The Bermuda balance sheet behind an American annuity

When investment firms buy insurers · Article 3/8 · The Bermuda connection

In 2020, Jackson reinsured the risks on a portfolio of American savings and retirement contracts with Athene Life Re. Jackson retained the investments, the Bermuda reinsurer received their economic return, and Apollo took on their management. The published treaty, its public amendment and recent financial statements trace that division of responsibilities through to the collateral and the terms on which Jackson can take the risks back.

The previous investigation into insurer acquisitions examines the rights acquired by Apollo, KKR, Brookfield and Blackstone. This third article follows one reinsurance treaty through to the assets and collateral.

On 18 June 2020, Prudential announced that Jackson National Life Insurance Company would reinsure a portfolio with Athene Life Re in Bermuda. The announcement described $27.6 billion of liabilities and $28.2 billion of assets, measured under IFRS at the end of the previous March. The geography of the transaction needs a little more explanation than those figures suggest: under the treaty, Jackson retained ownership of the investments backing the reinsured liabilities. ^{2, 1}

Customers still held their contracts with Jackson, an insurer domiciled in Michigan. Athene Life Re, or ALRe, undertook obligations to Jackson under a second contract. The treatment of benefits, investment returns and periodic settlements changed between the two companies, while the insurer owing money to the customer remained the same. Jackson’s financial statements at 30 June 2026 continue to describe this arrangement. ^{1, 7}

That distinction offers a way into understanding reinsurance in Bermuda. Assessing the protection behind an insurance contract requires following three things together: the obligation to pay, ownership of the securities and entitlement to their returns. In the Jackson–Athene transaction, those three lines separate, then meet again in the provisions governing collateral and exit.

Two contracts behind each benefit payment

The treaty was signed on 18 June 2020 and took economic effect on 1 June 2020. It covers an existing block of fixed annuities and fixed-index annuities: American savings and retirement products that provide a guaranteed interest rate or credit interest under a formula linked to an index. It also provides for contracts that will later be converted into an income stream, including the supplementary contract issued at that stage. The block therefore follows savings through to their payout phase. ^{1, 2, 3}

The reinsurance covers 100% of the liabilities within the treaty’s defined scope. Jackson continues to administer the policies and pay benefits, while ALRe owes Jackson the amounts specified in the agreement. Section 18.06 confines rights under the treaty to the parties and their permitted successors. Policyholders therefore retain their claim against Jackson; the reinsurance agreement itself gives them no direct contractual claim against ALRe. ^{1, 7}

The International Association of Insurance Supervisors, or IAIS, describes the general mechanism in the same terms: reinsurance transfers risk economically while leaving the insurer’s obligations to its customers in place. In exchange for the protection it buys, the original insurer becomes exposed to its reinsurer’s ability to perform. This is counterparty risk: a claim on another company brings the possibility of late payment, a dispute over the amount due or insufficient resources to pay. ²⁰

Method and scope

Contractual roles and initial June 2020 retrocession, from the Jackson–ALRe treaty and ACRA 1A’s 2020 accounts. Jackson remains liable to the policyholder. Arrows describe contractual relationships without a monetary scale.

The word coinsurance in this document refers to a form of proportional reinsurance. The treaty combines a funds-withheld component with a coinsurance component. The central mechanism is easier to see by looking at the funds withheld: the assets allocated to the portfolio remain Jackson’s property, while ALRe receives their economic performance under the agreed rules. ^{1, 7}

Keeping the securities, passing on the return

Section 6.02 provides for two separate custody accounts at The Bank of New York Mellon. Investments are deposited in those accounts or, for certain categories specified in the agreement, allocated to them. Jackson must retain ownership and control. Alongside those assets, it records a funds-withheld liability to the reinsurer, which changes with the return on the underlying investments. ^{1, 7}

A bond held under this arrangement can continue to pay its coupons into an account associated with Jackson. Yet the treaty allocates the benefit or cost of its performance to the reinsurer: income, gains, losses, defaults and impairments. The accounting makes this separation visible. Jackson keeps the investments on its balance sheet and recognises the corresponding effects in its liability to ALRe, using the methods explained in its reinsurance note. ^{1, 7, 8}

The cash needed to service the policies follows a related path. Jackson can withdraw cash from the account to pay benefits or reimburse itself for benefits already paid. The companies then reconcile the quarter’s movements and settle the balance required by the treaty. Adjustments reflect changes in reserves, payments and investment performance, among other items. A net amount can therefore pass between the companies while the bulk of the portfolio remains in the custody accounts. ¹

Method and scope

Funds-withheld mechanism in the 2020 treaty, notably sections 6.02 and 7. Income, losses and net settlements are allocated under the agreement while Jackson retains ownership of the securities.

Protection also depends on how the assets are set aside. In its June 2026 financial statements, Jackson says that investments in the segregated account are available exclusively for policies covered by the agreement and cannot be used to settle its other obligations to policyholders or general creditors. This describes an important protection for the reinsured block. Establishing how it would work in an insolvency also requires examining the security documents and applicable law. ⁷

Legal ownership gives Jackson a practical advantage: much of the financial backing is already under its control. The quality of the securities, their value when needed and their ability to generate cash then determine how much economic protection that ownership provides.

