Founded in 1959, F&G is a leading provider of insurance solutions serving retail annuity and life customers as well as institutional clients.
−Removed: Our mission is to help people turn their aspirations into reality and, as of December 31, 2023, F&G has approximately 677,000 policyholders who count on the safety and protection our fixed annuity and life insurance products provide.
−Removed: Through our insurance subsidiaries, including Fidelity & Guaranty Life Insurance Company (“FGL Insurance”) and Fidelity & Guaranty Life Insurance Company of New York (“FGL NY Insurance”), we market a broad portfolio of annuities, including fixed indexed annuities (“FIAs”) and multi-year guarantee annuities (“MYGAs”), pension risk transfer (“PRT”) solutions, as well as indexed universal life (“IUL”) insurance and institutional funding agreements.
−Removed: In February 2024, we entered one of the fastest growing segments of the annuity space by marketing registered index-linked annuities (“RILAs”).
−Removed: We were acquired on June 1, 2020, by Fidelity National Financial, Inc.
+Added: Our mission is to help people turn their aspirations into reality.
+Added: As of December 31, 2024, F&G has approximately 731,000 policyholders who count on the safety and protection of our fixed annuity and life insurance products.
+Added: We also serve approximately 115,000 plan participants who will receive their pension payments from F&G through our pension risk transfer solutions.
+Added: Through our insurance subsidiaries, including Fidelity & Guaranty Life Insurance Company (“FGL Insurance”) and Fidelity & Guaranty Life Insurance Company of New York (“FGL NY Insurance”), we market a broad portfolio of annuities, including fixed indexed annuities (“FIAs”), registered index-linked annuities (“RILAs”), (together referred to as “indexed annuities”), multi-year guarantee annuities (“MYGAs”) as well as pension risk transfer (“PRT”) solutions, indexed universal life (“IUL”) insurance and institutional funding agreements.
+Added: On June 1, 2020, F&G was acquired by Fidelity National Financial, Inc.
We have benefited from financial strength ratings upgrades since the acquisition;
−Removed: S&P and Fitch upgraded us to A- in June 2020, Moody’s upgraded to A3 in July 2023, and A.M.
−Removed: Best upgraded us to A in January 2024.
−Removed: These upgrades, valued by our distribution partners, positioned us to quickly expand our business in our existing channels and gain access to new markets.
−Removed: Gross sales increased from $4.5 billion for the full year 2020 to $13.2 billion in 2023 and did so profitably.
+Added: S&P and Fitch upgraded to A- in June 2020, Moody’s upgraded to A3 in July 2023, and A.M.
+Added: Best upgraded to A in January 2024.
+Added: These upgrades are valued by our distribution partners and positioned us to quickly expand our business in our existing channels and gain access to new markets.
+Added: Gross sales profitability increased from $4.5 billion for the full year 2020 to $15.3 billion in 2024.
With our success in expanding distribution under FNF’s ownership, we have grown assets under management (“AUM”) from $26.5 billion at the time of acquisition to $53.8 billion as of December 31, 2024.
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We believe the strength of our balance sheet provides confidence to our policyholders and business partners and positions us for continued growth.
−Removed: Our invested assets comprise what we believe to be a highly rated and well diversified portfolio.
−Removed: As of December 31, 2023, 95% of our fixed maturity securities were rated under criteria of the National Association of Insurance Commissioners (the “NAIC”) as NAIC 1 or NAIC 2, the two highest credit rating designations of the NAIC.
+Added: Our investment portfolio is diversified, well positioned and high quality.
+Added: As of December 31, 2024, 96% of our fixed maturity securities were rated under criteria of the NAIC as NAIC 1 or NAIC 2, the two highest credit rating designations of the NAIC.
These assets are managed against what we believe to be prudently underwritten liabilities.
We have in-force liabilities of $52.3 billion at December 31, 2024, with a liability duration of approximately 6 years, well matched to our assets.
−Removed: For the year ended December 31, 2023 , Net losses totaled $58 million, we produced adjusted net earnings (“ANE”) of $335 million, and we had an adjusted return on assets (“ROA”) of 72 basis points.
−Removed: Adjusted net earnings included $405 million of investment income from alternative investments and $51 million of significant expense items.
+Added: For the year ended December 31, 2024, net earnings attributable to F&G totaled $639 million, we produced adjusted net earnings attributable to F&G common shareholders of $546 million, and we had an adjusted return on assets attributable to F&G common shareholders (“ROA”) of 106 basis points.
+Added: Adjusted net earnings attributable to F&G common shareholders the year ended December 31, 2024 included $514 million of investment income from alternative investments and $46 million of collateralized loan obligations (“CLOs”) redemptions and bond prepay income, and $14 million tax valuation allowance, partially offset by $26 million of net expense from actuarial assumption and model updates and other items.
Alternative investments investment income based on management’s long-term expected return of approximately 10% was $659 million.
−Removed: We are focused on growing our inforce liabilities and AUM, driven by sales of attractively priced liabilities, including fixed indexed annuities, fixed rate annuities, registered indexed-linked annuities, indexed universal life, funding agreements, and pension risk transfer.
−Removed: We have plenty of momentum to continue to deliver sustainable asset growth from our retail and pension risk transfer growth strategies, and ongoing margin expansion from enhanced investment margin opportunities, operational scale benefits and fee-based earnings from accretive flow reinsurance.
−Removed: We are also well positioned to diversify our earnings given the strong growth of our middle market life insurance business and owned distribution strategies over time.
−Removed: As of December 31, 2023 , we had $3.1 billion of total F&G equity and $5.1 billion of total F&G shareholders’ equity excluding accumulated other comprehensive earnings (loss) (“AOCI”).
+Added: We are focused on growing our inforce liabilities and AUM, driven by sales of attractively priced liabilities across our multi-channel new business platform.
+Added: We have great momentum and remain focused on continuing to deliver long-term growth by driving sustainable asset growth from our retail and pension risk transfer growth strategies, generating ROA expansion from enhanced investment margin opportunities, scale benefits and fee-based earnings from accretive flow reinsurance, as well as diversifying earnings through strong growth in our middle market life insurance business and owned distribution strategies.
+Added: As of December 31, 2024 , we had $4.0 billion of total F&G equity and $5.6 bil lion of total F&G common shareholders’ equity excluding accumulated other comprehensive income (loss) (“AOCI”).
FGL Insurance’s estimated U.S.
−Removed: RBC ratio was approximately 451% a s of December 31, 2023, as compared to 442% and 451% as of December 31, 2022 and December 31, 2021, respectively.
+Added: RBC ratio was over 410% a s of December 31, 2024, as compared to 451% and 442% as of
+Added: December 31, 2023 and December 31, 2022, respectively.
FGL Insurance expects to maintain its U.S.
−Removed: risk-based capital (“RBC”) ratio at
−Removed: or above our target of 400%.
−Removed: Going forward, we intend to fund our continued growth through strong and growing statutory earnings, reinsurance programs, and unused debt capacity.
+Added: risk-based capital (“RBC”) ratio at or above our target of 400%.
F&G Dividend Distribution (the “separation and distribution”)
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FNF retained control of F&G through ownership of approximately 85% of F&G common stock.
−Removed: For additional information about risks to F&G related to the separation and distribution, please see “Risk Factors - Risks Related to the Separation and Distribution and our Status as a subsidiary of FNF.”
−Removed: Through a diversification growth strategy, F&G has demonstrated profitable, compound annual growth rates in gross sales of 50% and AUM of 23% for the four-year period 2019 to 2023 and, more recently, annual increases in gross sales of 17% and AUM of 14% for the year ended December 31, 2023 as compared to the year ended December 31, 2022.
−Removed: We have expanded our business in our traditional channels, and entered new markets.
−Removed: With this strategy, we will continue to deliver stable ROA, excluding short-term mark-to-market effects, driven by asset growth and increasing margins from scale as well as expansion into higher-margin, less capital-intensive products.
+Added: For additional information about risks to F&G related to our status as a subsidiary of FNF, please see “Risk Factors - Risks Related to the Separation and Distribution and our Status as a subsidiary of FNF.”
+Added: Through a diversified growth strategy, F&G has demonstrated profitable, compound annual growth rates in gross sales of 31% and AUM of 15% for the five-year period 2019 to 2024 and, more recently, annual increases in gross sales of 16% and AUM of 10% as of December 31, 2024 compared to the year ended December 31, 2023.
+Added: We have expanded our business in our traditional channel and entered new markets.
+Added: We are focused on delivering on our medium term financial targets laid out at our October 2023 Investor Day to grow assets, expand ROA and ROE, and increase our multiple as we grow our retail distribution, win our share of the healthy PRT pipeline, maintain spreads in any rate environment, benefit from demographic tailwinds, and diversify through our accretive flow reinsurance and owned distribution strategies, which set F&G apart.
We are positioned to accomplish our goals through the following areas of strategic focus:
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• Consistent track record of success.
−Removed: F&G’s deep and experienced management team has successfully diversified products and channels in recent years and demonstrated our ability to deliver consistent top line growth, increase assets under management and generate steady spreads and ROA, excluding short-term mark-to-market effects, across varying market cycles.
+Added: F&G’s deep and experienced management team has successfully diversified products and channels in recent years and demonstrated our ability to deliver consistent top line growth, increase assets under management and generate steady spreads and expand ROA, excluding short-term mark-to-market effects, across varying market cycles.
• Driving margin expansion and improved returns.
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retirement and middle markets are growing, and we are both well-established and well-positioned for continued growth.
−Removed: Our strategic alignment with our distribution
−Removed: partners allows us to reach a diverse, growing and underserved middle market demographic in both our retail and institutional channels.
+Added: Our strategic alignment with our distribution partners allows us to reach a diverse, growing and underserved middle market demographic in both our retail and institutional channels.
• Durable investment management edge.
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Approximately 93% of our $35.6 billion fixed indexed and fixed rate annuities account value are surrender-charge protected and our asset and liability cash flows are well matched.
+Added: Additionally, our funding agreements, pension risk transfer and immediate annuities are non-surrenderable.
• Track record of attracting top talent.
−Removed: F&G’s management team and nearly 1,200 employees have a record of long-term success and have delivered impressive results in the last few years.
+Added: F&G’s management team and over 1,300 employees have a record of long-term success and have delivered impressive results in the last few years.
Our commitment to our cultural values is the cornerstone of our success, whereby F&G is a company of individuals who believe in the power of partnerships, encourage innovation and creativity, and are transparent about decisions while delivering on their commitments.
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We Play in Large and Growing Markets
−Removed: We are in the midst of an age wave, with 10,000 Baby Boomers retiring each day through 2029.
−Removed: Today’s retirees face unique challenges:
−Removed: guaranteed income traditionally provided by pensions is going away, requiring many retirees to rely solely on their personal assets;
−Removed: for many, Social Security income is not enough.
−Removed: Today’s retirees must plan for a retirement that could last 25 to 30 years, weathering the ups and downs of the markets along the way.
−Removed: Insurance solutions can simplify retirement planning through features that generate more accumulation than traditional fixed income vehicles and generate more (and guaranteed) retirement income than traditional strategies.
−Removed: retirement market opportunity is vast and includes the $777 billion U.S.
+Added: We serve a market with very attractive demographic tailwinds as more than 10,000 Baby Boomers are retiring every day.
+Added: Demand for our fixed annuity products continues to grow as people plan for a retirement that could last approximately 30 years and are seeking solutions that can withstand market volatility.
+Added: Both retirees and advisors are turning to fixed annuities for simplicity, relatively higher interest rates, guaranteed tax deferred growth and principal protection, as an alternative to the traditional 60/40 investment portfolio.
+Added: retirement market opportunity is vast and includes the $1.1 trillion U.S.
consumer savings market and the $223 billion retail life and annuities market.
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In mid-2020, we expanded into the bank and broker-dealer channels to broaden our reach and capture share of the personal savings and CDs markets.
−Removed: Our entry into these channels was successful, resulting in $1 billion in new business within the first ten months.
−Removed: Annuity sales through the bank and broker dealer channels were $4.9 billion and $3.6 billion for the full year ended December 31, 2023 and 2022, respectively.
−Removed: The approximate 21 banks and broker dealers we work with account for 51% of all annuity sales.
+Added: Our entry into these channels was successful, resulting in $15.3 billion of cumulative new business since the launch in 2020 to year-end 2024.
+Added: In early 2024, we entered into the fast-growing RILA market and have successfully onboarded with seven banker dealer distribution partners.
+Added: We are focused on adding additional distribution partners and see the potential for RILA sales to ramp up over the medium term.
+Added: Annuity sales through the bank and broker-dealer channels were $5.0 billion and $4.9 billion for the years ended December 31, 2024 and 2023, respectively.
+Added: The approximate 22 banks and broker-dealers we
+Added: work with account for 42% of all annuity sales.
In these retail markets F&G ranks:
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(ii) 7th and 4th in MYGA sales in the broker-dealer and bank channels and 6th in MYGA industry sales;
−Removed: and (iii) 5th in IUL
−Removed: sales in the IMO channel, 3rd in the number of IUL policies sold and 6th in IUL industry sales, in each case, for the third quarter of 2023, as sourced from Wink’s Sales and Market Report.
