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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.
−Removed: Gross sales profitability increased from $4.5 billion for the full year 2020 to $15.3 billion in 2024.
+Added: Gross sales increased from $4.5 billion for the full year 2020 to $14.6 billion in 2025.
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 $57.6 billion as of December 31, 2025.
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These assets are managed against what we believe to be prudently underwritten liabilities.
−Removed: 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.
+Added: We have inforce liabilities of $56.8 billion at December 31, 2025, with a liability duration of approximately 5 years, well matched to our assets.
For the year ended December 31, 2025, net earnings attributable to F&G totaled $265 million, we produced adjusted net earnings attributable to F&G common shareholders of $482 million, and we had an adjusted return on assets attributable to F&G common shareholders (“ROA”) of 87 basis points.
−Removed: 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.
−Removed: 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 across our multi-channel new business platform.
−Removed: 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.
−Removed: 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”).
+Added: Adjusted net earnings attributable to F&G common shareholders for the year ended December 31, 2025 included income from a $16 million reinsurance true-up adjustment, $10 million tax valuation allowance benefit, and $4 million of actuarial reserve release.
+Added: Investment income from alternative investments was $278 million below management’s long-term expected return of approximately 10%.
+Added: We are uniquely positioned in the industry with a profitabl e and growing $56.8 billio n inforce block.
+Added: We generate spread-based earnings from fixed annuities and pension risk transfer and we have multiple sources of fee-based earnings with the reinsurance sidecar vehicle launched in August 2025 alongside our flow reinsurance, middle market life insurance and well performing owned distribution portfolio.
+Added: As our business grows, we are becoming a more fee-based, higher margin and capital light business, leveraging our position as one of the industry’s largest sellers of annuities and life insurance.
+Added: We are balancing this with continuing to grow our spread-based business, prioritizing pricing discipline and allocating capital to the highest return opportunities.
+Added: As of December 31, 2025 , we had $4.8 billion of total F&G equity and $6.0 billion of total F&G common shareholders’ equity excluding accumulated other comprehensive income (loss) (“AOCI”).
FGL Insurance’s estimated U.S.
−Removed: RBC ratio was over 410% a s of December 31, 2024, as compared to 451% and 442% as of
−Removed: December 31, 2023 and December 31, 2022, respectively.
+Added: RBC ratio was approximately 430% a s of December 31, 2025, as compared to 410% and 451% as of December 31, 2024 and December 31, 2023, respectively.
FGL Insurance expects to maintain its U.S.
risk-based capital (“RBC”) ratio at or above our target of 400%.
−Removed: F&G Dividend Distribution (the “separation and distribution”)
−Removed: On December 1, 2022, FNF distributed, on a pro rata basis, approximately 15% of the common stock of F&G.
+Added: F&G Dividend Distributions
+Added: On December 1, 2022, FNF distributed, on a pro rata basis, approximately 15% of the common stock of F&G (the “separation and distribution”).
The purpose of the separation and distribution was to enhance and more fully recognize the overall market value of each company.
−Removed: FNF retained control of F&G through ownership of approximately 85% of F&G common stock.
+Added: Additionally, on December 31, 2025, FNF distributed, on a pro rata basis, approximately 12% of the outstanding shares of F&G common stock.
+Added: Following the distribution, FNF retained approximately 70% ownership of F&G and the public float of F&G increased to approximately 30%.
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.”
−Removed: 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.
−Removed: We have expanded our business in our traditional channel and entered new markets.
−Removed: 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.
−Removed: We are positioned to accomplish our goals through the following areas of strategic focus:
−Removed: • Targeting large and growing markets .
−Removed: The opportunity for our core annuity products remains significant, as policyholders seek to add safety and certainty to their retirement plans.
−Removed: Our investments in life insurance products allows us to penetrate the underserved middle market, which addresses the needs of many of our cultural communities.
−Removed: And as corporations continue to de-risk their pension funds, our buyout solutions can guarantee pension-holders the lifetime benefits they need and want.
−Removed: Finally, we continue to attract strong institutional annuity buyers with funding agreements.
−Removed: F&G is a national leader in the markets we play in, and demographic trends provide tailwinds and significant room to continue growing.
−Removed: • Superior ecosystem .
+Added: Through a diversified growth strategy, F&G has delivered a compound annual growth rate in AUM of 17% for the six-year period 2019 to 2025 and, more recently, an annual increase in AUM of 7% as of December 31, 2025 compared to the year ended December 31, 2024.
+Added: Since 2019, we have expanded our business in our traditional channel and entered new markets.
+Added: Leveraging our position as one of the industry’s largest sellers of annuities and life insurance, F&G is transforming into a more fee-based, higher margin and less capital-intensive business, balanced with disciplined growth in our spread-based business, prioritizing pricing discipline and allocating capital to the highest return opportunities.
+Added: Through our strategic focus, we have made significant progress toward our medium term financial targets laid out at our October 2023 Investor Day to grow assets and expand returns.
+Added: Our strategy is underpinned by the following key areas of focus:
+Added: • Targeting large, growing markets.
+Added: As a nationwide leader, F&G is strategically positioned within large, growing markets, benefiting from powerful demographic trends that are fueling sustainable demand for guaranteed income solutions.
+Added: Our disciplined focus on core products – including indexed annuities, middle market life insurance, and pension risk transfer – will continue to drive AUM growth with attractive and stable liabilities.
+Added: The market for our core annuity products is substantial, driven by increasing demand for safety and certainty in retirement planning.
+Added: Our life insurance products strategically target the underserved middle market, offering solutions tailored to diverse cultural communities.
+Added: And as corporations continue to de-risk their pension funds, our pension risk transfer solutions provide guaranteed lifetime benefits to pension-holders.
+Added: Finally, our funding agreements continue to generate strong interest from institutional investors.
+Added: • Evolved ecosystem and sustainable advantage.
Our business model gives us a sustainable competitive advantage.
−Removed: We have strong and long-standing relationships with a diverse network of distributors, a durable investment edge through our Blackstone partnership, a scalable administrative platform, and a track record of attracting and retaining top talent.
−Removed: • 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 expand ROA, excluding short-term mark-to-market effects, across varying market cycles.
−Removed: • Driving margin expansion and improved returns.
−Removed: We are pursuing strategies to continue to grow earnings, while generating significant positive net cash flow and diversifying into “capital light” flow reinsurance and accretive owned distribution to generate higher return on equity.
+Added: Our evolved ecosystem is built on expanding relationships with key long-term distribution partners, a differentiated asset management approach powered by Blackstone's best-in-class asset origination with a proven track record and complemented by other asset managers, and strategic relationships with reinsurers that provide efficient access to substantial external capital.
+Added: • Proven track record;
+Added: well positioned for steady earnings growth and capital flexibility.
