The majority of states have now adopted the ORSA Model Law and the first filings are officially due by the end of 2015.  The NAIC has been conducting an ORSA pilot project for the last 3 years and many companies participated.  The participating companies received valuable input regarding their ORSA  Summary Report which will help them prepare their first official filing this year.  However, many companies did not participate in the pilot project so the submission of the Summary Report to regulators this year will be the first review by a regulator.  As a result of the NAIC pilot project a summary document was prepared providing the industry valuable feedback as to the observations of regulators during the pilot project.  Prior to submitting your ORSA Summary Report to regulators this may be a good time to review the NAIC Summary Document to make sure issues noted by Regulator’s during the pilot have been addressed in your ORSA Report.