+Added: and (iii) 5th in IUL sales in the IMO channel, 4th in the number of IUL policies sold and 6th in IUL industry sales, in each case, for the year to date as of September 30, 2024, as sourced from Wink’s Sales and Market Report.
We successfully expanded into new retail channels and diversified our annuity distribution, yet not at the expense of our traditional IMO channel.
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Since 2019, largely due to our NMG strategy, F&G’s IUL sales growth has far outpaced the industry, with a three-year combined annual growth rate of 46% compared to the industry’s 10%.
−Removed: This makes F&G the fastest growing IUL company of the top 20 IUL sellers in the market.
+Added: F&G’s growth rate in IUL has consistently placed us in the top 10 IUL sales ranking since 2021.
Untapped opportunities remain in this channel, particularly among younger and more diverse demographics.
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Owned Distribution.
−Removed: With industry consolidation of independent agent distribution underway, we believe we are uniquely positioned to partner as a distribution consolidator.
+Added: Our owned distribution strategy provides a diversified source of earnings while generating a meaningfully higher risk adjusted return on capital than retained business.
+Added: Owned distribution further strengthens our relationships with key partners and with industry consolidation underway, we believe we are uniquely positioned to partner as a distribution consolidator.
+Added: We have invested $680 million in owned distribution partners through the following transactions:
• In October 2021, we purchased a 30% minority ownership stake in Freedom Equity Group (“FEG”).
FEG is a nearly 4,000 agent strong NMG that focuses on cultural markets including Mexican-American, Hmong, Laotian, Filipino, Burmese, Congolese-American, Samoan, African-American, Thai and Vietnamese.
−Removed: We also purchased a 49% minority ownership stake in Syncis Holdings, LLC, an NMG, in January 2023.
+Added: • In January 2023, we purchased a 49% minority ownership stake in Syncis Holdings, LLC, an NMG.
Syncis is an approximately 1,200 agent NMG that focuses on cultural markets including Korean, African-American, and Persian.
−Removed: We continued to consolidate in the distribution space in 2023 with the purchase of a 30% minority ownership stake in Quility Holdings, LLC (“Quility”), a leading insurtech company that offers a frictionless experience for insurance agents, insurance distribution companies and the clients they serve, and the purchase of a 40% minority ownership stake in DCMT Worldwide, LLC (“DCMT”), who distributes life insurance and annuity products through a network of over 1,000 agents.
−Removed: In January 2024, we purchased a 70% majority ownership stake in Roar Joint Venture, LLC (“Roar”), a wholeseller of annuities and life insurance products to financial institutions and the broker-dealer community.
+Added: • In June 2023, we purchased a 40% minority ownership stake in DCMT Worldwide, LLC (“DCMT”), who distributes life insurance and annuity products through a network of over 1,000 agents.
+Added: • In January 2024, we purchased a 70% majority ownership stake in Roar Joint Venture, LLC (“Roar”), a wholesaler of annuities and life insurance products to financial institutions and the broker-dealer community.
+Added: • In July 2024, we acquired a 100% ownership stake in PALH, LLC (“PALH”), who owns a 100% ownership stake in an operating company.
+Added: PALH markets and sells life insurance and annuity products of various insurance carriers to individuals through a network of agents.
Institutional .
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Our FABN Program (the “FABN Program”) offers funding agreements to institutional clients by means of capital markets transactions through investment banks.
−Removed: Together, this business line has generated $2.3 billion in sales for F&G in 2021, its year of inception of FABN, $1.4 billion in sales for the year ended December 31, 2022, and $1.3 billion in sales for the year ended December 31, 2023.
−Removed: • We also offer PRT solutions to a $40 billion (of $2 trillion total defined benefit plan assets) market.
−Removed: We launched our PRT business by building an experienced team with access to brokers and institutional consultants for distribution.
+Added: This business line has generated $2.3 billion in sales for F&G in 2021, its year of inception of FABN, $1.4 billion in sales for the year ended
+Added: December 31, 2022, $1.3 billion in sales for the year ended December 31, 2023, and $1.0 billion in sales for the year ended December 31, 2024.
+Added: • We also offer PRT solutions to a $45 billion (of $3 trillion total private defined benefit plan assets) market.
+Added: Our PRT business is supported by an experienced team with access to brokers and institutional consultants for distribution.
+Added: We have generated over $7 billion of cumulative sales since launch in 2021 to year-end 2024 and now serve approximately 115,000 total participants, including beneficiaries, who will receive their pension payments from F&G.
+Added: Our targeted deal size is approximately $100 million to $1 billion, and we selectively pursue plan termination and larger retiree buyouts.
We expect our opportunity to continue to grow as employers shift away from traditional defined benefit pension plans and seek to de-risk frozen pension plans.
−Removed: This line of business generated $1.1 billion in sales for F&G in 2021, its year of inception, $1.4 billion in sales for the year ended December 31, 2022, and $2.0 billion in sales for the year ended December 31, 2023.
+Added: This line of business generated $1.1 billion in sales for F&G in 2021, its year of inception, $1.4 billion in sales for the year ended December 31, 2022, $2.0 billion in sales for the year ended December 31, 2023, and $2.2 billion in sales for the year ended December 31, 2024.
+Added: In the pension risk transfer market, F&G ranks as 8th in the PRT industry sales for the year to date as of September 30, 2024, as sourced from the Life Insurance Marketing and Research Association.
We Have Meaningfully Diversified Our Business
−Removed: With the addition of the retail bank and broker dealer channels and our success in entering the PRT and funding agreement institutional markets, F&G has diversified our product and distribution capabilities from one primary channel to now five, and from one primary product to now six with our recent entrance into the RILA markets.
−Removed: We completed this expansion over a four -year period and, combined with organic growth in our core IMO channel, increased gross sales by 238%, from $3.9 billion in 2019 to $13.2 billion in 2023.
+Added: With the addition of the retail bank and broker-dealer channels and our success in entering the PRT and funding agreement institutional markets, F&G has diversified our product and distribution capabilities from one primary channel to now five, and from one primary product to now six with our entrance into the RILA market in early 2024.
+Added: We completed this expansion over a five-year period and, combined with organic growth in our core IMO channel, increased gross sales by 292%, from $3.9 billion in 2019 to $15.3 billion in 2024.
We have reinforced our earnings engine in addition to driving top-line growth.
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Our competitive advantages – product and channel diversification, as well as our strategic partnership with Blackstone – enable us to address a greater share of the markets in which we play.
−Removed: Further, the strength of our distribution partner relationships and pension risk transfer growth strategy has allowed the Company to achieve profitable double digit sales growth.
+Added: Further, the strength of our distribution partner relationships and pension risk transfer growth strategy has enabled the Company to achieve profitable double digit sales growth.
The launch of our RILA product in early 2024 will further boost our sales growth as we enter a large and fast-growing market.
−Removed: We also expect to deliver ongoing margin expansion from enhanced investment margin opportunities, effectively managing our operating expenses while scaling our organization over time and driving fee-based earnings from accretive flow reinsurance.
−Removed: Lastly, we continue to diversify and enhance our earnings power as we execute on our own distribution strategy.
−Removed: Our ownership stakes generate a higher margin earnings stream at a lower cost of capital, which we expect to be accretive to our returns over time.
+Added: We have made good progress toward the medium term financial targets we laid out at our 2023 Investor Day as we focus on driving sustainable asset growth from our retail and pension risk transfer growth strategies, generating ROA expansion from enhanced investment margin, scale benefits and fee-based earnings from accretive flow reinsurance, and diversifying earnings through strong growth in our middle market life insurance business and owned distribution strategies.
The Products We Offer
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We believe this principal protection fills the need for middle-income Americans who must save for retirement but who want to limit the risk of decline in their savings.
−Removed: As noted above, in 2021, we launched into two institutional markets to originate FABN and PRT transactions.
+Added: As noted above, in 2021, we launched into two institutional markets to originate FABN and PRT
+Added: transactions.
These markets leverage our existing team's spread-based capabilities as well as our strategic partnership with Blackstone.
For the year ended December 31, 2024, FIAs generated approximately 44% of our gross sales.
−Removed: The remaining 64% of sales were primarily generated from fixed rate annuities (39%), funding agreements (9%), PRT sales (15%) and IUL (1%).
+Added: The remaining 56% of sales were primarily generated from fixed rate annuities (33%), PRT sales (15%), funding agreements (7%) and IUL (1%).
We invest the proceeds primarily in fixed income securities.
We also use options and futures that hedge the index credit of our FIA and IUL liabilities by replicating the market index returns to our policyholders.
−Removed: We invest predominantly in options on the S&P 500 Index.
+Added: We invest in options on indices such as the S&P 500 Index.
The majority of our products allow for active management to achieve targeted lifetime returns.
In addition, our annuity contracts generally either cannot be surrendered or include surrender charges that discourage early redemptions.
−Removed: Through F&G’s insurance subsidiaries, we issue a broad portfolio of deferred annuities (FIA and fixed rate annuities), immediate annuities, and PRT solutions.
+Added: Through F&G’s insurance subsidiaries, we issue a broad portfolio of deferred annuities (indexed annuities and fixed rate annuities), immediate annuities, and PRT solutions.
A deferred annuity is a type of contract that accumulates value on a tax deferred basis and typically begins making specified periodic or lump sum payments a certain number of years after the contract has been issued.
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Deferred Annuities – FIAs .
−Removed: Our FIAs allow contract owners the possibility of earning returns linked to the performance of a specified market index, predominantly the S&P 500 Index, while providing principal protection.
+Added: Our FIAs allow contract owners the possibility of earning returns linked to the performance of a specified market index, such as the S&P 500 Index, while providing principal protection.
The contract owners typically make a single deposit into our deferred annuities.
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Surrender charges apply for early withdrawal, typically for seven to fourteen years after purchase.
−Removed: We purchase derivatives consisting predominantly of over-the-counter options and, to a lesser degree, futures contracts (specifically for FIA contracts) on the equity indices underlying the applicable policy such as the S&P 500.
+Added: We purchase derivatives consisting predominantly of over-the-counter options and, to a lesser degree, futures contracts (specifically for FIA contracts) on the equity indices underlying the applicable policy such as the S&P 500 Index.
These derivatives are used to fund the index credits due to policyholders under the FIA and IUL contracts based upon policyholders’ contract elections.
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The cost of the hedge is included in the pricing of the product and can be reset on an annual basis for each policy based on market conditions.
−Removed: The majority of all such call options are one-year options purchased to match the funding requirements underlying the FIA/IUL contracts.
+Added: The majority of all such equity options are one-year options purchased to match the funding requirements underlying the FIA/IUL contracts.
On the anniversary dates of the FIA/IUL contracts, the market index used to compute the annual index credit under the contracts is reset.
−Removed: At such time, we purchase new call options to fund the next index credit.
+Added: At such time, we purchase new equity options to fund the next index credit.
We manage the cost of these purchases through the terms of our FIA/IUL contracts, which permit us to change caps or participation rates, subject to certain guaranteed minimums on each contract’s anniversary date.
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Generally accepted accounting principles (“GAAP”) accounting of the reserve liability for products with embedded derivatives such as FIA creates additional volatility beyond the accounting for the options and the futures.
−Removed: The contract holder account value of a FIA contract is equal to the sum of deposits paid, premium bonuses, if any, (described below), and index credits based on the change in the relevant market index (subject to a cap, spread and/or a participation rate) less any fees for riders and any withdrawals taken to-date.
−Removed: Caps (a maximum rate that may be credited) generally range from 1% to 5% when measured annually and 1% to 3% when measured monthly, spreads (a credited rate determined by deducting a specific rate from the index return) generally range from 0% to 3% when measured annually, and participation rates (a credited rate equal to a percentage of index return) generally range from 100% to 180% of the performance of the applicable market index.
+Added: The contractholder account value of a FIA contract is equal to the sum of deposits paid, premium bonuses, if any, (described below), and index credits based on the change in the relevant market index (subject to a cap, spread and/or a participation rate) less any fees for riders and any withdrawals taken to-date.
+Added: Caps (a maximum rate that may be credited) generally range from 1% to 10% when measured annually and 1% to 3% when measured monthly, spreads (a credited rate determined by deducting a specific rate from the index return) generally range from 1% to 3% when measured annually, and participation rates (a credited rate equal to a percentage of index return) generally
+Added: range from 50% to 250% of the performance of the applicable market index.
The cap, spread and participation rate can typically be reset annually and in some instances every two to five years.
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Guaranteed withdrawal payments may be stopped and restarted at the election of the contract owner.
−Removed: Some of the FIA contract riders that we offer include an additional death benefit or an increase in benefit amounts under chronic
−Removed: health conditions.
+Added: Some of the FIA contract riders that we offer include an additional death benefit or an increase in benefit amounts under chronic health conditions.
Rider fees range from 0% to 1%.
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The average crediting rate on all outstanding fixed rate annuities at December 31, 2024 was 5%.
−Removed: Deferred Annuities - Registered Index-Linked Annuities (“RILA”) – In early 2024, we entered into the RILA markets.