+Added: We have successfully executed on our diversified growth strategy, maintained a strong capital position and made significant progress toward our 2023 Investor Day targets.
+Added: We are positioned to deliver steady earnings growth aligned to pricing over the long term, significant scale benefit and an increasing mix of more stable, predictable and less capital intensive fee-based sources of earnings.
+Added: • Strategic shift to fee-based, less capital intensive for enhanced returns.
+Added: F&G is rapidly transforming into a more fee-based, higher margin and less capital intensive business.
+Added: Increased earnings contributions from fee-based flow reinsurance, middle market life insurance and owned distribution strategies, coupled with disciplined growth in our spread-based products, are expected to generate higher returns over time.
Our Competitive Advantages
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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.
−Removed: • Durable investment management edge.
−Removed: Our strategic partnership with Blackstone provides a sustained competitive advantage for our business.
+Added: • Differentiated asset management approach.
+Added: We have a differentiated asset management approach powered by Blackstone's best-in-class asset origination with a proven track record and complemented by other asset managers.
Our liability profile and risk appetite drives our investment strategy.
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Our high quality, diversified investment portfolio is well positioned to withstand macroeconomic headwinds and continues to perform well.
−Removed: We have enhanced the return while improving the credit quality of our portfolio, and credit related impairments remain low, averaging 7 basis points over the past 3 years, below our pricing assumption.
−Removed: • Clean and profitable in-force book.
+Added: We have enhanced the return while improving the credit quality of our portfolio, and credit related impairments remain low, averaging 6 basis points over the past 5 years, below our pricing assumptions.
+Added: • Clean and profitable inforce book.
As a life insurer, we generate spread earnings based on our assets under management and over the lifetime of the liabilities in place.
Our disciplined new business underwriting process provides us with stable liabilities, primarily in products that reset annually, which has allowed us to achieve consistently attractive lifetime returns.
−Removed: 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: Approximately 93% of our $36.1 billion indexed annuities and fixed rate annuities account value are surrender-charge protected and our asset and liability cash flows are well matched.
Additionally, our funding agreements, pension risk transfer and immediate annuities are non-surrenderable.
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• Clear governance structure.
−Removed: We have a disciplined approach for considering new lines of business to enter, the appropriate product/channel mix for achieving our targeted new business profitability, and the management of our capital and in-force liabilities.
+Added: We have a disciplined approach for considering new lines of business to enter, the appropriate product/channel mix for achieving our targeted new business profitability, and the management of our capital and inforce liabilities.
Further, we target and pursue opportunities that leverage our strengths.
We Play in Large and Growing Markets
−Removed: We serve a market with very attractive demographic tailwinds as more than 10,000 Baby Boomers are retiring every day.
+Added: We serve a market with very attractive demographic tailwinds as more than 11,000 Americans are turning 65 every day according to the U.S.
+Added: Census Bureau.
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.
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.
−Removed: retirement market opportunity is vast and includes the $1.1 trillion U.S.
−Removed: consumer savings market and the $223 billion retail life and annuities market.
−Removed: While insured products are designed to effectively serve the needs of retirees, annuities and life insurance solutions continue to be underutilized.
+Added: retirement market opportunity is vast and includes $5.8 trillion of mutual fund 401(k) assets, $800 billion of U.S.
+Added: consumer savings and the $447 billion retail life and annuities market.
+Added: While insured products are
+Added: designed to effectively serve the needs of retirees, annuities and life insurance solutions continue to be underutilized.
We believe middle market consumers, in particular, lack the guidance they need and want and can benefit greatly from insurance solutions.
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Our entry into these channels was successful, resulting in $19.9 billion of cumulative new business since the launch in 2020 to year-end 2025.
−Removed: In early 2024, we entered into the fast-growing RILA market and have successfully onboarded with seven banker dealer distribution partners.
−Removed: We are focused on adding additional distribution partners and see the potential for RILA sales to ramp up over the medium term.
Annuity sales through the bank and broker-dealer channels were $3.8 billion and $5 billion for the years ended December 31, 2025 and 2024, respectively.
−Removed: The approximate 22 banks and broker-dealers we
−Removed: work with account for 42% of all annuity sales.
+Added: The approximate 26 banks and broker-dealers we work with account for 36% of all annuity sales.
In these retail markets F&G ranks:
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and (iii) 5th in IUL sales in the IMO channel, 8th in the number of IUL policies sold and 7th in IUL industry sales, in each case, for the year to date as of September 30, 2025, as sourced from Wink’s Sales and Market Report.
−Removed: We successfully expanded into new retail channels and diversified our annuity distribution, yet not at the expense of our traditional IMO channel.
−Removed: We grew our IMO channel sales by 41% and 6% during the years ended December 31, 2024 and December 31, 2023, respectively.
+Added: We successfully expanded into new retail channels and diversified our annuity distribution, while continuing to leverage our traditional IMO channel.
+Added: Our IMO channel sales were $6.9 billion and $7.0 billion for the years ended December 31, 2025 and December 31, 2024, respectively.
We continue to invest in our life insurance business, focusing our approach to meet the needs of the underserved middle market which we reach largely through Network Marketing Groups (“NMGs”).
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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.
−Removed: We have invested $680 million in owned distribution partners through the following transactions:
+Added: We have invested approximately $700 million in owned distribution partners through the following transactions:
• In October 2021, we purchased a 30% minority ownership stake in Freedom Equity Group (“FEG”).
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Our competitive asset management advantage through Blackstone allows us to have very competitive offerings in our spread lending products as well as in the PRT market, while still meeting our internal pricing targets.
−Removed: • In addition to our funding agreement business with the Federal Home Loan Bank of Atlanta, (“FHLB”), we now offer the proven ability to originate Funding Agreement Backed Notes (“FABN”), a $210 billion market.
+Added: • In addition to our funding agreement business with the Federal Home Loan Bank of Atlanta, (“FHLB”), we originate Funding Agreement Backed Notes (“FABN”), a $276 billion market.
Our FABN Program (the “FABN Program”) offers funding agreements to institutional clients by means of capital markets transactions through investment banks.
−Removed: 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
−Removed: 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 view FABN as opportunistic and volumes will fluctuate quarter to quarter depending on economics and market opportunity.
+Added: We issued $1.2 billion and $0.6 billion of FABN for the years ended December 31, 2025 and 2024 respectively.
• We also offer PRT solutions to a $45 billion (of $3 trillion total private defined benefit plan assets) market.
Our PRT business is supported by an experienced team with access to brokers and institutional consultants for distribution.
−Removed: 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.
−Removed: Our targeted deal size is approximately $100 million to $1 billion, and we selectively pursue plan termination and larger retiree buyouts.
