Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
AGENCY REPORT TO THE  
JOINT COMMITTEE ON ADMINISTRATIVE RULES (JCAR)  
AGENCY INFORMATION:  
Agency name:  
Insurance and Financial Services  
Division/Bureau/Office:  
Insurance  
Name of person completing this form:  
Julie Merriman  
Phone number of person completing this form:  
517-284-8787  
Email of person completing this form:  
Name of Department Regulatory Affairs Officer reviewing this form:  
Jeff Hayden  
RULE SET INFORMATION:  
MOAHR assigned rule set number:  
2023-64 IF  
Title of the proposed rule set:  
Term and Universal Life Insurance Reserve Financing  
1. Purpose of the proposed rules and background:  
The proposed rules govern reserve financing arrangements used by certain life insurers in reinsurance transactions to  
secure the reinsurance treaty or capitalize the reinsurer in order to meet statutory reserve requirements. The  
proposed rules ensure that funds backing these transactions are held in the appropriate form and level of security.  
The proposed rules would adopt Model Regulation #787 of the National Association of Insurance Commissioners  
(NAIC). The Department currently implements substantially similar requirements through review of financial  
statements filed with the Department pursuant to the Director’s order issued under MCL 500.438 of the Insurance  
Code of 1956. The NAIC has adopted the Model Regulation as a state insurance department accreditation standard.  
Accordingly, the proposed rules would also assist in establishing uniform, national standards for the reserve financing  
arrangements subject to the rules and ensure that the Department maintains its accreditation status.  
2. Summary of the proposed rules:  
The proposed rules govern reserve financing arrangements used by certain life insurers in reinsurance transactions to  
secure the reinsurance treaty or capitalize the reinsurer. The proposed rules ensure that funds backing these  
transactions are held in the appropriate form and level of security. The proposed rules would adopt Model Regulation  
#787 of the National Association of Insurance Commissioners.  
3. List names of newspapers in which the notice of public hearing was published and publication  
dates:  
Escanaba Daily Press (May 15, 2024); Lansing State Journal (May 15, 2024); Detroit Free Press (May 15, 2024).  
4. Date of publication of the proposed rules and notice of public hearing in the Michigan Register:  
5/15/2024  
5. Date, time, and location of the public hearing:  
MCL 24.242 and 24.245  
Agency Report to JCAR -Page 2  
6/4/2024 09:30 AM at Ottawa Building, Conference Room #6, 611 West Ottawa Street, Lansing, Michigan 48933  
6. Provide the link the agency used to post the regulatory impact statement and cost-benefit analysis  
on its website:  
7. List of the name and title of agency representative(s) who attended the public hearing:  
Julie Merriman, Administrative Law Specialist, Department of Insurance and Financial Services  
8. Persons submitting comments of support:  
None  
9. Persons submitting comments of opposition:  
None  
10. Persons submitting other comments:  
None  
11. Identify any changes made to the proposed rules based on comments received during the public  
comment period:  
None.  
12. Date report completed:  
5/7/2026  
MCL 24.242 and 24.245  
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