+Added: Deferred Annuities - RILA – In early 2024, we entered into the RILA markets.
RILAs are similar to FIAs in offering the policyholder the opportunity for tax-deferred growth based in part on the performance of a market index.
−Removed: Compared to an FIA, RILAs have the potential for higher returns but also have the potential for risk of loss to principal and related earnings.
+Added: Compared to a FIA, RILAs have the potential for higher returns but also have the potential for risk of loss to principal and related earnings.
RILAs provide the ability for the policyholder to participate in the positive performance of certain market indices during a term, limited by a cap or adjusted for a participation rate.
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A market value adjustment (“MVA”) will also apply in most states to any withdrawal that incurs a surrender charge, subject to certain exceptions.
−Removed: The MVA is based on a formula that accounts for changes in interest rates since contract issuance.
+Added: The MVA is based on a
+Added: formula that accounts for changes in interest rates since contract issuance.
Generally, if interest rates have risen, the MVA will decrease surrender value, whereas if rates have fallen, it will increase surrender value.
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The following table summarizes our deferred annuity account values and surrender charge protection as of December 31, 2024 (dollars in millions):
−Removed: SURRENDER CHARGE EXPIRATION BY YEAR Fixed Rate and Fixed Indexed Annuities Account Value Percent of Total Weighted Average Surrender Charge
+Added: SURRENDER CHARGE EXPIRATION BY YEAR Fixed Rate and Indexed Annuities Account Value Percent of Total Weighted Average Surrender Charge
Out of surrender charge $ 2,427 7 % — %
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The balance of the cash value account is credited interest at a fixed rate or returns based on the performance of a market index, or both, at the option of the policyholder, using a method similar to that described above for FIAs.
+Added: In addition to the annual renewal premium, we are diversifying earnings through strong growth in our middle market life insurance business.
Funding Agreements.
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Funding agreements through the FHLB are flexible in their format and the ability to issue during broad windows, as long as sufficient eligible collateral has been deposited with the bank.
−Removed: F&G and it’s predecessors have been entering into funding agreements with the FHLB since at least 2004.
+Added: F&G and its predecessors have been entering into funding agreements with the FHLB since at least 2004.
In June 2021, we established a FABN Program, which is a medium term note program under which funding agreements are issued to a special-purpose trust that issues marketable notes.
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These products primarily create earnings through spread income.
−Removed: In each transaction FGL Insurance and/or FGL NY Insurance issues a group annuity contract to discharge pension plan liabilities from a pension plan sponsor, either through a separate account or through a general account
+Added: In each transaction FGL Insurance and/or FGL NY Insurance issues a group annuity contract to discharge pension plan liabilities from a pension plan sponsor, either through a separate account or through a general account guarantee.
Certificate holders covered under a group annuity contract have a guaranteed benefit from the insurance company.
−Removed: We entered the PRT solutions business by building a team of experienced professionals, then working with brokers and institutional consultants for distribution.
−Removed: As of December 31, 2023, we had completed PRT transactions that represented pension obligations of $4.5 billion.
+Added: Our PRT solutions business is supported by a team of experienced professionals, and we partner with brokers and institutional consultants for distribution.
+Added: As of December 31, 2024, we had completed cumulative PRT transactions that represented pension obligations of $7.0 billion.
Reinsurance philosophy/arrangements.
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Hannover Reinsurance Transaction.
−Removed: Originally effective January 1, 2017, FGL Insurance has a reinsurance agreement with Hannover Life Reassurance Company of America (“Hannover Re”), an unaffiliated reinsurer, to reinsure an in-force block of FGL Insurance’s FIA and fixed rate deferred annuity contracts with GMWB and Guaranteed Minimum Death Benefit (“GMDB”) guarantees.
+Added: Originally effective January 1, 2017, FGL Insurance has a reinsurance agreement with Hannover Life Reassurance Company of America, an unaffiliated reinsurer, to reinsure an in-force block of FGL Insurance’s FIA and fixed rate deferred annuity contracts with GMWB and Guaranteed Minimum Death Benefit (“GMDB”) guarantees.
In accordance with the terms of this agreement, FGL Insurance cedes 70% net retention of secondary guarantee payments in excess of account value for GMWB and death benefits in excess of account value for GMDB guarantees.
3 unchanged sentences
FGL Insurance has a reinsurance agreement with Kubera Insurance (SAC) Ltd.
−Removed: (“Kubera”), an unaffiliated reinsurer, to cede a quota share of certain FIA statutory reserves on a coinsurance funds withheld basis, net of applicable existing reinsurance.
+Added: (“Kubera”), an unaffiliated reinsurer, to cede certain FIA statutory reserves on a coinsurance funds withheld quota share basis, net of applicable existing reinsurance.
+Added: This agreement has been amended several times to include additional FIA policies, with the latest amendment effective December 1, 2024.
The effects of this agreement are not accounted for as reinsurance as it does not satisfy the risk transfer requirements for GAAP;
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As the policies ceded to Somerset are investment contracts, there is no significant insurance risk present and the reinsurance agreements are accounted for as separate investment contracts.
+Added: Effective July 1, 2024, FGL Insurance amended the existing flow reinsurance agreement with Somerset to additionally cede the base contract benefits and GMWB riders attached under certain FIA policies on a coinsurance funds withheld quota share basis written on or after July 1, 2024.
+Added: As the base contract benefits and GWMB riders are ceded to Somerset, there is sufficient insurance risk present that results in this portion of the reinsurance agreement being accounted for as reinsurance.
Everlake Reinsurance Transaction.
Effective September 1, 2023, FGL Insurance executed a coinsurance agreement with Everlake Life Insurance Company (“Everlake”), an unaffiliated reinsurer to cede, on a quota share basis, certain flow MYGA business written effective on or after September 1, 2023.
−Removed: As the policies ceded to Everlake are investment contracts, there is no significant insurance risk present and the effects of this agreement are accounted for as a separate investment contract.
+Added: As the policies ceded to Everlake are investment contracts, there is no significant insurance risk present and therefore the reinsurance agreement is accounted for as a separate investment contract.
+Added: Effective January 1, 2025, F&G amended the existing flow reinsurance agreement with Everlake Life Insurance Company (“Everlake”) to cede future additional MYGA business for agreed upon periods to Everlake pursuant to an offer and acceptance process, rather than on a flow basis.
+Added: The amendment included a cession of an inforce block of certain MYGA policies on a coinsurance quota share basis.
Aspida Reinsurance Transaction.
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The industry has reduced or eliminated redundancies thereby increasing capital using a variety of techniques including reserve facilities.
−Removed: F&G has a reinsurance treaty with Raven Reinsurance Company (“Raven Re”), its wholly owned captive reinsurance company, to cede the Commissioners Annuity Reserve Valuation Method (“CARVM”) liability for annuity benefits where surrender charges are waived related to certain FIA, DA and MYGA policies.
+Added: FGL Insurance has a reinsurance treaty with Raven Reinsurance Company (“Raven Re”), its wholly owned captive reinsurance company, to cede the Commissioners Annuity Reserve Valuation Method (“CARVM”) liability for annuity benefits where surrender charges are waived related to certain FIA, deferred annuity and MYGA policies.
In connection with the CARVM reinsurance agreement, FGL Insurance and Raven Re entered into an agreement with Nomura Bank International plc (“NBI”) to establish a reserve financing facility in the form of a letter of credit issued by NBI.
The financing facility has $175 million available to draw on as of December 31, 2024.
−Removed: The amended facility may terminate earlier than the current termination date of October 1, 2027, in accordance with the terms of the
−Removed: reimbursement agreement.
−Removed: Under the terms of the reimbursement agreement, in the event the letter of credit is drawn upon, Raven Re is required to repay the amounts utilized, and FGAL is obligated to repay the amounts utilized if Raven Re fails to make the required reimbursement.
+Added: The amended facility may terminate earlier than the current termination date of October 1, 2027, in accordance with the terms of the reimbursement agreement.
+Added: Under the terms of the reimbursement agreement, in the event the letter of credit is drawn upon, Raven Re is required to repay the amounts utilized, and F&G Annuities & Life, Inc.
+Added: (“FGAL”) is obligated to repay the amounts utilized if Raven Re fails to make the required reimbursement.
Under the terms of the agreement, FGAL is also required to make a capital contribution to Raven Re in certain circumstances, including in the event that Raven Re’s statutory capital and surplus falls below defined levels.
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In accordance with the terms of this agreement, FGL Insurance cedes a quota share of GMWB and GWP paid in excess of account value.
−Removed: In connection with the reinsurance agreement between FGL Insurance and Corbeau Re, Corbeau Re entered into an excess of loss reinsurance agreement (“XOL”) with Canada Life Barbados Branch to finance the portion of statutory reserves considered to be non-economic.
+Added: In connection with the reinsurance agreement between FGL
+Added: Insurance and Corbeau Re, Corbeau Re entered into an excess of loss reinsurance agreement (“XOL”) with Canada Life Barbados Branch to finance the portion of statutory reserves considered to be non-economic.
The XOL matures on December 31, 2043, and provides for coverage on losses up to $1,500 million as of December 31, 2024.
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We monitor the business issued by each distribution partner for pricing metrics, mortality, persistency, as well as market conduct and suitability.
−Removed: We offer our products through a network of approximately 280 IMOs, representing nearly 102,000 agents.
+Added: We offer our products through a network of approximately 300 IMOs, representing approximately 126,000 agents.
We believe that our relationships with these IMOs are strong.
−Removed: The average tenure of the Power Partners is approximately 20 years.
We identify Power Partners as those who have demonstrated the ability to generate significant production for our business.
We currently have 41 Power Partners, comprised of 19 annuity IMOs and 22 life insurance IMOs.
+Added: The average tenure of the Power Partners is approximately 21 years.
We took a similar approach in launching products as a new entrant into the bank and broker-dealer channels by partnering with one of the largest broker-dealers in the industry.
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We employ a hybrid distribution model in this channel, whereby some financial institutions partner directly with F&G and our sales team, and others work with an intermediary.
−Removed: As such, we partner with a select number of financial institution intermediaries who have expertise in the channel and maintain the appropriate field wholesaling forces to be successful in this channel.
+Added: As such, we partner
+Added: with a select number of financial institution intermediaries who have expertise in the channel and maintain the appropriate field wholesaling forces to be successful in this channel.
In 2024, the top 5 firms represented 77% of channel sales.
Bank and broker-dealers represented 42% of annuity sales for the year ended December 31, 2024.
−Removed: The top five states for the distribution of F&G’s retail products in the year ended December 31, 2023 were Florida, California, Pennsylvania, Ohio and Texas, which together accounted for 38.5% of F&G’s retail sales.
+Added: The top five states for the distribution of F&G’s retail products in the year ended December 31, 2024 were Florida, California, Pennsylvania, Texas and Ohio, which together accounted for 38.7% of F&G’s retail sales.
Our Investment Management Governance and Approach
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The types of assets in which we may invest are influenced by various state laws, which prescribe qualified investment assets applicable to insurance companies.
−Removed: FGL Insurance and certain other subsidiaries of F&G (other than FGL NY Insurance) are party to investment management agreements (“IMAs”) with Blackstone ISG-I Advisors LLC (“BIS”) pursuant to which BIS is appointed as investment manager of substantially all assets in the general and separate accounts of those entities (the “F&G Accounts”).
+Added: FGL Insurance and certain other subsidiaries of F&G are party to investment management agreements (“IMAs”) with Blackstone ISG-I Advisors LLC (“BIS”) pursuant to which BIS is appointed as investment manager of substantially all assets in the general and separate accounts of those entities (the “F&G Accounts”).
+Added: Effective October 1, 2024, FGL Insurance amended and restated its IMA with BIS to increase a fee cap from 26 basis points to 30 basis points.
+Added: This increase did not change the overall economics of the IMA as it was not material in nature.
MVB Management, LLC, (“MVB Management”), an entity that is 50% owned by BilCar, LLC (an affiliate of William Foley, the Executive Chairman and a director of the Company) (“BilCar”), receives a participation fee from BIS in connection with assets of F&G and its subsidiaries that are managed by BIS.
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• for aggregate assets under management in the F&G Accounts above $34 billion, .12% of such aggregate assets under management.
−Removed: In addition, the Sub-Manager Fee Agreement has been amended to provide for certain updates thereto, including, among other things, to reflect certain additional asset classes, certain revisions to the applicable sub-manager fee rates in respect of certain existing asset classes and certain revisions to the applicable sub-manager fee rates in respect of assets under management relating to new business of the Company and its subsidiaries generated after March 31, 2023.
+Added: In addition, the Sub-Manager Fee Agreement has been amended to provide for certain updates thereto, including, among other things, to reflect certain additional asset classes, certain revisions to the applicable sub-manager fee rates in respect of certain existing asset classes and certain revisions to the applicable sub-manager fee
+Added: rates in respect of assets under management relating to new business of the Company and its subsidiaries generated after March 31, 2023.
For the avoidance of doubt, there will be no management fee payable under the IMAs with respect to New AUM.