+Added: We have generated almost $9 billion of cumulative sales since launch in 2021 to year-end 2025, including $2.1 billion and $2.2 billion of sales for the years ended December 31, 2025 and 2024.
+Added: We serve over 145,000 plan participants, who will receive their pension payments from F&G.
+Added: Our targeted deal size is up to $500 million, 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, $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.
−Removed: 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.
+Added: In the pension risk transfer market, F&G ranked 7th in the PRT industry sales for year to date sales through September 30, 2025, 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 entrance into the RILA market in early 2024.
+Added: With the addition of the retail bank and broker-dealer channels and our success in the PRT and funding agreement institutional markets, F&G has diversified our product and distribution capabilities from one primary channel to five, and from one primary product to six.
We completed this expansion over a five-year period and, combined with organic growth in our core IMO channel, increased gross sales by 274%, from $3.9 billion in 2019 to $14.6 billion in 2025.
−Removed: We have reinforced our earnings engine in addition to driving top-line growth.
+Added: We generate spread-based earnings from fixed annuities and pension risk transfer and we have multiple sources of fee-based earnings including the reinsurance sidecar vehicle alongside our flow reinsurance strategy, middle market life insurance and our owned distribution portfolio.
+Added: As our business grows, we are becoming a more fee-based, higher margin and less capital intensive business, leveraging our position as one of the industry’s largest sellers of annuities and life insurance.
+Added: We are balancing this with continuing to grow our spread-based business, prioritizing pricing discipline and allocating capital to the highest return opportunities.
We have acquired and retained customers through the years, growing AUM from $26.5 billion at the time of FNF’s acquisition to $57.6 billion as of December 31, 2025.
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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 enabled the Company to achieve profitable double digit sales growth.
−Removed: 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 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.
+Added: Further, the strength of our distribution partner relationships and pension risk transfer growth strategy has enabled the Company to achieve profitable sales growth.
+Added: We have made significant progress toward the medium term financial targets we laid out at our 2023 Investor Day to grow AUM, expand adjusted ROA, increase adjusted ROE, and expand our earnings multiple.
+Added: We are well positioned to deliver on our targets as we move further toward a more fee-based, higher margin, and less capital intensive business model, leveraging our position as one of the industry’s largest sellers of annuities and life insurance.
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
−Removed: transactions.
+Added: As noted above, in 2021, we launched into two institutional markets to originate FABN and PRT transactions.
These markets leverage our existing team's spread-based capabilities as well as our strategic partnership with Blackstone.
+Added: We view our products in two categories:
+Added: “core” and “opportunistic”.
+Added: Our “core” products include fixed indexed annuities, registered index-linked annuities, pension risk transfer and indexed universal life.
+Added: Our “opportunistic” products include multi-year guaranteed annuities, FABN and Federal Home Loan Bank funding agreements.
+Added: Opportunistic sales fluctuate quarter to quarter depending on economics and market opportunity, and we prioritize pricing discipline and allocate capital to the highest return opportunities.
For the year ended December 31, 2025, FIAs generated approximately 46% of our gross sales.
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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 equity options are one-year options purchased to match the funding requirements underlying the FIA/IUL contracts.
+Added: The majority of all
+Added: 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.
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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.
−Removed: 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
−Removed: range from 50% to 250% of the performance of the applicable market index.
+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 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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Deferred Annuities - RILA – In early 2024, we entered into the RILA markets.
−Removed: 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.
+Added: RILAs are similar to FIAs in offering the policyholder the opportunity for tax-deferred growth based in part on the performance of a market
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.
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The penalty period typically ranges from seven to fourteen years for FIAs and three to ten years for fixed rate annuities.
−Removed: This surrender charge initially ranges from 8% to 14% of the contract value for FIAs and is 8% of the contract value for fixed rate annuities and generally decreases by approximately one to two percentage points per year during the penalty period.
+Added: This surrender charge initially ranges from 7% to 15% of the contract value for FIAs and is approximately 9% of the contract value for fixed rate annuities and generally decreases by approximately one to two percentage points per year during the penalty period.
The average surrender charge was 7% for our FIAs and 7% for our fixed rate annuities as of December 31, 2025.
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
−Removed: formula that accounts for changes in interest rates since contract issuance.
+Added: The MVA is based on a 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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Holders of universal life insurance policies may make periodic payments over the life of the contract and earn returns on their policies, which are credited to the policyholder’s cash value account.
−Removed: The insurer periodically deducts its expenses and the cost of life insurance protection from the cash value account.
+Added: insurer periodically deducts its expenses and the cost of life insurance protection from the cash value account.
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.
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The maximum aggregate principal amount permitted to be outstanding at any one time under the FABN Program is currently $5.0 billion.
−Removed: As of December 31, 2024, we had approximately $2.5 billion outstanding under the FABN Program.
+Added: As of December 31, 2025, we had approximately $3.3 billion outstanding under the FABN Program with an additional $750 million issued in January 2026.
Pension Risk Transfer.
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Please refer to Note E - Reinsurance to our Consolidated Financial Statements included in Part II - Item 8 of this Annual Report on Form 10-K for further discussion on reinsurance, reinsurance recoverables for our largest reinsurers and credit risk and counterparty risk.
−Removed: Please refer to “ Risk Factors ” for additional details regarding credit risk related to reinsurance agreements.
+Added: Please refer to “ Risk Factors - We are subject to the credit risk of our counterparties, including companies with whom we have reinsurance agreements or from whom we have purchased options” for additional details regarding credit risk related to reinsurance agreements.
A description of significant ceded reinsurance transactions appears below.
Wilton Reinsurance Transaction .
−Removed: Almost all of the life insurance policies in force issued before March 1, 2010, except for the return of premium benefits on term life insurance products, are subject to a reinsurance arrangement with Wilton Reassurance Company (“Wilton Re”).
−Removed: Pursuant to the agreed upon terms, Wilton Re purchased through a 100% quota share reinsurance agreement certain FGL Insurance life insurance policies that are subject to redundant reserves, reported on a statutory basis, under Regulation XXX and Guideline AXXX, as well as another block of FGL Insurance’s in-force traditional, universal life and IUL insurance policies.
+Added: Almost all of the life insurance policies inforce issued before March 1, 2010, except for the return of premium benefits on term life insurance products, are subject to a reinsurance arrangement with Wilton Reassurance Company (“Wilton Re”).
+Added: Pursuant to the agreed upon terms, Wilton Re purchased through a 100% quota share reinsurance agreement certain FGL Insurance life insurance policies that are subject to redundant reserves, reported on a statutory basis, under Regulation XXX and Guideline AXXX, as well as another block of FGL Insurance’s inforce traditional, universal life and IUL insurance policies.
