NAV price source crosscheck error

[LaurieM-CAM]

If a fund is priced using it's NAV and qualifies for NAV source per SSAP 100R then on the annual statement, FV Hierarchy Level and Method code should be left blank. We did this and received a cross check error saying that code on col 19 is missing. We will note that the crosscheck error is incorrect, but can you confirm and adj the crosscheck?

NAIC Rule PTASU092020 9200001

[Administrator]

The guidance to leave column 19 blank is new for 2018. However, the validation PTASU092020 appears to be unchanged from last year.

We will share this discrepancy with our NAIC contact. The change process for NAIC rules is much more restrictive, so we can not modify the rule until the NAIC publishes new rule files to all of the vendors. In the event that happens, we will get the new rules out as quickly as possible.

Until then, you are correct in entering an explanation for the rule. I would suggest including a reference to SSAP 100R in some form, so that both the NAIC and any state regulators who see the explanation can tell why the rule is incorrect. Something like:

SSAP 100R allows column 19 to be blank when using NAV instead of FV.

Gary