Aggregate fees paid to BIS were $203 million, $194 million and $155 million for the years ended December 31, 2024, 2023 and 2022, respectively.
+Added: Effective January 1, 2025, FGL NY Insurance and BIS entered into an IMA pursuant to which BIS is appointed as investment manager of substantially all assets in the general account of FGL NY Insurance .
+Added: FGL NY Insurance terminated its current IMA with its current investment manager effective December 31, 2024.
+Added: There are no separate agreements or arrangements between BIS or its affiliates, on the one hand, and FGL NY Insurance or its affiliates, on the other hand, concerning the IMA between BIS and FGL NY Insurance.
F&G has a robust governance process and framework to manage the investment portfolio.
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However, F&G and FNF are party to an omnibus termination side letter under which they are required to cause our insurance subsidiaries to engage BIS as an investment manager and to generally not engage any other person as an investment manager.
−Removed: See also “ Risk Factors—Risks Relating to Our Business—We rely on our investment management or advisory agreements with BIS and other investment managers and sub-managers for the management of portions of certain of our life insurance companies’ investment portfolios.”
+Added: See also “Risk Factors—Risks Relating to Our Business— We rely on our investment management advisory agreements with BIS and other investment managers and sub-managers for the management of portions of certain of our life insurance companies’ investment portfolios.”
The initial term of the side letter expires in 2029 and will automatically renew for successive two-year terms unless F&G terminates the side letter.
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If we provide any such notice, the termination would not become effective for one year from the date of termination given in the notice, during which time BIS may seek to cure the events giving arise to the termination notice.
−Removed: Because our subsidiaries can terminate an investment management agreement at any time upon 30 days' notice, it is possible that such a termination by one of our subsidiaries could cause us to be in breach of our obligations
−Removed: under the side letter.
+Added: Because our subsidiaries can terminate an investment management agreement at any time upon 30 days' notice, it is possible that such a termination by one of our subsidiaries could cause us to be in breach of our obligations under the side letter.
BIS’s contractual remedies under the side letter include specific performance and the right to seek damages including, in the event of a non-permitted termination of an investment management agreement by one of our subsidiaries, as compensation for the costs incurred in performing services under, and the failure to receive the benefits reasonably anticipated by, an IMA, the full amount of damages available at law in the same manner and to the same extent as if such IMA had been terminated by us our at our direction in violation of the terms of the side letter.
−Removed: Our investment portfolio consists of fixed-rate high-quality fixed maturities, including publicly and privately issued corporate bonds, municipal and other government bonds, asset-backed securities (“ABS”), residential mortgage-backed securities (“RMBS”), commercial mortgage-backed securities (“CMBS”), commercial mortgage loans (“CMLs”), residential mortgage loans (“RMLs”), limited partnership investments, and other investments.
−Removed: We also maintain holdings in floating rate, and less rate-sensitive investments, including collateralized loan obligations (“CLO”), non-agency RMBS, and various types of ABS.
+Added: Our investment portfolio consists of fixed-rate high-quality fixed maturities, including publicly and privately issued corporate bonds, municipal and other government bonds, asset-backed securities (“ABS”), residential mortgage-backed securities (“RMBS”), commercial mortgage-backed securities, commercial mortgage loans (“CMLs”), residential mortgage loans (“RMLs”), limited partnership investments, and other investments.
+Added: We also maintain holdings in floating rate, and less rate-sensitive investments, including CLOs, non-agency RMBS, and various types of ABS.
It is our expectation that our investment portfolio will broaden in scope and diversity to include other asset classes held by life and annuity insurance writers.
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dollar denominated emerging market bonds, highly rated preferred stocks and hybrids.
−Removed: We currently maintain a well-matched asset/liability profile (asset duration, including cash and cash equivalents, of 5.2 years vs.
+Added: We currently maintain a well-matched asset/liability profile (asset duration of 4.9 years vs.
liability duration of 5.8 years).
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These include investment limits by asset class, ratings and issuer.
−Removed: Liquidity risk is managed
−Removed: through frequent forecasting of sources and uses of cash and managed to our Liquidity Policy.
+Added: Liquidity risk is managed through frequent forecasting of sources and uses of cash and managed to our Liquidity Policy.
Asset liability management procedures and limits protect the Company, within limits, against significant changes in interest rates.
2 unchanged sentences
The responsibility for monitoring, evaluating and responding to risk embedded across the organization:
−Removed: first assigned to our management and employees, second to those occupying specialist functions, such as legal compliance and risk teams, and third to those occupying supervisory functions, such as internal audit and the board of directors.
+Added: first assigned to our management and employees, second to those occupying specialist functions, such as legal compliance and risk teams, and third to those occupying supervisory functions, such as internal audit and the Board.
Operations/Outsourcing
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Generally, rating agencies base their financial strength ratings upon information furnished to them by the insurer and upon their own investigations, studies and assumptions.
−Removed: strength ratings are based upon factors of concern to policyholders, agents and intermediaries and are not directed toward the protection of investors.
+Added: Financial strength ratings are based upon factors of concern to policyholders, agents and intermediaries and are not directed toward the protection of investors.
Credit and financial strength ratings are not recommendations to buy, sell or hold securities and they may be revised or revoked at any time at the sole discretion of the rating organization.
4 unchanged sentences
Outlooks should not be confused with expected stability of the issuer’s financial or economic performance.
−Removed: A rating may have a “stable” outlook to indicate that the rating is not expected to change, but a “stable” outlook does not preclude a rating agency from changing a rating at any time without notice.
+Added: A rating may have a
+Added: “stable” outlook to indicate that the rating is not expected to change, but a “stable” outlook does not preclude a rating agency from changing a rating at any time without notice.
The rating organizations may take various actions, positive or negative.
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F&G Annuities & Life, Inc.
−Removed: Issuer Credit / Default Rating Not Rated BBB- BBB Ba1
+Added: Issuer Credit / Default Rating Not Rated BBB- BBB Baa3
Outlook Stable Stable Stable
−Removed: Senior Unsecured Notes Not Rated BBB- BBB- Not Rated
+Added: Senior Unsecured Notes Not Rated BBB- BBB- Baa3
+Added: Junior Subordinated Notes (a)
+Added: Not Rated BB BB Ba1
CF Bermuda Holdings Limited
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Outlook Stable Stable Stable
−Removed: Senior Unsecured Notes (2025 maturity) (a)
−Removed: BBB BBB BBB Baa2
−Removed: Outlook Stable Stable
Operating Subsidiary Ratings
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Outlook Stable
−Removed: (a) Explicitly guaranteed by parent Fidelity National Financial, Inc.
−Removed: upon acquisition of F&G on June 1, 2020
+Added: (a) Reflects rating of $375 million Junior Subordinated Notes due 2065 issued in January 2025
+Added: (b) Ratings removed for Fidelity & Guaranty Life Holdings, Inc.
+Added: Senior Unsecured Notes due 2025 following full redemption in February 2025
Best, S&P, Fitch and Moody’s review their ratings of insurance companies from time to time.
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Potential Impact of a Ratings Downgrade.
−Removed: We are required to maintain minimum ratings as a matter of routine practice as part of our over-the-counter derivatives agreements on International Swap and Derivative Association
−Removed: (“ISDA”) forms.
+Added: We are required to maintain minimum ratings as a matter of routine practice as part of our over-the-counter derivatives agreements on International Swap and Derivative Association (“ISDA”) forms.
Under some ISDA agreements, we have agreed to maintain certain financial strength ratings.
1 unchanged sentence
If the insurance subsidiaries held net short positions against a counterparty, and the subsidiaries’ financial strength ratings were below the levels required in the ISDA agreement with the counterparty, the counterparty would demand immediate further collateralization, which could negatively impact overall liquidity.
−Removed: Based on the fair value of our derivatives as of December 31, 2023, we hold no net short positions against a counterparty;
−Removed: therefore, there is currently no potential exposure for us to post collateral.
+Added: Based on the fair value
+Added: of our derivatives as of December 31, 2024, we hold no net short positions against a counterparty;
+Added: therefore, we were not required to post collateral at December 31, 2024.
A downgrade of the financial strength rating of one of our principal insurance subsidiaries could affect our competitive position in the insurance industry and make it more difficult for us to market our products, as potential customers may select companies with higher financial strength ratings.
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State insurance departments also have the authority to conduct examinations of non-domiciliary insurers that are licensed in their states.
−Removed: The IID last completed a routine examination of FGL Insurance for the five year period ending 2017 and found no material deficiencies and proposed no adjustments to the financial statements as filed.
−Removed: The IID is currently in the process of executing an exam for the five year period ending 2022.
−Removed: Results of the most recent examination have not been finalized.
+Added: The IID last completed a routine financial examination of FGL Insurance for the five year period ending 2022 and found no material deficiencies and proposed no adjustments to the financial statements as filed.
+Added: The IID is currently in the process of executing a market conduct exam for the five year period ending 2022.
+Added: Results of the most recent market conduct exam have not been finalized.
The NYDFS last completed a routine financial examination of FGL NY Insurance for the five year period ended December 31, 2017, and found no material deficiencies and proposed no adjustments to the financial statements as filed.
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The Vermont Department of Financial Regulation completed a routine financial examination of Raven Re for the five year period ending December 31, 2022, and found no material deficiencies and proposed no adjustments to the financial statements as filed.
−Removed: An examination for the five year period ending 2022 will be executed during the 2024 calendar year.
Dividend and Other Distribution Payment Limitations
The insurance laws of Iowa and New York regulate the amount of dividends that may be paid in any year by FGL Insurance and FGL NY Insurance, respectively.
−Removed: Pursuant to Iowa insurance law, ordinary dividends are payments, together with all other such payments within the preceding twelve months, that do not exceed the greater of (i) 10% of FGL Insurance’s statutory surplus as regards policyholders as of December 31 of the preceding year;
−Removed: or (ii) the net gain from operations of FGL Insurance (excluding realized capital gains) for the 12-month period ending December 31 of the preceding year.
−Removed: Dividends in excess of FGL Insurance’s ordinary dividend capacity are referred to as extraordinary and require prior approval of the Iowa Insurance Commissioner.
−Removed: In deciding whether to approve a request to pay an extraordinary dividend, Iowa insurance law requires the Iowa Insurance Commissioner to consider the effect of the dividend payment on FGL Insurance’s surplus and financial condition generally and whether the payment of the dividend will cause FGL Insurance to fail to meet its required U.S.
−Removed: FGL Insurance may only pay dividends out of statutory earned surplus.
−Removed: In 2023, FGL Insurance did not pay extraordinary dividends to FGLH.
−Removed: FGL Insurance’s maximum ordinary dividend capacity for 2024 is $0.
+Added: FGL Insurance dividends are paid as declared by its Board of Directors.
+Added: Pursuant to Iowa insurance law, any proposed payment of a dividend is classified as an “extraordinary dividend” if it, together with the aggregate fair market value of other dividends or distributions made during the preceding twelve months, exceeds the greater of (i) 10% of capital and surplus as of the preceding December 31 or (ii) net gain from operations before realized capital gains or losses for twelve month period ending December 31 of the preceding year.
+Added: No extraordinary dividends may be paid without prior approval of the IID.
+Added: In addition, no ordinary dividends may be paid except from the earned profits arising from FGL Insurance’s business, which does not include contributed capital or contributed surplus.
+Added: In 2024, FGL Insurance did not pay dividends to Fidelity & Guaranty Life Holdings, Inc.
+Added: Pursuant to the limitations described above, it is estimated that FGL Insurance’s maximum ordinary dividend capacity for 2025 is $0.
Any payment of dividends by FGL Insurance is subject to the regulatory restrictions described above and the approval of such payment by the board of directors of FGL Insurance, which must consider various factors, including general economic and business conditions, tax considerations, FGL Insurance’s strategic plans, financial results and condition, FGL Insurance’s expansion plans, any contractual, legal or regulatory restrictions on the payment of dividends and its effect on RBC and such other factors the board of directors of FGL Insurance considers relevant.
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Insurers that have less statutory capital than the RBC calculation requires are considered to have inadequate capital and are subject to varying degrees of regulatory action depending upon the level of capital inadequacy.
−Removed: As of the most recent annual statutory financial statements
−Removed: filed with insurance regulators, the RBC ratios for FGL Insurance and FGL NY Insurance each exceeded the minimum RBC requirements.
+Added: As of the most recent annual statutory financial statements filed with insurance regulators, the RBC ratios for FGL Insurance and FGL NY Insurance each exceeded the minimum RBC requirements.
It is desirable to maintain an RBC ratio in excess of the minimum requirements in order to maintain or improve financial strength ratings.
FGL Insurance’s estimated U.S.
−Removed: RBC ratio was approximately 451% as of December 31, 2023.
+Added: RBC ratio was over 410% as of December 31, 2024, above our 400% target.
See “Risk Factors — Risks Related to Our Business — A financial strength ratings downgrade, potential downgrade, or any other negative action by a rating agency could increase our cost of capital, making it challenging to grow our business, and could hinder our ability to participate in certain market segments, thereby adversely affecting our results of operations and our financial condition ” in this Annual Report on Form 10-K.
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In many cases, it is not unusual for financially sound companies to have one or more ratios that fall outside the usual range.
