate accounts are reported as components of the life insurer鈥檚 general account financial statement, they are clearly identified as belonging to the separate accounts. 

Separate accounts were originally established in response to federal securities laws for investment-linked variable annuities. Although it took many years, the application of separate accounts has dramatically expanded beyond this simple product design. Product development has resulted with an array of 鈥渉ybrid鈥 products鈥攑roducts that overlay traditional insurance company guarantees (e.g., mortality, morbidity, etc.) being allocated to the separate account investment portfolio. 

Actions

To clarify information pertaining to separate account products and related separate account assets and liabilities, detailed statutory financial statement data and disclosures are provided regarding the products and assets captured in a separate account. While detailed in SSAP No. 56鈥擲eparate Accounts, examples of information provided include: 

  • Distinct filings are required for separate products that are 鈥渋nsulated鈥 or 鈥渘ot insulated鈥 from the general account creditors. When completing the separate account filing for insulated products, the reporting entity only includes those assets that are legally insulated by state law or statute. For these accounts, state law provides legal protection to the separate account contract holder from the general account liabilities. 

  • Separate account filings include additional information categorizing separate account assets in accordance with the following characteristics: 

  • Identification for all separate account assets not reported at fair value, and the measurement basis used for them. 

  • Aggregation of separate account assets from products which are either SEC registered or Non-SEC registered, and specific identification of assets from private placement annuities or private placement life insurance. 

  • Amount of separate account assets that represent seed money, other fees and expenses due to the general account, and additional required surplus amounts. 

  • Identification of separate account assets in which the investment directive is not determined by the contract holder. Situations in which the investment directive is not determined by the contractholder also requires disclosure on whether the investments, if included in the general account, would have resulted with the reporting entity exceeding any general account investment limitations. 

  • Identification of separate account assets in which less than 100% of investment proceeds are attributed to the contractholder. This also includes identification of the separate account investment income attributed to the reporting entity during the reporting period and whether the income was transferred to the general account or reinvested within the separate account. 

  • Identification of all products reported as a separate account product under statutory accounting principles, and whether the product was classified differently under U.S. GAAP. For products with different classifications between statutory accounting and U.S. GAAP, identification of the characteristics that resulted with a different classification under U.S. GAAP. 

Information on separate account products with general accounting guarantees, including the amount of guarantees paid by the general account for the current reporting year, and for the previous four reporting years. This information also details the risk charges paid from the separate account to the general account related to these guarantees, and whether the risk charges are reviewed and opined upon. 

Note that the information provided above does NOT constitute a complete summary of the disclosure and reporting requirements applicable to Separate Accounts. Users are advised to consult SSAP No. 56 within the Accounting Practices and Procedures Manual, as well as the Separate Accounts Blanks, for further guidance. 

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