The effects of this agreement are accounted for as reinsurance as the ceded policies qualify as insurance products and because the agreement satisfies the risk transfer requirements for GAAP.
Hannover Reinsurance Transaction.
−Removed: 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.
+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 inforce 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.
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To enhance Kubera's ability to pay its obligations under the amended reinsurance agreement, F&G entered into a Variable Note Purchase Agreement (the “NPA”), whereby F&G agreed to fund a note to Kubera to be used to ultimately settle with F&G, with principal increases up to a maximum amount of $435 million, to the extent a potential funding shortfall (treaty assets are less than the total funding requirement) is projected relative to the business ceded to Kubera from F&G as part of the amended reinsurance agreement.
−Removed: The potential funding shortfall will be determined quarterly and, among other items, is impacted by the market value of the assets in the funds withheld account related to the reinsurance agreement and Kubera's capital as calculated on a Bermuda regulatory basis.
+Added: The potential funding shortfall will be determined quarterly and, among other items, is impacted by the market value of the assets in the funds
+Added: withheld account related to the reinsurance agreement and Kubera's capital as calculated on a Bermuda regulatory basis.
The NPA matures on November 30, 2071.
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Effective December 1, 2023, FGL Insurance executed an additional coinsurance funds withheld agreement with Somerset to cede certain flow MYGA business written effective on or after December 1, 2023.
−Removed: 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: As the policies ceded to Somerset are investment contracts, there is no significant insurance risk present and these portions of the reinsurance agreements are accounted for as separate investment contracts.
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.
2 unchanged sentences
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 therefore the reinsurance agreement is accounted for as a separate investment contract.
−Removed: 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: Effective January 1, 2025, FGL amended the flow reinsurance agreement 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.
The amendment included a cession of an inforce block of certain MYGA policies on a coinsurance quota share basis.
−Removed: Aspida Reinsurance Transaction.
+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: Aspida Reinsurance Transactions.
FGL Insurance has a reinsurance agreement with Aspida Life Re Ltd.
1 unchanged sentence
As the policies ceded to Aspida Re are investment contracts, there is no significant insurance risk present and therefore the reinsurance agreement is accounted for as a separate investment contract.
+Added: FGL Insurance entered into a reinsurance agreement with Aspida Re Cayman Ltd.
+Added: (“Aspida Re Cayman”), an unaffiliated reinsurer, to cede certain flow MYGA business, on a funds withheld coinsurance basis, net of applicable existing reinsurance, written effective on or after November 1, 2025.
+Added: As the policies ceded to Aspida Re Cayman are investment contracts, there is no significant insurance risk present and therefore the reinsurance agreement is accounted for as a separate investment contract.
New Re Reinsurance Transaction.
1 unchanged sentence
Effective July 1, 2023, this agreement was amended to reinsure additional FIA products.
−Removed: The coinsurance quota share is only applicable to the base contract benefits under the FIA policies.
−Removed: The yearly renewable term is applicable to the waiver of surrender charges and return of premium.
−Removed: The effects of this agreement are not accounted for as reinsurance as it does not satisfy the risk transfer requirements for GAAP;
−Removed: therefore, deposit accounting is applied and FGL Insurance applies the right of offset in the reinsurance agreement.
+Added: The coinsurance quota share is applicable to the base contract benefits under the FIA policies and the yearly renewable term is applicable to the waiver of surrender charges and return of premium.
+Added: Effective October 1, 2025, this agreement was recaptured and terminated and FGL Insurance entered into a new indemnity reinsurance agreement with Munich Re to cede certain inforce and future flow FIA policies on a coinsurance basis, applicable to the base contract benefits, waiver of surrender charges, and minimum guaranteed surrender value benefits and for certain FIA policies, return of premium rider and minimum interest credit rider benefits.
+Added: The effects of these agreements are not accounted for as reinsurance as they do not satisfy the risk transfer requirements for GAAP;
+Added: therefore, deposit accounting is applied and FGL Insurance applies the right of offset in the reinsurance agreements.
The CARVM Facility.
15 unchanged sentences
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
−Removed: 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 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 $2,400 million as of December 31, 2024.
13 unchanged sentences
In connection with the agreement, F&G Cayman Re entered into a financing agreement with Deutsche Bank AG (“DB”), operating out of its New York branch, whereby DB issued a letter of credit used to support the coinsured general account statutory reserves (generally considered to be the non-economic reserves).
+Added: IUL YRT Reinsurance:
+Added: Effective January 1, 2025, F&G entered into separate flow reinsurance agreements with several unaffiliated reinsurers to reinsure mortality risk on certain new IUL policies and effective July 1, 2025, F&G entered into additional separate reinsurance agreements with several unaffiliated reinsurers to reinsure mortality risk on certain inforce IUL policies.
+Added: In accordance with the terms of these agreements, F&G cedes the net amount at risk on the IUL policies, which is the difference between the stated death benefit and the contractholder funds balance, on a yearly renewable term basis.
+Added: The effects of these agreements are accounted for as reinsurance as the ceded policies qualify as insurance products and the agreements satisfy the risk transfer requirements for GAAP.
+Added: New Reinsurance Vehicle:
+Added: During the third quarter of 2025, F&G announced the launch of a strategic partnership with a new reinsurance vehicle backed by Blackstone managed funds, with approximately $1 billion in anticipated capital commitments.
+Added: Effective August 1, 2025, F&G executed this forward flow reinsurance agreement with Fort Greene Reinsurance SPC Limited Segregated Portfolio No.
+Added: 1, (“Fort Greene”) to cede certain FIA policies on a coinsurance funds withheld quota share basis and certain funding agreements on a modified coinsurance basis.
+Added: F&G does not hold any ownership stake in the unaffiliated Fort Greene entity.
+Added: As the policies ceded to Fort Greene 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 December 1, 2025, FGL Insurance recaptured a portion of the reinsurance agreement with its affiliate F&G Life Re, covering a quota share of certain FIA policies.
+Added: All intercompany balances have been eliminated in the preparation of the accompanying Consolidated Financial Statements.
+Added: See Note E - Reinsurance to our Consolidated Financial Statements included in Part II - Item 8 of this Annual Report on Form 10-K.
Our Retail Distribution Channels
23 unchanged sentences
Bank and broker-dealers represented 36% of annuity sales for the year ended December 31, 2025.
−Removed: 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.
+Added: The top five states for the distribution of F&G’s retail products in the year ended December 31, 2025 were California, Florida, Pennsylvania, Texas and New Jersey, which together accounted for 40% of F&G’s retail sales.
Our Investment Management Governance and Approach
14 unchanged sentences
however, BIS has the right to manage (and receive fees based on) all assets in the F&G Accounts with limited exceptions.
−Removed: For certain asset classes, we continue to utilize specialized third-party investment managers.