−Removed: Insurance companies generally submit data annually to the NAIC, which in turn analyzes the data using prescribed financial data ratios, each with defined “usual ranges”.
−Removed: Generally, regulators will begin to investigate or monitor an insurance company if its ratios fall outside the usual ranges for four or more of the ratios.
+Added: Insurance companies generally submit data annually to the NAIC, which in turn analyzes the data using prescribed financial data ratios, each with defined “usual ranges.” Generally, regulators will begin to investigate or monitor an insurance company if its ratios fall outside the usual ranges for four or more of the ratios.
IRIS consists of a statistical phase and an analytical phase whereby financial examiners review insurers’ annual statements and financial ratios.
1 unchanged sentence
each ratio has a “usual range” of results.
−Removed: As of December 31, 2023, FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re had four , one, two and three ratios outside the usual range, respectively.
−Removed: The IRIS ratios for net income to total income (including realized capital gains and losses), total affiliated investments to capital and surplus, change in premium and change in product mix for FGL Insurance were outside the usual range.
−Removed: The IRIS ratio for change in reserving ratio for FGL NY Insurance was outside the usual range.
+Added: As of December 31, 2024, FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re had five, one, two and four ratios outside the usual range, respectively.
+Added: The IRIS ratios for net and gross change to capital and surplus, total affiliated investments to capital and surplus, surplus relief - over $5 million capital and surplus and change in premium for FGL Insurance were outside the usual range.
+Added: The IRIS ratio for change in premium ratio for FGL NY Insurance was outside the usual range.
The IRIS ratios for adequacy of investment income and change in premium for Raven Re were outside the usual range.
−Removed: The IRIS ratios for net income to total income (including realized capital gains and losses), adequacy of investment income and surplus relief - Over $5 million capital and surplus for Corbeau Re were outside the usual range.
+Added: The IRIS ratios for net income to total income (including realized capital gains and losses), adequacy of investment income, change in premium and change in asset mix for Corbeau Re were outside the usual range.
In all instances in prior years, regulators have been satisfied upon follow-up that no regulatory action was required.
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Following the implementation of principle-based reserving for life insurance products, the NAIC is now developing a principle-based reserving framework for fixed annuity products.
−Removed: The respective appointed actuaries for FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re must each submit an opinion on an annual basis that their respective reserves, when
−Removed: considered in light of the respective assets FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re hold with respect to those reserves, make adequate provision for the contractual obligations and related expenses of FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re.
+Added: The respective appointed actuaries for FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re must each submit an opinion on an annual basis that their respective reserves, when considered in light of the respective assets FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re hold with respect to those reserves, make adequate provision for the contractual obligations and related expenses of FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re.
FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re have filed all of the required opinions with the insurance departments in the states in which they do business.
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In addition, investors deemed to have a direct or indirect controlling interest are required to make regulatory filings and respond to regulatory inquiries.
−Removed: Under most states’ statutes, including those of Iowa and New York, acquiring 10% or more of the voting stock of an insurance company or its parent company is presumptively
−Removed: considered a change of control, although such presumption may be rebutted.
+Added: Under most states’ statutes, including those of Iowa and New York, acquiring 10% or more of the voting stock of an insurance company or its parent company is presumptively considered a change of control, although such presumption may be rebutted.
In addition, the insurance laws of Iowa and New York permit a determination of control in circumstances where the thresholds for the presumption of control have not been crossed.
−Removed: Similar laws apply to a direct or indirect change of ownership of Raven Re and Corbeau Re.
+Added: Similar laws apply to a direct or indirect change of ownership of Raven Re and
Any person who is deemed to acquire control over F&G, FNF, FGL US Holdings, CF Bermuda, FGLH, FGL Insurance, FGL NY Insurance, Raven Re, Corbeau Re or certain of their affiliates including any person who acquires 10% or more of our or FNF’s voting securities of FGL Insurance, FGL NY Insurance or certain of their affiliates, without the prior approval of the insurance regulators of Iowa and New York, will be in violation of those states’ laws and may be subject to injunctive action requiring the disposition or seizure of those securities by the relevant insurance regulator or prohibiting the voting of those securities and to other actions determined by the relevant insurance regulator.
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See “Risk Factors — Risks Related to Our Business — Increased regulation or scrutiny of alternative investment advisers, arrangements with such investment advisers and investment activities may affect BIS’s or, if engaged, any other asset manager’s ability to manage our investment portfolio or impact of the reputation of our business” in this Annual Report on Form 10-K.
−Removed: On December 7, 2021, the NAIC assigned to its Macroprudential Working Group, the evaluation of a list of “Regulatory Considerations Applicable (But Not Exclusive) to Private Equity (PE) Owned Insurers.” Included within this list is the consideration of material increases in privately structured securities (both by affiliated and non-affiliated asset managers), which the NAIC says introduces other sources of risk or increases traditional credit risk, such as complexity risk and illiquidity risk.
+Added: On December 7, 2021, the NAIC assigned to its Macroprudential Working Group, the evaluation of a list of “Regulatory Considerations Applicable (But Not Exclusive) to Private Equity (PE) Owned Insurers.” Included
+Added: within this list is the consideration of material increases in privately structured securities (both by affiliated and non-affiliated asset managers), which the NAIC says introduces other sources of risk or increases traditional credit risk, such as complexity risk and illiquidity risk.
As a result, the NAIC has issued several clarifying revisions to the guidance and disclosure requirements for related party and affiliated securities and continues to consider additional proposals and disclosure requirements.
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The Dodd-Frank Act
+Added: The Dodd-Frank Wall Street Reform and Consumer Protection Act (“The Dodd-Frank Act”) established the Federal Insurance Office within the U.S.
+Added: Department of the Treasury to monitor the insurance industry.
The Dodd-Frank Act made sweeping changes to the regulation of financial services entities, products and markets.
5 unchanged sentences
If FIAs were to be treated as securities, federal and state securities laws would require additional registration and licensing of these products and the agents selling them, and FGL Insurance and FGL NY Insurance would be required to seek additional marketing relationships for these products, any of which could impose significant restrictions on its ability to conduct operations as currently operated.
+Added: However, our RILA product is not exempted from being treated as a security by the SEC.
+Added: Additionally, the Dodd-Frank Act established the Financial Stability Oversight Council (“FSOC”), which plays a role in shaping the regulatory environment affecting RILAs.
+Added: The FSOC monitors systemic risks and may designate insurers offering RILAs as systemically important financial institutions if their activities pose significant risks to the broader economy, subjecting them to enhanced prudential standards and supervision by the Board of Governors of the United States Federal Reserve.
+Added: The prudential standards for non-bank Systemically Important Financial Institutions (“SIFIs”) include enhanced RBC requirements, leverage limits, liquidity requirements, single counterparty exposure limits, governance requirements for risk management, stress test requirements, special debt-to-equity limits for certain companies, early remediation procedures, and recovery and resolution planning.
ERISA and Fiduciary Standards
−Removed: We may offer certain insurance and annuity products to employee benefit plans governed by ERISA and/or the Code, including group annuity contracts designated to fund tax-qualified retirement plans.
−Removed: ERISA and the Code provide (among other requirements) standards of conduct for employee benefit plan fiduciaries, including investment managers and investment advisers with respect to the assets of such plans, and hold fiduciaries liable if they fail to satisfy fiduciary standards of conduct.
+Added: We may offer certain insurance and annuity products to employee benefit plans governed by ERISA and/or the Internal Revenue Code of 1986, as amended (the “Code”), including group annuity contracts designated to fund tax-qualified retirement plans.
+Added: ERISA and the Code provide (among other requirements) standards of conduct for employee benefit plan fiduciaries, including investment managers and investment advisers with respect to the assets of such plans, and holds fiduciaries liable if they fail to satisfy fiduciary standards of conduct.
State and federal regulators have been adopting stronger consumer protection regulations that may materially impact our company, business, distribution, and products.
−Removed: The NAIC adopted an amended Suitability in Annuity Transactions Model Regulation in February 2020 incorporating a requirement that agents act in the best interest of
−Removed: consumers without putting their own financial interests or insurer’s interests ahead of consumer interests.
+Added: The NAIC adopted an amended Suitability in Annuity Transactions Model Regulation in February 2020 incorporating a requirement that agents act in the best interest of consumers without putting their own financial interests or insurer’s interests ahead of consumer interests.
The best interest requirement is satisfied by complying with four regulatory obligations relating to care, disclosure, conflict of interest, and documentation.
3 unchanged sentences
FGL NY Insurance separately instituted new business procedures in response to the NYDFS best interest rule adopted in August 2019 which survived a legal challenge and deviates from the NAIC model regulation and is considered more onerous in certain respects including its broader application to life insurance sales.
−Removed: In December 2020, the Department of Labor (“DOL”) issued its final version of an investment advice rule replacing the previous “Fiduciary Rule” that had been challenged by industry participants and vacated in March 2018 by the United States Fifth Circuit Court of Appeals.
−Removed: The new investment advice rule reinstates the five-part test for determining whether a person is considered a fiduciary for purposes of ERISA and the Code and sets forth a new prohibited transaction exemption (“PTE”) referred to as PTE 2020-02.
−Removed: The rule’s preamble also contains the DOL’s reinterpretation of elements of the five-part test that appears to encompass more insurance agents selling individual retirement account (“IRA”) products and withdraws the agency’s longstanding position that rollover recommendations out of employer plans are not subject to ERISA.
+Added: In December 2020, the DOL issued its final version of an investment advice rule replacing the previous “Fiduciary Rule” that had been challenged by industry participants and vacated in March 2018 by the United States Fifth Circuit Court of Appeals.
+Added: The new investment advice rule reinstates the five-part test for determining whether a person is considered a fiduciary for purposes of the Employee Retirement Income Security Act of 1974 (“ERISA”) and the Internal Revenue Code of 1986, as amended (the “Code”), and sets forth a new exemption, referred to as prohibited transaction class exemption (“PTE”) 2020-02.
+Added: The rule’s preamble also contains the DOL’s reinterpretation of elements of the five-part test that appears to encompass more insurance agents selling IRA products and withdraws the DOL’s longstanding position that rollover recommendations out of employer plans are not subject to ERISA.
The new rule took effect on February 16, 2021.
−Removed: The DOL investment advice rule leaves in place PTE 84-24, which is a longstanding class exemption providing prohibited transaction relief for insurance agents selling annuity products, provided certain disclosures are made to the plan fiduciary, which is the policyholder in the case of an IRA, and certain other conditions are met.
+Added: The DOL left in place PTE 84-24, which is a longstanding class exemption providing prohibited transaction relief for insurance agents selling annuity products, provided that certain disclosures are made to the plan fiduciary, which is the policyholder in the case of an IRA, and certain other conditions are met.
Among other things, these disclosures include the agent’s relationship to the insurer and commissions received in connection with the annuity sale.
−Removed: FGL Insurance along with FGL NY Insurance, designed and launched a compliance program in January 2022 requiring all agents selling IRA products to submit an acknowledgment with each IRA application indicating the agent has satisfied PTE 84-24 requirements on a precautionary basis in case the agent acted or is found to have acted as a fiduciary.
+Added: We, along with FGL Insurance and FGL NY Insurance, designed and launched a compliance program in January 2022 requiring all agents selling IRA products to submit an acknowledgment with each IRA application indicating the agent has satisfied PTE 84-24 requirements on a precautionary basis in case the agent acted or is found to have acted as a fiduciary.
Meanwhile, the DOL has publicly announced its intention to consider future rulemaking that may revoke or modify PTE 84-24.
−Removed: On November 2, 2023, following previous attempts to expand fiduciary regulation for advisers, the DOL released a proposed rule (the “New Fiduciary Rule”) to significantly broaden the definition of “fiduciary” under ERISA.
−Removed: Among other requirements, if finalized in its proposed form, the New Fiduciary Rule provides that any person will be an investment advice fiduciary if they provide investment advice or make an investment recommendation to a retirement investor ( i.e., a plan, plan fiduciary, plan participant or beneficiary, IRA, IRA owner or beneficiary, or IRA fiduciary) for a fee or other compensation, and the person provides the advice or makes the recommendation on a regular basis as part of their business and the recommendation is provided under circumstances indicating that the recommendation is based on the particular needs or individual investor circumstances of the retirement investor.
−Removed: Unlike the current ERISA standard, the New Fiduciary Rule would subject non-discretionary investment advice to retirement plans and accounts to the prudent-person “best interest” standard that has historically been reserved for investment advisors with discretionary authority or control over ERISA plan assets.
−Removed: If the New Fiduciary Rule is adopted in its present form, certain of the Company’s agents would likely be considered fiduciaries for purposes of ERISA and the Internal Revenue Code—subjecting the Company, and the insurance industry on the whole, to greater regulatory risk.
−Removed: Management believes these current and emerging developments relating to market conduct standards for the financial services industry may over time materially affect the way in which our agents do business, the role of IMOs, sale of IRA products including IRA-to-IRA and employer plan rollovers, how the company supervises its distribution force, compensation practices, and liability exposure and costs.
