BACKGROUND

The Risk Management Own Solvency Risk Assessment Model Act #505 (ORSA) was adopted on September 6, 2012. In order to assist insurance companies that must file an ORSA with the lead state insurance department of insurance, the NAIC developed an ORSA Guidance Manual.

Since adoption, the NAIC has periodically updated the ORSA Guidance Manual to clarify or expand the ORSA requirements based on its own experience of assisting state insurance regulators with ORSA reviews and on the feedback received from the members of the NAIC ORSA Implementation (E) Subgroup and interested parties.

The NAIC would like to collect feedback from a wider audience of insurance companies that file ORSAs, interested regulators and any interested third parties on any wording or requirements in the ORSA Guidance Manual that needs to be clarified or revised.

The results of the survey will be accumulated by NAIC staff, analyzed and presented in an anonymous format at a public meeting of the NAIC ORSA Implementation (E) Subgroup together with a proposal of how the Subgroup members intend to respond to the feedback provided by the survey participants.

If you are interested in providing your feedback, please complete the survey by October 24, 2025.

If you have any questions on the survey, please contact NAIC staff (Elisabetta Russo erusso@naic.org or Sherry Flippo sflippo@naic.org).
SURVEY

The NAIC has designed this survey to collect the feedback by each section and subsection of the latest ORSA Guidance Manual that was adopted in August 2025. You can select just the (sub)sections you want to provide feedback on and leave the other (sub)sections blank. Please ensure that you have the latest version of the ORSA Guidance Manual before entering the survey. For sections of the manual that cover many pages, please refer to the page number or the specific wording in your feedback that requires clarification to help NAIC staff identify it.

The latest version of the NAIC ORSA Guidance Manual can be found on the webpage of Subgroup, on the right-hand side tab labelled “Documents”, at this link: https://content.naic.org/committees/e/own-risk-solvency-assessment-implementation-sg#.

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* 1. Organization Name:

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* 2. Respondent's Name:

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* 3. Title:

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* 5. Introduction
Please describe any clarification needed in this section and in the sub-sections listed below.

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* 6. A. Exemption

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* 7. B. Application for Waiver

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* 8. C. General Guidance

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* 9. D. Maintenance Process

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* 10. Section 1 - Description of the Insurer’s Enterprise Risk Management Framework
Please describe any clarification needed in this section.
For example, provide more guidance on the ORSA filing(s) that should be submitted to the US regulators by insurers that have a non-US group-wide supervisor.

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* 11. Section 2 - Insurer’s Assessment of Risk Exposures
Please describe any clarification needed in this section.
For example, provide more guidance on what regulators expect in a high-level summary of the quantitative and/or qualitative assessments of risk exposure in both normal and stressed environments for each material risk category.

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* 12. Section 3 - Group Assessment of Risk Capital and Prospective Solvency Assessment
Please describe any clarification needed in this section and in the sub-sections listed below.
For example, provide more guidance on what regulators expect to see in the group assessment of risk capital.

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* 13. A. Group Assessment of Risk Capital

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* 14. B. Prospective Solvency Assessment

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* 15. Additional Expectations for International Active Insurance Groups (IAIG)-
Please describe any clarification needed in this section.

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* 16. Appendix - Glossary
Please describe any clarification needed in this section.

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* 17. Any Other Comments
Please provide any additional comments.

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