+Added: One such exception relates to non-affiliated funds‑withheld reinsurance agreements, pursuant to which third‑party asset managers are responsible for all aspects of investment management for the associated assets.
+Added: In these arrangements, the F&G investment team retains governance oversight, including monitoring compliance with the investment guidelines negotiated between F&G and the respective third‑party managers to ensure alignment with our investment objectives, risk parameters and applicable regulatory requirements.
+Added: In addition, for certain asset classes, including consolidated variable interest entities, we utilize specialized third-party investment managers.
As of December 31, 2025, approximately 78% of our $69 billion investment portfolio was managed by BIS, with 20% managed by other third parties, and the remaining 2% internally managed.
4 unchanged sentences
• 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
−Removed: 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 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 $182 million, $203 million and $194 million for the years ended December 31, 2025, 2024 and 2023, respectively.
−Removed: 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: Effective January 1, 2025, FGL NY Insur ance 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 .
FGL NY Insurance terminated its current IMA with its current investment manager effective December 31, 2024.
17 unchanged sentences
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 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
+Added: 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.
3 unchanged sentences
We also have a small amount of equity holdings required as part of our funding arrangements with the FHLB.
−Removed: Over the year, we have hedged a portion of the existing floating rate asset exposure in the portfolio.
−Removed: In addition to hedging the existing floating-rate assets, subject to the broader macro and interest rate environment, we will also look to hedge a significant share of new purchases of floating-rate assets.
+Added: The Company employs hedging strategies to manage exposure to floating interest rates on a portion of its existing and newly acquired floating‑rate assets, subject to market conditions.
+Added: The Company also uses foreign exchange hedging instruments to manage exposure to non‑U.S.
+Added: dollar‑denominated investments by economically converting such exposures to U.S.
+Added: dollars, with the objective of reducing volatility in earnings resulting from changes in interest rates and foreign exchange rates.
The portfolio also has exposure to U.S.
18 unchanged sentences
These include investment limits by asset class, ratings and issuer.
−Removed: Liquidity risk is managed through frequent forecasting of sources and uses of cash and managed to our Liquidity Policy.
+Added: Liquidity risk is managed
+Added: 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.
33 unchanged sentences
Outlooks should not be confused with expected stability of the issuer’s financial or economic performance.
−Removed: A rating may have a
−Removed: “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 “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.
1 unchanged sentence
Best S&P Fitch Moody’s
−Removed: Holding Company & Security Ratings
+Added: Holding Company and Security Ratings
F&G Annuities & Life, Inc.
4 unchanged sentences
Not Rated BB BB Ba1
−Removed: CF Bermuda Holdings Limited
−Removed: Issuer Credit / Default Rating Not Rated BBB- BBB Baa3
−Removed: Outlook Stable Stable Stable
−Removed: Fidelity & Guaranty Life Holdings, Inc.
−Removed: Issuer Credit / Default Rating BBB BBB- BBB Not Rated
−Removed: Outlook Stable Stable Stable
Operating Subsidiary Ratings
6 unchanged sentences
F&G Life Re Ltd
−Removed: Financial Strength Rating Not Rated A- A- A3
−Removed: Outlook Stable Stable Stable
+Added: Financial Strength Rating Not Rated Not Rated Not Rated A3
+Added: Outlook Stable
F&G Cayman Re Ltd
2 unchanged sentences
(a) Reflects rating of $375 million Junior Subordinated Notes due 2065 issued in January 2025
−Removed: (b) Ratings removed for Fidelity & Guaranty Life Holdings, Inc.
−Removed: 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.
7 unchanged sentences
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
−Removed: of our derivatives as of December 31, 2024, we hold no net short positions against a counterparty;
+Added: Based on the fair value of our derivatives as of December 31, 2025, we hold no net short positions against a counterparty;
therefore, we were not required to post collateral at December 31, 2025.
38 unchanged sentences
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 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.
−Removed: The IID is currently in the process of executing a market conduct exam for the five year period ending 2022.
−Removed: Results of the most recent market conduct exam have not been finalized.
+Added: The IID last completed a routine financial examination and a market conduct examination of FGL Insurance for the five year period ending December 31, 2022 and found no material deficiencies and proposed no adjustments to the financial statements as filed.
The NYDFS last completed a routine financial examination of FGL NY Insurance for the five year period ended December 31, 2022, and found no material deficiencies and proposed no adjustments to the financial statements as filed.
−Removed: The NYDFS 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.
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.
28 unchanged sentences
FGL Insurance’s estimated U.S.
−Removed: RBC ratio was over 410% as of December 31, 2024, above our 400% target.
+Added: RBC ratio was approximately 430% as of December 31, 2025, 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.
10 unchanged sentences
each ratio has a “usual range” of results.
−Removed: 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.
−Removed: 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.
−Removed: The IRIS ratio for change in premium ratio for FGL NY Insurance was outside the usual range.
+Added: As of December 31, 2025, FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re had three, one, two and four ratios outside the usual range, respectively.
+Added: The IRIS ratios for “net income to total income (including realized capital gains and losses)”, “total affiliated investments to capital and surplus” and “surplus relief - over $5 million capital and surplus” for FGL Insurance were outside the usual range.
+Added: The IRIS ratio for “change in reserving 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.
6 unchanged sentences
The amendments implement the annual filing requirement for the group capital calculation but will not become effective until adopted by state legislatures or regulatory agencies.
−Removed: Legislation was introduced in New York in May 2022 that would require a group capital calculation.
−Removed: FNF’s lead regulator, which is also the Company’s lead regulator for this purpose, has not yet adopted a requirement for group capital.
+Added: FNF’s lead regulator, the Florida Office of Insurance Regulation, which is also the Company’s lead regulator for this purpose, adopted a requirement for group capital reporting in late 2025 that will be effective for year-end 2026 with filing required in the first half of 2027.
Insurance Reserves
36 unchanged sentences
In addition, FGL Insurance and FGL NY Insurance must file, and in many jurisdictions and for some lines of business obtain regulatory approval for, rates and forms relating to the insurance written in the jurisdictions in which they operate.
−Removed: FGL Insurance is currently the subject of two ongoing market conduct examinations in various states.
+Added: FGL Insurance is currently the subject of an ongoing market conduct examination in one state.
Market conduct examinations can result in monetary fines or remediation and generally require FGL Insurance to devote significant resources to the management of such examinations.
−Removed: FGL Insurance does not believe that any of the current market conduct examinations it is subject to will result in any fines or remediation orders that will be material to its business.
+Added: FGL Insurance does not believe that the current market conduct examination it is subject to will result in any fines or remediation orders that will be material to its business.