−Removed: In addition to implementing the compliance procedures described above, management is monitoring further developments closely and will be working with IMOs and distributors to adapt to evolving regulatory requirements and risks.
+Added: On April 23, 2024, following previous attempts to expand fiduciary regulation for advisers, the DOL released a new rule, the New Fiduciary Rule, which significantly broadens the definition of “fiduciary” under ERISA and Section 4975 when advisers provide investment recommendations to plans subject to ERISA and Section 4975 of the Code.
+Added: Among other requirements, the New Fiduciary Rule provides that any person will be an investment advice fiduciary if such person provides investment advice or makes an investment recommendation to a retirement investor (i.e., a plan, a discretionary plan fiduciary, a plan participant or beneficiary, an IRA, an IRA owner or beneficiary, or an IRA fiduciary) for a fee or other compensation, the person makes professional investment recommendations to investors on a regular basis as part of their business, and the recommendation is provided under circumstances that would indicate to a reasonable investor in like circumstances that the recommendation is based on a review of the particular needs or individual investor circumstances of the retirement investor, reflects the application of professional or expert judgment to the retirement investor’s particular needs or individual circumstances, and may be relied upon by the retirement investor as intended to advance the retirement investor’s
+Added: best interest.
+Added: Unlike the current ERISA standard, the New Fiduciary Rule subjects non-discretionary investment advice to retirement plans and accounts under the care and loyalty standards that also apply to investment advisors with discretionary authority or control over such plans and accounts.
+Added: In addition, on the same date, the DOL issued amended versions of PTE 2020-02 and PTE 84-24, either or both of which provide prohibited transaction exemptive relief to insurance companies and insurance producers who make insurance product recommendations to retirement investors, subject to certain conditions.
+Added: The New Fiduciary Rule likely means that certain of the Company’s agents will be considered fiduciaries for purposes of ERISA and the Code, subjecting the Company, and the insurance industry on the whole, to greater regulatory risk.
+Added: The DOL’s new Fiduciary Rule, which was scheduled to become effective on September 23, 2024, has been challenged.
+Added: On July 25, 2024, in the case of Federation of Americans for Consumer Choice, Inc., et al.
+Added: United States Department of Labor, et al.
+Added: , (“Federation of Americans”) the United States District Court for the Eastern District of Texas issued an order staying the effective date of the DOL’s final fiduciary rule (and related amendments to PTE 84-24) that was issued in March 2024.
+Added: The District Court, in part relying on the Supreme Court’s recent ruling in Loper Bright Enterprises v.
+Added: Raimondo , found that the plaintiffs (primarily insurance agents) were likely to succeed on their arguments that the Final Rule improperly expanded the definition of an “investment advice fiduciary” under ERISA.
+Added: As a result, the Final Rule’s original effective date of September 23, 2024 has been delayed until further notice.
+Added: In addition, on July 26, 2024, a companion case to Federation of Americans filed in the United States District Court for the Northern District of Texas, American Council of Life Insurers, et al.
+Added: United States Dep’t of Labor, et al.
+Added: , held the remaining PTE amendments included in the Final Rule (PTEs 2020-02, 75-1, 77-4, 80-83, 83-1 and 86-128) that were not challenged in Federation of Americans were also stayed, noting that the Northern District fully agreed with the Eastern District’s analysis and decision to stay the effective date of the Final Rule.
+Added: On September 20, 2024, the DOL appealed both rulings to the Fifth Circuit Court of Appeals.
+Added: On February 11, 2025, the DOL filed an unopposed motion to hold the appeals in abeyance to allow new agency officials time to become familiar with the issues in these cases and determine how they wish to proceed.
+Added: The motion was granted so the appeals are in abeyance.
+Added: A Fifth Circuit reversal of the Texas district court rulings could have harmful effects on the insurance industry, creating additional hurdles to operate our business.
+Added: Management believes these current and emerging developments relating to market conduct standards for the financial services industry may, over time, materially affect the way in which our agents do business, the role of IMOs, sale of IRA products including IRA-to-IRA and employer plan rollovers, how we supervise our distribution force, compensation practices and liability exposure and costs.
+Added: In addition to implementing the compliance procedures described above, management is monitoring further developments closely and will be working with IMOs and distributors to adapt to these evolving regulatory requirements and risks.
+Added: See “Risk Factors—Legal, Regulatory and Tax Risk s—Current and emerging developments relating to market conduct standards for the financial industry emerging from the United States Department of Labor’s (“DOL”) implementation of the “fiduciary rule” may over time materially affect our business.”
The SECURE 2.0 Act
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In addition, F&G and its competitors may implement operational changes to adapt to the effect of the new legislation.
−Removed: See “Risk Factors— Legal, Regulatory and Tax Risks—The SECURE 2.0 Act of 2022 may impact our business and the markets in which we compete .”
+Added: See “Risk Factors— L egal, Regulatory and Tax Risks —The SECURE 2.0 Act of 2022 may impact our business and the markets in which we compete .”
Corporate Alternative Minimum Tax
The Inflation Reduction Act of 2022 (the “Inflation Reduction Act”) was signed into law on August 16, 2022.
−Removed: Among other changes, the Inflation Reduction Act introduced a 15% corporate alternative minimum tax (“CAMT”) on adjusted financial statement income and a 1% excise tax on treasury stock repurchases.
+Added: Among other changes, the Inflation Reduction Act introduced a 15% corporate alternative minimum tax (“CAMT”)
+Added: on adjusted financial statement income and a 1% excise tax on treasury stock repurchases.
These provisions were effective January 1, 2023.
2 unchanged sentences
The life companies will join the consolidated tax return group with FNF and file a life/non-life consolidated return once the five-year waiting period has completed in 2026, which should strengthen that position as FNF is not anticipating owing CAMT on its future returns.
−Removed: For the year ended December 31, 2023, the Company was subject to CAMT, but there is no impact to total tax.
+Added: For the years ended December 31, 2024 and 2023, the Company was subject to CAMT, but there was no impact to total tax.
A CAMT credit carryforward was created and is expected to be able to be utilized in future years.
5 unchanged sentences
The NAIC is developing a framework for approaching issues related to race and insurance.
−Removed: On March 16, 2021, the NYDFS issued a circular letter that states that the NYDFS expects the insurers it regulates to make diversity of their leadership a business priority and key element of their corporate governance.
+Added: The NAIC goals include improving access to different types of insurance products in minority communities, addressing issues related to affordability, and providing guidance to regulators on ways to improve insurance access and the understanding of insurance in underserved communities.
+Added: In New York, NYDFS issued a circular letter that states that the NYDFS expects the insurers it regulates to make diversity of their leadership a business priority and key element of their corporate governance, and it includes diversity-related questions in its examination process.
This guidance is applicable to FGL NY Insurance.
7 unchanged sentences
In addition, the Bermuda Insurance Act requires BMA approval of increases in control or dispositions of control of an insurance company.
−Removed: Effective January 1, 2015, Bermuda was placed on the NAIC’s List of Qualified Jurisdictions, which makes Bermuda-domiciled reinsurers that meet certain criteria to qualify as a certified reinsurer eligible for reduced
−Removed: reinsurance collateral requirements under the NAIC’s Credit for Reinsurance Model Law and Regulations as adopted by various states.
−Removed: F&G Life Re has not applied for a determination to be designated as a certified reinsurer in any state.
+Added: Effective January 1, 2015, Bermuda was placed on the NAIC’s List of Qualified Jurisdictions, which makes Bermuda-domiciled reinsurers that meet certain criteria to qualify as a certified reinsurer eligible for reduced reinsurance collateral requirements under the NAIC’s Credit for Reinsurance Model Law and Regulations as adopted by various states.
+Added: F&G Life Re is a certified reinsurer in Iowa.
Bermuda has been awarded full equivalence for commercial insurers under Europe’s Solvency II regime applicable to insurance companies, which regime came into effect on January 1, 2016.
1 unchanged sentence
Under the NAIC’s Credit for Reinsurance Model Law and Regulations which has been adopted by all states, a ceding insurer may take credit for reinsurance ceded to a reciprocal jurisdiction reinsurer without posting collateral.
−Removed: F&G Life Re has not applied for a determination to be designated a reciprocal jurisdiction reinsurer in any state.
+Added: F&G Life Re has been designated a reciprocal jurisdiction reinsurer in Iowa.
All insurers are required to implement corporate governance policies and processes as the BMA considers appropriate given the nature, size, complexity and risk profile of the insurer and all insurers, on an annual basis, are required to deliver a declaration to the BMA confirming whether or not they meet the minimum criteria for registration under the Bermuda Insurance Act.
All insurers are required to comply with the Bermuda Insurance Code of Conduct, which is a codification of best practices for insurers provided by the BMA, and to submit annually to the BMA with its statutory financial return a declaration of compliance confirming it complies with the Bermuda Insurance Code of Conduct.
+Added: All insurers are also required to comply with the Bermuda Insurance Sector Cyber Risk Management Code of Conduct issued by the BMA under the Bermuda Insurance Act, which establishes the duties, requirements, standards, procedures and principles to be complied with in relation to operational cyber risk management.
The BMA utilizes a risk-based approach when it comes to licensing and supervising insurance and reinsurance companies.
20 unchanged sentences
In the event a dividend complies with the above, F&G Life Re must ensure the amount of any such dividend does not exceed that excess.
−Removed: Furthermore, as a Class E insurer, F&G Life Re must not declare or pay a dividend in any financial year which would exceed 25% of its total capital and statutory surplus, as set out in its previous year’s financial statements, unless at least seven days before payment of such dividend F&G Life Re files with the BMA an affidavit signed by at least two directors of F&G Life Re and its principal representative under the Bermuda Insurance Act stating that, in the opinion of those signing, declaration of such dividend has not caused the insurer to fail to meet its relevant margins.
+Added: Furthermore, as a Class E insurer, F&G Life Re must not declare or pay a dividend in any financial year which would exceed 25% of its total statutory capital and surplus, as set out in its previous year’s Bermuda statutory financial statements, unless at least seven days before payment of such dividend F&G Life Re files with the BMA an affidavit signed by at least two directors of F&G Life Re and its principal representative under the Bermuda Insurance Act stating that, in the opinion of those signing, declaration of such dividend has not caused the insurer to fail to meet its relevant margins.
The Bermuda Companies Act also limits F&G Life Re’s ability to pay dividends and make distributions to its shareholders.
5 unchanged sentences
The Corporate Income Tax (“CIT”) Act of 2023 was passed in Bermuda on December 27, 2023.
−Removed: The CIT Act will commence on January 1, 2025 and will apply a statutory rate of 15% to the taxable income or loss of Bermuda tax resident entities and permanent establishments.
−Removed: F&G Life Re, a 953(d) company with no or minimal US permanent tax differences, is not expected to owe any Bermuda CIT due to the foreign tax credit.
+Added: The CIT Act commenced on January 1, 2025 and applies a statutory rate of 15% to the taxable income or loss of Bermuda tax resident entities and permanent establishments.
+Added: F&G Life Re, a 953(d) company with no or minimal US permanent tax differences, does not anticipate to owe any Bermuda CIT due to the foreign tax credit.
The deferred tax asset recorded for the year ended December 31, 2024, of $10 million has a full valuation allowance.
As a result, there is no material impact to the financial statements.
+Added: Block Transactions
+Added: Since January 2023, the BMA has required all long-term (life) commercial reinsurers such as F&G Life Re to obtain the prior approval of the BMA for all long-term block reinsurance transactions, which is defined as a block transaction that covers an existing long-term business policy that is written and in force and on the books of the cedant, as of the date of the reinsurance transaction (including pension risk transfer transactions).
+Added: Affiliate, Related Party or Connected Party Assets
+Added: As a Class E insurer, F&G Life Re is required to obtain the prior written approval of the BMA before investing in assets with counterparty credit exposure to an affiliate, related party or connected party (each as defined under the Bermuda Insurance Act) of F&G Life Re.
Cayman Islands Regulatory Overview
−Removed: F&G Cayman Re Ltd.
−Removed: (“F&G Cayman Re”) is a Cayman Islands exempted company incorporated under the Companies Act, (2023 Revision) as amended, (the “Cayman Islands Companies Act”) and licensed as a Class D insurer in the Cayman Islands under the Insurance Act, 2010 as amended and its related regulations (the “Cayman Islands Insurance Act”).
+Added: F&G Cayman Re is a Cayman Islands exempted company incorporated under the Companies Act, (2023 Revision) as amended, and licensed as a Class D insurer in the Cayman Islands under the Insurance Act, 2010 as amended and its related regulations (the “Cayman Islands Insurance Act”).
F&G Cayman Re is regulated by the Cayman Islands Monetary Authority (“CIMA”).
1 unchanged sentence
CIMA has broad discretion in its consideration of whether to grant a license and must act in the public interest.
−Removed: CIMA is required by the Cayman Islands Insurance Act to determine whether an applicant is a fit and proper body to be engaged in insurance business.
+Added: CIMA is required by the Cayman
+Added: Islands Insurance Act to determine whether an applicant is a fit and proper body to be engaged in insurance business.
A licensed insurer must comply with the terms of its license and such other conditions as CIMA may impose at any time.
