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STATUTORY FINANCIAL DATA AND RESTRICTIONS
12 Months Ended
Dec. 31, 2014
STATUTORY FINANCIAL DATA AND RESTRICTIONS  
STATUTORY FINANCIAL DATA AND RESTRICTIONS

20. STATUTORY FINANCIAL DATA AND RESTRICTIONS

The following table presents statutory net income (loss) and capital and surplus for our Non-Life Insurance Companies and our Life Insurance Companies in accordance with statutory accounting practices:

(in millions)201420132012
Years Ended December 31,
Statutory net income (loss)(a)(b)(c):
Non-Life Insurance Companies:
Domestic$3,377$11,440$3,701
Foreign1,2008421,100
Total Non-Life Insurance Companies4,57712,2824,801
Life Insurance Companies:
Domestic2,6905,0473,827
Foreign(9)(9)(9)
Total Life Insurance Companies2,6815,0383,818
At December 31,
Statutory capital and surplus(a)(c):
Non-Life Insurance Companies:
Domestic$28,198$27,685
Foreign12,54012,022
Total Non-Life Insurance Companies40,73839,707
Life Insurance Companies:
Domestic8,64215,038
Foreign437129
Total Life Insurance Companies9,07915,167
Aggregate minimum required statutory capital and surplus:
Non-Life Insurance Companies:
Domestic$7,101$7,019
Foreign9,1479,078
Total Non-Life Insurance Companies16,24816,097
Life Insurance Companies:
Domestic3,8214,287
Foreign4645
Total Life Insurance Companies3,8674,332

(a) Excludes discontinued operations and other divested businesses. Statutory capital and surplus and net income (loss) with respect to foreign operations are as of November 30.

(b) Non-Life Insurance Companies did not recognize material statutory gains related to legal entity simplification (restructuring) in 2014. Non-Life Insurance Companies include approximately $8.0 billion of recognized statutory gains related to legal entity simplification (restructuring) in 2013. These recognized gains were largely offset by reductions in unrealized gains; therefore, there was no material impact to total surplus.

(c) In aggregate, the 2013 Non-Life Insurance Companies and Life Insurance Companies statutory net income (loss) and statutory capital and surplus amounts increased by $1.1 billion and $557 million, respectively, compared to the amounts previously reported in our Annual Report on Form 10-K for the year ended December 31, 2013, due to finalization of statutory filings.

Our insurance subsidiaries file financial statements prepared in accordance with statutory accounting practices prescribed or permitted by domestic and foreign insurance regulatory authorities. The principal differences between statutory financial statements and financial statements prepared in accordance with U.S. GAAP for domestic companies are that statutory financial statements do not reflect DAC, some bond portfolios may be carried at amortized cost, investment impairments are determined in accordance with statutory accounting practices, assets and liabilities are presented net of reinsurance, policyholder liabilities are generally valued using more conservative assumptions and certain assets are non-admitted.

For domestic insurance subsidiaries, aggregate minimum required statutory capital and surplus is based on the greater of the RBC level that would trigger regulatory action or minimum requirements per state insurance regulation. Capital and surplus requirements of our foreign subsidiaries differ from those prescribed in the U.S., and can vary significantly by jurisdiction. At both December 31, 2014 and 2013, all domestic and foreign insurance subsidiaries individually exceeded the minimum required statutory capital and surplus requirements and all domestic insurance subsidiaries individually exceeded RBC minimum required levels.

At December 31, 2014 and 2013, the use of prescribed or permitted statutory accounting practices by our domestic and foreign insurance subsidiaries did not result in reported statutory surplus or risk-based capital that is significantly different from the statutory surplus or risk-based capital that would have been reported had NAIC statutory accounting practices or the prescribed regulatory accounting practices of their respective foreign regulatory authority been followed in all respects for domestic and foreign insurance entities. As described in Note 13, our domestic insurance subsidiaries domiciled in New York and Pennsylvania discount non-tabular workers’ compensation reserves based on the prescribed or approved regulations in each of those states. While these practices differ from applicable NAIC statutory accounting practices, such practices do not have a material impact on our statutory surplus and statutory net income (loss) or risk based capital.

The NAIC Model Regulation “Valuation of Life Insurance Policies” (Regulation XXX) requires U.S. life insurers to establish additional statutory reserves for term life insurance policies with long-term premium guarantees and universal life policies with secondary guarantees (ULSGs). In addition, NAIC Actuarial Guideline 38 (Guideline AXXX) clarifies the application of Regulation XXX as to these guarantees, including certain ULSGs.

Domestic insurance subsidiaries manage the capital impact of statutory reserve requirements under Regulation XXX and Guideline AXXX through intercompany reinsurance transactions. The affiliated life insurers providing reinsurance capacity for such transactions are fully licensed insurance companies and are not formed under captive insurance laws. Under one of these intercompany reinsurance arrangements, certain Regulation XXX and Guideline AXXX reserves related to new and in-force business are ceded to an affiliated U.S. life insurer, which is a licensed life insurer in the state of Missouri and an accredited reinsurer in the state of Texas. As an accredited reinsurer, this affiliated life insurer is not required to post any collateral such as letters of credit or assets in trust.

Under the other intercompany reinsurance arrangement, certain Regulation XXX and Guideline AXXX reserves related to a closed block of in-force business are ceded to an affiliated off-shore life insurer, which is licensed as a class E insurer under Bermuda law. Bermuda law permits the off-shore life insurer to record an asset that effectively reduces the statutory reserves for the assumed reinsurance to the level that would be required under U.S. GAAP. Letters of credit are used to support the credit for reinsurance provided by the affiliated off-shore life insurer. The letters of credit are subject to reimbursement by AIG Parent in the event of a drawdown. See Note 8 for additional information regarding these letters of credit. 

Subsidiary Dividend Restrictions

Payments of dividends to us by our insurance subsidiaries are subject to certain restrictions imposed by regulatory authorities. With respect to our domestic insurance subsidiaries, the payment of any dividend requires formal notice to the insurance department in which the particular insurance subsidiary is domiciled. For example, unless permitted by the Superintendent of Financial Services, property casualty companies domiciled in New York generally may not pay dividends to shareholders that, in any 12-month period, exceed the lesser of 10 percent of such company’s statutory policyholders’ surplus or 100 percent of its “adjusted net investment income,” for the previous year, as defined. Generally, less severe restrictions applicable to both property casualty and life insurance companies exist in most of the other states in which our insurance subsidiaries are domiciled. Under the laws of many states, an insurer may pay a dividend without prior approval of the insurance regulator when the amount of the dividend is below certain regulatory thresholds. Other foreign jurisdictions may restrict the ability of our foreign insurance subsidiaries to pay dividends. Various other regulatory restrictions also limit cash loans and advances to us by our subsidiaries.

Largely as a result of these restrictions, approximately $45.8 billion of the statutory capital and surplus of our consolidated insurance subsidiaries were restricted from transfer to AIG Parent without prior approval of state insurance regulators at December 31, 2014.

To our knowledge, no AIG insurance company is currently on any regulatory or similar “watch list” with regard to solvency.

Parent Company Dividend Restrictions

Our ability to pay dividends has not been subject to any contractual restrictions since the cancellation of our Series G Preferred Stock in May 2011. See Note 17 herein for additional information about our ability to pay dividends to our shareholders.