Regulation of Investments
2 unchanged sentences
We believe that the investment portfolios of FGL Insurance, FGL NY Insurance, Raven Re and Corbeau Re as of December 31, 2025, complied in all material respects with such regulations.
−Removed: In 2023, the NAIC released new regulations the define a residual interest.
−Removed: All the Company’s impacted insurance subsidiaries have complied with the new regulations.
−Removed: Beginning January 1, 2025, these investments will be subject to a new accounting model, which the Company is currently in the process of implementing.
−Removed: Also in 2023, the NAIC released new regulations that define the criteria for investments that can be classified as a bond, which the Company is currently in the process of implementing for all of its impacted insurance subsidiaries.
+Added: In 2023, the NAIC released new regulations that define a residual interest and new criteria for investments that can be classified as a bond.
+Added: All of the Company’s impacted insurance subsidiaries have implemented the new accounting requirements beginning January 1, 2025.
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
−Removed: 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.
−Removed: 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.
+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 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: As a result, the NAIC has issued several clarifying revisions to the
+Added: guidance and disclosure requirements for related party and affiliated securities and continues to consider additional proposals and disclosure requirements.
In addition, the NAIC continues to refine its application of RBC factors for certain investments.
6 unchanged sentences
The Dodd-Frank Act
−Removed: The Dodd-Frank Wall Street Reform and Consumer Protection Act (“The Dodd-Frank Act”) established the Federal Insurance Office within the U.S.
−Removed: Department of the Treasury to monitor the insurance industry.
+Added: The Dodd-Frank Wall Street Reform and Consumer Protection Act (“The Dodd-Frank Act”) established the Federal Insurance Office (“FIO”) within the U.S.
+Added: Department of the Treasury to monitor all aspects of the insurance industry and of lines of business other than certain health insurance, certain long-term care insurance and crop insurance.
+Added: Although the FIO currently does not directly regulate the insurance industry, FIO does monitor and scrutinize developments in the industry.
+Added: FIO publications or reports, some of which are periodically submitted to Congress, could continue to increase scrutiny of the industry and ultimately lead to changes in the regulation of insurers and reinsurers in the United States, which could negatively impact our insurance business.
The Dodd-Frank Act made sweeping changes to the regulation of financial services entities, products and markets.
Certain provisions of the Dodd-Frank Act are applicable to us, our competitors or those entities with which we do business.
+Added: Further, certain provisions of the Dodd-Frank Act may become applicable to us, our competitors, or certain entities with which we do business.
These provisions may impact us in many ways, including, but not limited to, having an effect on the overall business climate, requiring the allocation of certain resources to government affairs, and increasing our legal and compliance related activities and the costs associated therewith.
+Added: For example, it is possible that regulations issued by the Consumer Financial Protection Bureau may extend, or be interpreted to extend, to the sale of certain insurance products by covered financial institutions, which could adversely affect sales of such products.
+Added: The FIO, in response to various studies it conducts, may also recommend changes in laws or regulations that affect our business.
+Added: There may be further federal involvement in the business of insurance in the future, which may add significant legal complexity and associated costs to our business.
Under the Dodd-Frank Act, annuities that meet specific requirements, including requirements relating to certain state suitability rules, are specifically exempted from being treated as securities by the SEC.
3 unchanged sentences
However, our RILA product is not exempted from being treated as a security by the SEC.
−Removed: Additionally, the Dodd-Frank Act established the Financial Stability Oversight Council (“FSOC”), which plays a role in shaping the regulatory environment affecting RILAs.
−Removed: 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.
−Removed: 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.
+Added: Additionally, the Dodd-Frank Act established the Financial Stability Oversight Council (“FSOC”), which plays a role in shaping the regulatory environment affecting RILAs and other insurance products that are connected to the
+Added: capital markets.
+Added: The FSOC monitors systemic risks and may designate insurers offering RILAs, as well as certain other products, 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 (Risk-Based Capital) 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
5 unchanged sentences
The amended model regulation also requires agents to provide certain disclosures to consumers, obligates insurers to supervise agent compliance with the new requirements, and prohibits sales contests or other incentives based on sales of specific annuities within a limited period of time.
−Removed: Several states have adopted the revised NAIC model regulation, including FGL Insurance’s domiciliary state of Iowa.
+Added: All 50 states have adopted the revised NAIC model regulation, including FGL Insurance’s domiciliary state of Iowa.
Management has instituted business procedures to comply with these revised requirements where required.
7 unchanged sentences
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.
−Removed: Meanwhile, the DOL has publicly announced its intention to consider future rulemaking that may revoke or modify PTE 84-24.
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.
−Removed: 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
−Removed: best interest.
+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
+Added: 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 best interest.
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.
3 unchanged sentences
On July 25, 2024, in the case of Federation of Americans for Consumer Choice, Inc., et al.
−Removed: United States Department of Labor, et al.
−Removed: , (“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.
−Removed: The District Court, in part relying on the Supreme Court’s recent ruling in Loper Bright Enterprises v.
−Removed: 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.
−Removed: As a result, the Final Rule’s original effective date of September 23, 2024 has been delayed until further notice.
+Added: United States Department of Labor, et al., (“Federation of Americans”) the United States District Court for the Eastern District of Texas (the “Eastern District of Texas”) issued an order staying the effective date of the DOL’s New Fiduciary Rule (and related amendments to PTE 84-24) that was issued in March 2024.
+Added: The Eastern District of Texas, 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 New Fiduciary Rule improperly expanded the definition of an “investment advice fiduciary” under ERISA.
+Added: As a result, the New Fiduciary Rule’s original effective date of September 23, 2024 was delayed until further notice.
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.
−Removed: United States Dep’t of Labor, et al.
−Removed: , 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: United States Dep’t of Labor, et al., held the remaining PTE amendments included in the New Fiduciary 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 New Fiduciary Rule.
On September 20, 2024, the DOL appealed both rulings to the Fifth Circuit Court of Appeals.
−Removed: 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.
−Removed: The motion was granted so the appeals are in abeyance.
−Removed: 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.
−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 we supervise our distribution force, compensation practices and liability exposure and costs.
+Added: In early 2025, the DOL filed successive unopposed motions 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 motions were granted so the appeals were in abeyance.
+Added: In November 2025, the DOL moved to voluntarily dismiss their appeals and the Fifth Circuit agreed and remanded the cases to the District Courts.
+Added: The DOL has moved the District Courts to allow until March 2026 to determine their position and next steps with the cases.
+Added: Adverse Texas District Court rulings could have harmful effects on the insurance industry, creating additional hurdles to operate our business.
+Added: We cannot predict the final outcome of the pending litigation regarding the New Fiduciary Rule, however, 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, all of which could adversely impact our business, results of operations and/or financial condition.
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.