5 unchanged sentences
For a Class D insurer, the minimum capital requirement is $50,000,000.
−Removed: In addition, an insurer must maintain a minimum margin of solvency at a level equal to or in excess of the total prescribed capital requirement which is established by reference to either the applicable prescribed capital
−Removed: requirements based on license class or an internal capital model approved by CIMA.
+Added: In addition, an insurer must maintain a minimum margin of solvency at a level equal to or in excess of the total prescribed capital requirement which is established by reference to either the applicable prescribed capital requirements based on license class or an internal capital model approved by CIMA.
Notwithstanding the minimum capital requirements, CIMA may set an enhanced prescribed capital requirement in respect of any insurer.
10 unchanged sentences
None of our employees are subject to collective bargaining agreements.
−Removed: We believe that our relations with employees are generally good.
+Added: We consider our relations with our employees to be good.
Talent Management
−Removed: F&G embeds diversity, equity and inclusion into our culture and is embraced within our core values - Collaborative, Authentic, Dynamic and Empowered.
−Removed: These core values coupled with our competitive total rewards philosophy and flexible work environment provide an attractive employee value proposition.
+Added: F&G’s core values - Collaborative, Authentic, Dynamic and Empowered, coupled with our competitive total rewards philosophy and flexible work environment provide an attractive employee value proposition.
We recruit top talent to join our team and provide opportunities for personal and professional growth.
Our development programs are designed to provide opportunities for all employees to grow and develop.
−Removed: Development programs are aligned to the skills and behaviors defined in our F&G Competencies - Think Enterprise Wide, Leverage Data, Center Equity, Communicate with Courage, Be Accountable- and ensure our employees are developing skills that are critical to achieve business goals now and in the future.
−Removed: Leadership Academy is our premiere leadership development program designed to develop the next level of leaders at F&G and enables cross-functional leaders to hone their leadership capability and network with colleagues from across the enterprise.
+Added: Development programs are aligned to the skills and behaviors defined in our F&G Competencies - Think Enterprise
+Added: Wide, Leverage Data, Center Equity, Communicate with Courage, Be Accountable- and ensure our employees are developing skills that are critical to achieve business goals now and in the future.
+Added: Leadership Academy is our leadership development program designed to develop the next level of leaders at F&G and enables cross-functional leaders to hone their leadership capability and network with colleagues from across the enterprise.
Employee engagement is measured annually through two surveys.
7 unchanged sentences
We offer competitive health care benefit options for medical, dental and vision coverage, as well as a health savings account with an employer contribution.
−Removed: Other benefits offerings include health care and dependent care flexible spending accounts, employee assistance program, wellness reimbursements, charitable matching donations, and adoption assistance.
−Removed: To support a healthy work-life balance, all employees receive paid time off, holidays, volunteer time off and paid parental leave for new parents.
+Added: Other benefits offerings include health care and dependent care flexible spending accounts, employee assistance program, lifestyle reimbursements, charitable matching donations, and adoption assistance.
+Added: To support a healthy work-life balance, all employees receive paid time off, holidays, flexible Fridays, volunteer time off and paid parental leave for new parents.
Employee retention is critical to the success of our business.
1 unchanged sentence
Our turnover rates have been consistently below national and industry-specific benchmarks.
−Removed: Our Approach to Environmental, Social, and Governance (“ESG”)
−Removed: F&G’s products and services inherently provide a social good, and that sentiment of service also provides the foundation for F&G’s culture and guides business operations as well as interactions within our communities.
−Removed: Governance - Board oversight
−Removed: Our Company and our Board seek to address ESG issues to better serve our employees, business partners, and the communities impacted by our business.
−Removed: The F&G AC is responsible for overseeing the Company’s ESG risks.
−Removed: The AC Charter states that “The Committee shall review with management the Company’s policies and practices with respect to risk assessment and risk management, including with respect to … environmental, social, and governance risk, except with respect to those risks for which oversight has been assigned to other committees of the Board or retained by the Board.” The AC meets at least four times per year.
−Removed: Climate expertise resides on the Board and the AC.
−Removed: The AC receives updates from the Company’s Chief Risk Officer (“CRO”) on a quarterly basis regarding enterprise risk management (“ERM”) including an overview of current and emerging risks.
−Removed: Such risks may include climate risks as a subset of investment risks and an update on overall ESG-related matters.
−Removed: The CRO will continue to update the AC on F&G’s climate risk profile as risks and opportunities arise.
−Removed: Management’s role in assessing and managing ESG-related risks and opportunities.
−Removed: F&G’s management team leads ESG efforts with oversight from the AC, who reports the Company’s ESG progress and efforts to the Board.
−Removed: F&G’s Chief Executive Officer (“CEO”) has the ultimate responsibility within management for governance-related matters at F&G.
−Removed: The CEO, CRO, General Counsel (“GC”), SVP Chief People Officer (“SVP-PO”), Deputy Chief Investment Officer (“D-CIO”), and Chief Financial Officer (“CFO”), SVP Investor & External Relations comprise the ESG Executive Steering Committee, which is responsible for making key enterprise decisions around strategy, capital and asset allocation, planning and budgeting, and developing human capital.
−Removed: The CRO chairs the ESG Executive Steering Committee.
−Removed: The D-CIO, GC and SVP-PO are responsible for assessing the recommendations made to the ESG Executive Steering Committee and providing effective input prior to agreeing on strategy, initiatives, or other courses of action.
−Removed: The Senior Vice President of Investor & External Relations and the CFO are consulted for input prior to final approval of actions.
−Removed: The ultimate decision rests with the CEO.
−Removed: F&G has an ESG working group that is comprised of functional and business-level management responsible for performing any underlying analysis, research, documentation, and implementation supporting the ESG Executive Steering Committee efforts.
−Removed: This group may spin up sub-working groups or task forces to address specific activities.
−Removed: For example, a targeted group was formed to assist with a pilot climate stress scenario analysis performed in 2023.
+Added: Workplace Flexibility
+Added: F&G is committed to providing employees with the opportunities and flexibility they need to succeed, as well as ensuring a culture of belonging and inclusion by:
+Added: • Providing well rounded benefits that support employees diverse needs such as, domestic partner medical coverage, gender dysphoria services, $50,000 lifetime maximum for infertility services ($35,000 is United Health Care standard), travel & lodging reimbursement for services rendered out-of-state due to state law, Employee Assistance Program including 6 free counseling sessions per person per incident per year, in addition to other emotional health solutions, $10,000 in adoption assistance benefit, parental leave benefits, flexible PTO and lifestyle reimbursements.
+Added: • Supporting employee training, developing and educating through LinkedIn learning with a wide array of topics (e.g., Using Gender inclusive language, fueling your Company Culture, Inclusive Leadership, Unconscious Bias, etc.), tuition reimbursement, and manager and leadership training.
+Added: • Hosting educational and developmental events such as, a Mental Awareness and Racial Equity Master Class, a Mental Health panel, and a panel on Neurodiversity.
+Added: • Recognized for several Cultural Excellence Awards in 2024, 2023 and 2022 through Energage, for excellence in 1) Compensation and Benefits, 2) Leadership, 3) Work-Life Flexibility, 4) Professional Development, 5) Appreciation, 6) Employee Wellbeing, 7) Professional Development and 8) Purpose and Values.
+Added: Community engagement
+Added: F&G focuses its community engagement and charitable giving to support essential needs such as food insecurity and housing.
+Added: In recent years, F&G has won multiple awards for its corporate support and employee involvement with United Way, including Outstanding Corporate/Foundation Philanthropist for 2023 from the Association of Fundraising Professionals Central Iowa Chapter.
+Added: Other community investments include:
+Added: • Serving as founding partner of the American Council of Life Insurer’s Impact Investments Initiative (“360 Community Capital”) to make housing affordable and sustainable in underserved communities.
+Added: • Fostering partnerships in the Des Moines community with the Iowa Food Bank and Polk County Housing Trust.
+Added: • Offering company-wide volunteer events for employees to make an impact locally with organizations such as Rebuilding Together.
+Added: • Providing employees with 16 hours of paid time off per year for volunteering.
+Added: • Supporting dozens of other community organizations identified by F&G employees in support of essential needs within the community where they live and work.
+Added: Operational Sustainability
+Added: F&G aims to reduce the company’s environmental footprint through a variety of sustainable and environmentally sound programs within its LEED-certified headquarters building in Des Moines, Iowa.
+Added: F&G also promotes flexible work from home arrangements which reduce commute time, greenhouse gas emissions, and paper usage.
+Added: Our Company and our Board is committed to sustainable practices to serve our employees, business partners and the community
+Added: The F&G AC is responsible for overseeing the Company’s sustainability risks.
+Added: Such risks may include climate risks as a subset of investment risks.
+Added: The Company’s Chief Risk Officer (“CRO”) will continue to update the AC on F&G’s climate risk profile as risks and opportunities arise.
+Added: Management’s Role in Assessing and Managing Sustainability Risks and Opportunities
Additional governance committees
−Removed: The AC and ESG Executive Steering Committee utilize and rely on other groups and committees within F&G beyond the ESG working group to ensure all risks and opportunities related to ESG are addressed appropriately.
−Removed: The ERMC is an enterprise committee, consisting of C-suite level executives including the CEO, CFO, CRO, and Chief Investment Officer, who are responsible for reviewing risks and associated strategy across the business.
−Removed: The ESG risks are included in the overall F&G Risk Register that is the basis for quarterly risk assessments.
+Added: The AC and ERMC utilize and rely on other groups and committees within F&G to facilitate that all risks and opportunities related to our sustainability are addressed appropriately.
+Added: The ERMC is an enterprise committee, consisting of C-suite level executives including the Chief Executive Officer, Chief Financial Officer, Chief Investment Officer and CRO who are responsible for reviewing risks and associated strategy across the business.
+Added: The risks are included in the overall F&G Risk Register that is the basis for quarterly risk assessments.
The overall risk posture of the organization is updated in the quarterly ERM dashboard report.
−Removed: The development of an enterprise-ESG program, including climate-risks, is included in F&G’s 2023 Own Risk and Solvency Assessment (“ORSA”) summary report, and articulates the responsibility for actively monitoring and focusing resources on ESG-related activities.
+Added: The development of and maturity of the enterprise ESG program, including climate-risks, is included in F&G’s 2023 Own Risk and Solvency Assessment (“ORSA”) summary report, and articulates the responsibility for actively monitoring and focusing resources on sustainability-related activities.
The Investment Committee provides oversight of investments held, approves new asset classes, and reviews investment managers and mandates.
−Removed: The Investment Committee also oversees the relationships with F&G’s Asset Management companies, which includes assessing their ESG policies and practices for consistency with F&G’s missions and vision.
−Removed: The Diversity, Equity and Inclusion (“DEI”) Advisory Council (“Council”) is an ongoing cross functional group that includes the CEO & President.
−Removed: The Council was established to help create a comprehensive DEI strategy, objectives, and success metrics for DEI.
−Removed: The Council provides advice, guidance, and championship for the DEI strategy execution, and helps to ensure a high-functioning interaction model for the Council, Employee Resource Groups (“ERG”), Human Resources, Communications, and the business lines.
−Removed: The Council reports initiatives and progress up through the Management Committee as needed.
+Added: The Investment Committee also oversees the relationships with F&G’s Asset Management companies, which includes assessing their sustainability policies and practices for consistency with F&G’s missions and vision.
F&G’s product solutions provide social good by supporting clients to achieve their retirement goals and to improve their financial lives, while protecting against unforeseen events through life insurance policies.
This sentiment of service provides the foundation for F&G’s culture and guides business operations as well as interactions within our communities.
−Removed: Through the underlying ESG investment policies of F&G’s asset management partners, the investment portfolio supporting the current range of products offered by F&G considers climate-related risks and the transition to a low carbon economy.
+Added: The investment portfolio supporting the current range of products offered by F&G considers climate-related risks and the transition to a low carbon economy.
As long-term investors, F&G understands the energy transition will be gradual, and the focus should be on investment outcomes that will support our fiduciary duty to our clients and the investment goals of our clients.
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The identified risks were added to the enterprise risk register for inclusion in the quarterly self-assessment and annual risk assessment processes.
−Removed: Most risks can be addressed more acutely in the short and medium term, as well as integrated into long-term planning.
+Added: The risks were also integrated into the ESG Program.
Impact of pending and passed legislation
−Removed: Developments in national, state, and international regulations related to climate risk are increasing.
−Removed: Business emissions are categorized into Scope 1, 2 and 3 emissions and account for both direct and indirect emitted gases (“GHG”).
−Removed: Scope 1 emissions are GHGs released directly from the business.
−Removed: Scope 2 emissions are indirect GHGs
−Removed: released from the energy purchased by an organization.
−Removed: Scope 3 emissions are also indirect GHG emissions, accounting for upstream and downstream emissions of a product or service and emissions across a business value chain.
−Removed: Additional compilation of data is required for disclosure requirements of scope 1 & 2 emissions, which impacts operational processes, although not material in cost.
−Removed: Moreover, F&G is diligently working to identify and gather the appropriate data for Scope 3 emissions.
−Removed: F&G provides information on ESG efforts to its investor, client, and employee stakeholders through the State Climate Survey, client and investor surveys, and internal communications.
−Removed: While there is interest in F&G’s efforts, demand for changes to F&G products has not changed as a result of information provided.
+Added: Developments in national, state, and international regulations related to ESG and climate risk are ever-changing.
+Added: F&G is diligently working to identify and gather the appropriate data for evolving reporting standards.
+Added: The California Air Resources Board ("CARB"), and similar regulators in other U.S.
+Added: states and international jurisdictions in which we sell our products have phased in, or are phasing in, emission regulations setting maximum emission standards.
+Added: The state of California passed two bills that will require certain companies doing businesses in the state to disclose GHG emissions and climate-related financial risk information.
+Added: Senate Bill 253 (SB 253) requires the annual disclosure of Scope 1, 2 and 3 GHG emissions, with certain GHG emissions data subject to third party assurance.
+Added: The bill requires disclosure of Scope 1 and 2 GHG emissions beginning in 2026 for the 2025 reporting year and disclosure of Scope 3 GHG emissions beginning in 2027 for the 2026 reporting year.
+Added: SB 253 would be effective for public and private companies with total annual revenues exceeding $1 billion and that do business in California.
+Added: Senate Bill 261 (SB 261) requires biennial disclosures posted on a company’s website related to climate-related financial risks and the measures a company has adopted to reduce and adapt to such risks.
+Added: The bill requires disclosure of the climate-related financial risk disclosures beginning in 2026 for the 2025 reporting year.
+Added: SB 261 is effective for public and private companies with total annual revenues exceeding $500 million.
+Added: Both SB 253 and 261 have been challenged in the U.S.
+Added: District Court for the Central District of California.
+Added: Further, on September 27, 2024, the California Governor amended both SB 253 and SB 261 by signing into law Senate Bill 219 (SB 219).
+Added: SB 219 extends the time in which CARB has to promulgate implementing regulations for SB 253 until July 1, 2025, a delay of six months, but does not otherwise change the reporting deadlines in SB 253 or SB 261.
Capital expenditures related to climate change
Current expenditures related specifically to climate change have been minimal.
−Removed: F&G added an ESG module to the Governance, Risk, and Compliance application to maintain risk information and metrics related to ESG efforts.
+Added: F&G added a sustainability module to the Governance, Risk, and Compliance application to maintain risk information and metrics related to sustainability efforts.
Future expenditures will likely increase as F&G moves forward with plans for ongoing scenario analysis and data stores to facilitate the calculation of Scope 3 emissions.
−Removed: Operational sustainability and workforce flexibility
−Removed: F&G aims to reduce the company’s environmental footprint through a variety of sustainable and environmentally sound programs within its LEED-certified headquarters building in Des Moines, Iowa.
−Removed: F&G also promotes flexible work from home arrangements which reduce commute time, greenhouse gas emissions, and paper usage.
−Removed: F&G is committed to providing employees with the opportunities and flexibility they need to succeed, as well as ensuring a culture of belonging and inclusion by:
−Removed: • Providing well rounded benefits that support employees diverse needs such as, domestic partner medical coverage, gender dysphoria services, $50k lifetime maximum for infertility services ($35k is United Health Care standard), travel & lodging reimbursement for services rendered out-of-state due to state law, Employee Assistance Program including 6 free counseling sessions per person per incident per year, in addition to other emotional health solutions, $10k in adoption assistance benefit, parental leave benefits, flexible PTO and wellness reimbursements.
−Removed: • Supporting employee training, developing and educating through LinkedIn learning with a wide array of topics (e.g., Using Gender inclusive language, Fueling your Company Culture, Inclusive Leadership, Unconscious Bias, etc.), tuition reimbursement, and manager and leadership training.
−Removed: • Hosting educational and developmental events such as, a Mental Awareness and Racial Equity Master Class, a Mental Health panel, and a panel on Neurodiversity.
−Removed: • Growing the share of people of color in leadership roles (VP+) from 2022 to 2023;
−Removed: F&G’s management committee (C-suite) is comprised of 40% female leadership.
−Removed: • Recognized for several Cultural Excellence Awards in 2022 and 2023 through Energage, for excellence in 1) Compensation and Benefits, 2) Leadership, 3) Work-Life Flexibility, 4) Innovation, 5) Appreciation, and 6) Employee Wellbeing.
−Removed: Diversity and inclusion
−Removed: Specific diversity and inclusion programs and organizations supported by F&G include:
−Removed: • The International Association of Black Actuaries and The Organization of Latino Actuaries, both of which F&G employees are members of and serve as a network for potential new hires.
−Removed: • Women Lead Change, an organization dedicated to the development, advancement and promotion of women, their organizations, and impact on the economy and future workforce.
−Removed: • Capitol City Pride, which brings together members of Iowa’s LGBTQ+ community, allies and businesses.
−Removed: • Enabling our employee-led Council’s work in creating awareness and support around important topics such as mental health awareness, including the launch of ERGs.
−Removed: ERGs are a safe space for employees of similar identity/affinity to network, grow, voice, engage, and help the organization build a culture of inclusion and belonging.
−Removed: They are forums that deliver intentional, impactful and powerful programming for the benefit of members.
−Removed: Our ERGs launched in 2023 include Women’s Empowerment, Wellness, PRIDE, F&G Ultimate Network (“F.U.N”), and Community Impact, and in early 2024, we launched two new ERGs, Black Originators, Leaders and Doers (“BOLD”) and Asian Pacific Islander Alliance (“APIA”).
−Removed: Community engagement
−Removed: F&G focuses its community engagement and charitable giving to support essential needs such as food insecurity and housing.
−Removed: In recent years, F&G has won multiple awards for its corporate support and employee involvement with United Way, including Outstanding Corporate/Foundation Philanthropist for 2023 from the Association of Fundraising Professionals Central Iowa Chapter.
−Removed: Other community investments include:
−Removed: • Serving as founding partner of the American Council of Life Insurer’s Impact Investments Initiative to make housing affordable and sustainable in underserved communities.
−Removed: • Fostering partnerships in the Des Moines community with the Iowa Food Bank and Polk County Housing Trust.
−Removed: • Offering company-wide volunteer events for employees to make an impact locally with organizations such as Rebuilding Together.
−Removed: • Providing employees with 32 hours of paid time off per year for volunteering.
−Removed: • Supporting dozens of other community organizations identified by F&G employees in support of essential needs within the community where they live and work.
Investment Portfolio climate scenario analysis
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The overall scenario analysis covered multiple industry-recognized scenarios, including a 2°C or lower scenario.
−Removed: The pilot run scenario included nine sectors of the global economy in three countries, representing a cross-section of F&G’s physical and transition risk exposures across 21 securities.
−Removed: These securities were a high-level representation of F&G’s public asset ownership and real estate assets.
−Removed: The selection captured high-carbon positions to better understand those risks.
−Removed: Three scenarios (orderly, disorderly, and hot house) were used in the assessment to evaluate expected risk under forward-looking climate scenarios.
−Removed: Orderly and Disorderly scenarios include transition and physical risk while Hot House captured physical risk only.
−Removed: Network for Greening the Financial System scenarios were leveraged for transition risk and Intergovernmental Panel on Climate Change scenarios were used for physical risk.
−Removed: The Orderly scenario reflects an aggressive introduction of carbon pricing from 2030, which directly and negatively impacts the financials of those companies and sectors which are more carbon intensive.
−Removed: After the initial value decline, there is stabilization from 2030 onwards as the grid decarbonizes rapidly (reducing Scope 2 emissions for most companies).
−Removed: The Disorderly scenario follows a similar profile to the Orderly scenario but there is little movement until 2030 when the delayed transition starts.
−Removed: At this point the value decline is very steep but flattens from 2035 onwards.
−Removed: Both Order and Disorderly arrive at a similar impact in 2050 by reaching net zero.
−Removed: In contrast, there is no transition risk in the Hot House scenario.
−Removed: In this scenario the only driver of value change is the impact of physical risks disrupting operations and/or causing damage to physical assets owned by individual companies.
−Removed: The impact is lower than the transition risk scenarios as physical risk becomes more significant in the modeling only after 2050, past the end point of the current scenario analysis.
For the pilot portfolio temperature alignment was calculated, aligning F&G’s pilot portfolio with a warming trajectory through 2050.
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Automobile manufacturers saw the largest impact and variability, while financials and structured products had smaller impacts.
−Removed: F&G plans to use climate scenario analysis with the intention of expanding its assessments and looking for opportunities to better incorporate its investment and enterprise risk process over the next few years.
−Removed: The pilot results will aid in developing a comprehensive strategy related to climate risk, which includes a plan to conduct an overall scenario analysis on the investment portfolio and to assess transition risk by asset class and sector for the portfolio using different climate scenarios.
+Added: We will continue to enhance our capabilities in the evaluation and assessment of risks due to climate change as a component of our overall enterprise risk process.
Risk Management
5 unchanged sentences
Qualitative and quantitative approaches are used to manage risk appetite and are monitored as part of the strategy and planning process.
−Removed: Risks are defined in the risk taxonomy, based on International Organization for Standardization (“ISO”) 31000, and captured in a risk library.
+Added: Risks are defined in the risk taxonomy, based on International Organization for Standardization 31000, and captured in a risk library.
The taxonomy includes four parent categories:
9 unchanged sentences
F&G monitors risks via an annual risk assessment, the quarterly risk self-assessments, quarterly ERMC meetings, monthly Investment Committee meetings, monthly Capital Committee meetings, and ad hoc analysis.
−Removed: The overall risk posture of the organization is updated in the ERMC meeting report that includes a CRO assessment, emerging risks, ERM dashboard, market risk discussion, stress testing results, and risk appetite measures.
−Removed: The development of an enterprise ESG program, including climate risks, is included in F&G’s 2023 ORSA summary report, and articulates the Management Committee’s responsibility for actively monitoring and focusing resources on ESG-related activities.
+Added: overall risk posture of the organization is updated in the ERMC meeting report that includes a CRO assessment, emerging risks, ERM dashboard, market risk discussion, stress testing results, and risk appetite measures.
+Added: The development of an enterprise program, including climate risks, is included in F&G’s 2023 ORSA summary report, and articulates the Management Committee’s responsibility for actively monitoring and focusing resources on sustainability-related activities.
Overall climate risk was deemed to be minimal by the ESG Steering Committee during a qualitative review of risks and opportunities based on the insurance-related products sold by F&G.
11 unchanged sentences
The 3rd line of defense provides management with independent, objective assurance of the overall effectiveness, and efficiency of the design and operation of internal controls.
−Removed: The framework and process alignment includes utilization of committee structure to identify, assess, and prioritize risk to ensure both senior management and the board of directors understand and can manage the risk profile.
+Added: The framework and process alignment includes utilization of committee structure to identify, assess, and prioritize risk to ensure both senior management and the Board understand and can manage the risk profile.
Any changes in business trends as a result of climate change would be identified through Risk Management interaction with the 1st line of defense discussions and risk assessments.
No material or significant changes due to climate change have been identified to date.
−Removed: Investment risk is one of the largest sources of risk to the company, and the Deputy CRO - Investments with the Deputy Chief Investment Officer are responsible for integrating ESG, including understanding and managing climate-related risks, into F&G’s investment process.
−Removed: Our primary asset manager generally considers material ESG factors a key part of evaluating new investments.
−Removed: By considering applicable ESG factors in the investment process, they aim to identify and address material investment risks and opportunities.
−Removed: They also continuously monitor ESG related risks throughout the investment holding period and engage on certain focus areas such as Climate Risk, Diversity & Inclusion and good Corporate Governance.
+Added: Investment risk is one of the largest sources of risk to the Company, and the Senior Vice President, Investment Risk and ALM Strategy, with the Deputy Chief Investment Officer are responsible for integrating sustainability practices, including understanding and managing climate-related risks, into F&G’s investment process.
+Added: Our primary asset manager generally considers material sustainability factors a key part of evaluating new investments.
+Added: By considering applicable sustainability factors in the investment process, they aim to identify and address material investment risks and opportunities.
+Added: They also continuously monitor sustainability-related risks throughout the investment holding period and engage on certain focus areas such as Climate Risk, Inclusion and good Corporate Governance.
Metrics and Targets
2 unchanged sentences
F&G anticipates gathering Scope 1 and Scope 2 emissions in the coming year for additional office locations in New York, Bermuda and Cayman.
−Removed: F&G is also evaluating industry developments related to the available frameworks and methodologies to quantify and collect emissions to better understand our scope 3 emissions footprint.
F&G’s existing risk management framework includes various metrics to manage risks across the investment portfolio.
−Removed: F&G is currently assessing the development of climate-related targets to improve the existing risk management framework.
+Added: F&G is currently assessing the development of climate-related targets to improve the existing risk
+Added: management framework.
Efforts will continue to develop and enhance key policies and statements to reflect our ongoing commitment to mitigating climate-related risk, including climate scenario analysis, and F&G will continue to monitor risks and opportunities related to our climate risk assessment.
6 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.