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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— L egal, 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—Legal, 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”)
−Removed: 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”) on adjusted financial statement income and a 1% excise tax on treasury stock repurchases.
These provisions were effective January 1, 2023.
For purposes of calculating the adjusted financial statement income, the Company is included in the controlled group of FNF, its parent company.
+Added: Beginning in 2026, the Company will not be eligible to file a consolidated return with FNF, but would still be subject to CAMT as the Company is still considered an applicable corporation due to FNF's ownership.
Though the Company is subject to the minimum tax, the Company does not expect to be in a perpetual CAMT position.
−Removed: 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 years ended December 31, 2024 and 2023, the Company was subject to CAMT, but there was no impact to total tax.
−Removed: A CAMT credit carryforward was created and is expected to be able to be utilized in future years.
+Added: The Company was not subject to CAMT in 2023, but was for 2024 and 2025, but there was no impact to total tax.
+Added: A CAMT credit carryforward from 2024 was created and is expected to be able to be utilized in future years.
On November 15, 2021, NYDFS issued final Guidance for New York Domestic Insurers on Managing the Financial Risks from Climate Change, detailing NYDFS’s expectations related to domestic insurers' management of the financial risks from climate change.
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F&G Life Re is regulated by the Bermuda Monetary Authority (“BMA”).
+Added: On February 19, 2026, the Company announced the expected sale of its Bermuda based subsidiary, F&G Life Re, to Ancient Financial Holdings, LP (“Ancient”).
+Added: Blackstone will retain asset management for the inforce assets and Ancient will manage assets under a new flow reinsurance treaty for certain MYGA new business.
+Added: transaction is expected to be completed on March 1, 2026.
+Added: The transaction reflects F&G’s disciplined execution of risk transfer options and that we no longer needed a Bermuda operation to support our reinsurance strategy.
The Bermuda Insurance Act provides that no person may carry on an insurance business in or from within Bermuda unless registered as an insurer under the Bermuda Insurance Act by the BMA.
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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.
−Removed: 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.
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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 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.
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(ii) 2% of first $500,000,000 of assets plus 1.5% of assets above $500,000,000;
−Removed: and (iii) 25% of that insurer’s enhanced capital requirement (“ECR”).
+Added: and (iii) 25% of that insurer’s
+Added: enhanced capital requirement (“ECR”).
An insurer may file an application under the Bermuda Insurance Act to waive the aforementioned requirements.
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Block Transactions
−Removed: 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: 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
+Added: transaction that covers an existing long-term business policy that is written and inforce and on the books of the cedant, as of the date of the reinsurance transaction (including pension risk transfer transactions).
Affiliate, Related Party or Connected Party Assets
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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
−Removed: 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 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.
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The laws and regulations of the Cayman Islands require that, among other things, F&G Cayman Re maintain minimum levels of statutory capital, surplus and liquidity, meet solvency standards, submit to periodic examinations of its financial condition and restrict payments of dividends and reductions of capital.
−Removed: Statutes, regulations and policies that F&G Cayman Re is subject to may also restrict the ability of F&G Cayman Re to write insurance and reinsurance policies, make certain investments and distribute funds.
+Added: Statutes, regulations and policies that F&G Cayman Re is subject to may also restrict the ability of F&G Cayman Re to write insurance and
+Added: reinsurance policies, make certain investments and distribute funds.
Any failure to meet the applicable requirements or minimum statutory capital requirements could subject it to further examination or corrective action by CIMA, including restrictions on dividend payments, limitations on our writing of additional business or engaging in finance activities, supervision or liquidation.
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None of our employees are subject to collective bargaining agreements.
−Removed: We consider our relations with our employees to be good.
+Added: We consider relations with our employees to be good.
Talent Management
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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
−Removed: 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 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 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 generation 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.
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The Gallup Employee Engagement survey data is our key metric to support strategic decisions on engaging and retaining our talent.
−Removed: Initiatives such as our Employee Resource Groups and our Connection Week program are a few examples of programs that were identified based on our employee engagement data.
+Added: Initiatives such as our Employee Resource Groups and our Connection Week program are a few examples of programs that were identified based on employee engagement data.
At F&G, we provide comprehensive benefits designed to meet the needs of our employees and demonstrate the value they bring to the organization.
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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, lifestyle reimbursements, charitable matching donations, and adoption assistance.
+Added: Other benefit offerings include health care and dependent care flexible spending accounts, employee assistance programs, lifestyle reimbursements, charitable matching donations, and adoption assistance.
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.
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Community engagement
−Removed: F&G focuses its community engagement and charitable giving to support essential needs such as food insecurity and housing.
+Added: F&G’s mission is to help people turn their aspirations into reality.
+Added: F&G recognizes that focusing its community engagement and charitable giving to support essential needs is critical to fulfilling that mission.
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.
Other community investments include:
−Removed: • 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: • Serving as founding partner of the American Council of Life Insurer’s 360 Community Capital Initiative to make housing affordable and sustainable in underserved communities.
• 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 16 hours of paid time off per year for volunteering.
• 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: • Supporting Junior Achievement of Central Iowa, helps young people gain the knowledge and skills to own their own economic success, plan for their futures, and make smart academic and economic decisions.
+Added: • Supporting Ellipsis, which is a care provider for kids and families in Iowa that provides residential care and treatment, counseling and therapy, behavioral health intervention services, care coordination, and family support through volunteering.
+Added: • Supporting ChildServe which is an organization that improves the health and well-being of thousands of children each year through specialized clinical, home, and community-based programs and services.
Operational Sustainability
−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.
+Added: F&G is committed to sustainable practices that serve our employees, business partners, and community.
+Added: F&G recognizes the rapidly evolving regulatory environment on climate-related risks and is monitoring to ensure sustainability practices remain consistent with regulatory requirements.
F&G also promotes flexible work from home arrangements which reduce commute time, greenhouse gas emissions, and paper usage.
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Such risks may include climate risks as a subset of investment risks.
−Removed: 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: The Company’s Chief Risk and Audit Officer (“CRAO”) will continue to update the AC on F&G’s climate risk profile as risks and opportunities arise.
Management’s Role in Assessing and Managing Sustainability Risks and Opportunities
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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.
−Removed: 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 ERMC is an enterprise committee which includes the Chief Executive Officer, President an d Chief Financial Officer, Chief Liability Officer and Treasurer, Chief Operating Officer, Chief Investment Officer, Chief Risk & Audit Officer, Chief Information Officer, Chief of Government, Regulatory and Compliance Affairs, Chief Human Resource Officer, Investments Chief Operating Officer, Head of Operational Risk, Senior Advisor, and General Counsel and Secretary and is responsible for reviewing risks and associated strategy across the business.
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 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.
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Impact of pending and passed legislation
−Removed: Developments in national, state, and international regulations related to ESG and climate risk are ever-changing.
+Added: Developments in national, state, and international regulations related to Sustainability and climate risk are ever-changing.
F&G is diligently working to identify and gather the appropriate data for evolving reporting standards.
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states and international jurisdictions in which we sell our products have phased in, or are phasing in, emission regulations setting maximum emission standards.
−Removed: 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: The state of California passed two bills that will require certain companies doing business in the state to disclose GHG emissions and climate-related financial risk information.
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.
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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.
−Removed: Capital expenditures related to climate change
−Removed: Current expenditures related specifically to climate change have been minimal.
−Removed: F&G added a sustainability module to the Governance, Risk, and Compliance application to maintain risk information and metrics related to sustainability efforts.
−Removed: 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: Investment Portfolio climate scenario analysis
−Removed: F&G conducted a one-time pilot scenario analysis exercise with the advisory support of Baringa using BlackRock’s Aladdin Climate technology (incorporating Baringa’s industry-leading Climate Change Scenario Model).
−Removed: This analysis included an overall scenario analysis on the investment portfolio and assessed the transition risks by asset class and sector for the portfolio using different climate scenarios.
−Removed: The overall scenario analysis covered multiple industry-recognized scenarios, including a 2°C or lower scenario.
−Removed: For the pilot portfolio temperature alignment was calculated, aligning F&G’s pilot portfolio with a warming trajectory through 2050.
−Removed: The analysis also included an assessment of physical risk of three commercial properties held in the F&G portfolio.
−Removed: The evaluation included electricity and gas expenditures, outdoor labor costs, vulnerability to rising sea levels, and weather-related catastrophes.
−Removed: The overall results of the pilot scenario analysis indicated larger impacts under the Orderly and Disorderly scenarios by 2050, as expected, highlighting energy-intensive industries.
−Removed: Utilities saw larger variability between the issuers, while energy and airlines saw more uniform impacts.
−Removed: Automobile manufacturers saw the largest impact and variability, while financials and structured products had smaller impacts.
−Removed: 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
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Updates to the policy are determined by the ERM leadership team.
−Removed: The ERM process includes a risk appetite statement which outlines the level of acceptable risk in the pursuit of overall financial and strategic objectives.
−Removed: Risk appetite statements and risk tolerances are linked to the strategic objectives set out in the corporate plan and are stressed using a variety of multifactor scenarios.
+Added: The ERM process includes risk appetite statements and risk tolerances that are linked to the strategic objectives set out in the corporate plan and are stressed using a variety of multifactor scenarios.
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 31000, and captured in a risk library.
−Removed: The taxonomy includes four parent categories:
−Removed: Operational, Governance/Strategy, Product/Distribution, and Investments.
−Removed: These four parent categories are broken down further into 31 sub-categories (IMO/Agent Servicing, Business Continuity/Disaster Recovery, Third-Party Administration/Outsourcing, Fraud, Human Resources/People, Policy Administration, IT Systems, Information Security, Accounting and Financial Reporting, Actuarial and Governance Operations, Project Management, Model Risk, Compliance, Capital Management, Risk Management, Business Strategy, Corporate Governance, Marketing/Communications, ESG, Legal/Litigation, Regulatory Environment, Reputation, Pricing and Product Design, Product Governance, In-force Performance Management, Distribution, Asset Liability Management (“ALM”), Investment Guidelines and Compliance, Credit, Foreign Exchange, and Liquidity Risk).
−Removed: The library identifies risk ownership, corresponding risk limits, and high-level controls for monitoring, reporting, and mitigating material risks.
+Added: Risks are defined in the risk taxonomy and includes four parent categories:
+Added: Operational, Product, Financial & Investment, and Strategy.
Risks are identified via ongoing discussions between ERM and the business partners, as well as through monitoring of industry groups and publications.
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The quarterly self-assessment results are reported in the ERM dashboard to the ERMC.
−Removed: The dashboard reflects the residual risk ratings at the sub-category level for the Enterprise, and the direction the risk is trending (increasing, decreasing, stable).
−Removed: 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: 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 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.
−Removed: 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.
−Removed: As a life insurance and annuities company, physical climate risks that are material risks for property and casualty insurers are less impactful.
−Removed: Climate-related underwriting risk (mortality/morbidity) is monitored within the overall risk framework, although it is not considered material to F&G’s overall business.
+Added: The dashboard reflects the residual risk ratings at the sub-category level for the Enterprise.
+Added: F&G monitors risks via an annual risk assessment, annual cybersecurity assessment, the quarterly risk self-assessments, quarterly ERMC meetings, monthly Investment Committee meetings, monthly Capital Committee meetings, and ad hoc analysis.
+Added: The overall risk posture of the organization is updated in the ERMC meeting report that includes a CRAO assessment, emerging risks, ERM dashboard, market risk discussion, stress testing results, and risk appetite measures.
F&G recognizes the rapidly evolving regulatory environment on climate-related risks and opportunities and has a regulatory monitoring process.
−Removed: The ongoing monitoring of ESG-related regulations is included in the overall regulatory monitoring process overseen by the Legal Department.
−Removed: Any new regulation passed related to ESG is entered into the Comply On Demand Enterprise system and assigned to subject matter experts for review.
+Added: The ongoing monitoring of sustainability regulations is included in the overall regulatory monitoring process overseen by the Legal Department.
+Added: Any new regulation passed related to sustainability is entered into the Comply on Demand Enterprise system and assigned to subject matter experts for review.
If policy or procedure changes are required, the implementation of those changes is monitored through this system.
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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 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.
−Removed: Our primary asset manager generally considers material sustainability factors a key part of evaluating new investments.
−Removed: By considering applicable sustainability factors in the investment process, they aim to identify and address material investment risks and opportunities.
−Removed: 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.
+Added: Investment risk is one of the largest sources of risk to the Company, and the Vice President, Head of Investment Risk and the Chief Investment Officer and Senior Vice President, Investments Chief Operating Officer are responsible for integrating sustainability practices, including understanding and managing climate-related risks, into F&G’s investment process.
Metrics and Targets
−Removed: F&G is evaluating how climate-related metrics can be leveraged to better understand the potential risks and opportunities to our business.
−Removed: F&G anticipates conducting an expanded quantitative analysis of the investment portfolio, as well as considering other metrics and proactive contributions to reduce uncertainty, filling data gaps, and working with investment managers and other stakeholders to collect additional data about climate risks.
−Removed: F&G anticipates gathering Scope 1 and Scope 2 emissions in the coming year for additional office locations in New York, Bermuda and Cayman.
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
−Removed: management framework.
−Removed: 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.
+Added: F&G will continue to monitor risks and opportunities related to our climate risk assessment.
Available Information
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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.