Apollo invests within an agreed mandate

The contract names Apollo Insurance Solutions Group LP as the account’s initial investment manager. Jackson appoints it, but the agreement with ALRe constrains Jackson’s freedom to change the mandate or investment limits. Section 6.02 requires the reinsurer’s prior consent in specified circumstances and sets out a particular replacement procedure, including when a material breach of law threatens Jackson or the account, or in cases of fraud, gross negligence or wilful misconduct in performing the mandate. ¹

Here the distinction between owning the securities and managing them becomes especially useful. Jackson owns the assets, Apollo holds the investment mandate, and ALRe bears the agreed economic result. Under the treaty, the reinsurer bears the investment manager’s and custodian’s fees. ALRe consequently has a direct interest in the return earned after those charges and in how well it matches the benefits to be financed. ¹

At 30 June 2026, Jackson reported that Apollo managed $10.5 billion of cash and investments under this relationship. The same report disclosed $11.9 billion of contract liabilities reinsured with Athene. These figures use different definitions and valuation methods. Assessing the backing for the liabilities requires reconciling all the treaty’s components and their accounting treatment, including the financial hedges. ⁷

Those hedges serve a specific purpose. Where a contract credits interest by reference to an index, movements in that index can change the amounts owed. Section 6.01 makes the reinsurer responsible for hedging this risk and provides, subject to specified conditions, for rights over derivatives and their collateral to be assigned for Jackson’s benefit. Protection therefore includes instruments whose maturity dates and exercise terms matter alongside their reported value. ¹

Jackson also received compensation at inception. Its 2025 statutory accounts record a $1,196.3 million ceding commission associated with the 2020 agreement. That payment forms part of the transaction’s initial economics; Apollo’s management charges follow a separate agreement. The detailed investment management agreement appears among the exhibits identified but omitted from the public filing reviewed here, preventing a reconstruction of its precise fee schedule. ^{8, 1}

The audited accounts of Athene Co-Invest Reinsurance Affiliate 1A Ltd, or ACRA 1A, reveal another stage in the transaction. They state that, effective 1 June 2020, ACRA 1A entered into a ModCo agreement with ALRe covering 100% of the risks ALRe had assumed on the Jackson block. Reinsurance purchased by a reinsurer is called retrocession. It adds another claim to ALRe’s side of the chain, while ALRe’s commitment to Jackson remains governed by the original treaty. ^{25, 1}

This second transaction shows how a co-investment platform can work: partners’ capital supports the risk behind the reinsurer that signed the original agreement. The Jackson treaty permits retrocessions to affiliates without applying the volume restriction imposed on transactions with outside parties. ACRA’s accounts document this stage in 2020. The detailed retrocession treaty was not among the documents obtained, limiting what can be established about its own collateral and exit terms. ^{1, 25}

Each form of collateral has its own conditions

The funds-withheld account provides the first layer of protection. ALRe also supplies additional assets or commitments for Jackson’s benefit. At 30 June 2026, Jackson reported $1.1 billion in letters of credit and a trust with a carrying value of approximately $57 million supporting obligations under the treaty. ⁷

A trust sets assets aside for a specified purpose under the responsibility of a trustee. A letter of credit commits a bank to pay when a demand meets the agreed conditions. The trust thus relies on assets already placed in a collateral arrangement; the letter of credit adds a bank’s payment commitment. To establish how either can be used, the relevant withdrawal rights, required documents and deadlines must be checked. ^{1, 17}

The treaty also establishes an order for using the collateral. Section 9.05 permits a draw on a letter of credit when non-payment continues for ten calendar days after notice and the resources of the overcollateralisation account, measured under the contract’s rules, have been exhausted. That sequence explains why a reported collateral amount and immediately available cash answer different questions. ¹

Method and scope

Jackson at 30 June 2026: $1.1bn of letters of credit, a conditional bank commitment, and a trust with approximately $57m of book value. These protections remain separate from the funds-withheld portfolio. The treaty defines drawing and withdrawal conditions.

The treaty details permitted uses of withdrawals, rules for substituting assets and adjustments to an overcollateralisation account called the OC Account. It defines a required balance through a formula that takes several parts of the arrangement into account. A first amendment, signed on 30 September 2020, added a component for excess derivative collateral to that formula and replaced the relevant investment guidelines. ^{1, 5}

These adjustments help explain why simply adding the published amounts would give an incomplete picture. Letters of credit represent a payment commitment that may be drawn upon, the trust is reported at carrying value, and the managed portfolio contains assets with different characteristics. A meaningful reconciliation requires the values specified by the contract, the resources actually available and the obligations they cover, all measured at the same date.

The Bermuda Monetary Authority, or BMA, itself emphasises asset quality, concentration limits and the ceding insurer’s ability to manage a portfolio after recapture. Illiquid securities or structures that are difficult to value can complicate the use of collateral even where the legal right to access it is established. That makes the investment guidelines a central document in the investigation. ¹⁷

The treaty allows several stages of intervention

Jackson has rights designed to strengthen its protection before a possible full recapture. The treaty tracks two measures of the reinsurer’s capital: an ECR ratio, comparing available statutory economic capital with the relevant Bermuda requirement, and an RBC ratio, calculated for ALRe using Athene’s published methodology referenced in the agreement, on the US company action level basis. Each has its own definition, and their percentages belong on different scales. ¹

Under the published terms, an ECR ratio below 135% or an RBC ratio below 250%, recorded at the end of a monitoring period and persisting at the end of the following quarter, triggers stronger protections. If the statutory book value of permitted assets in the OC Account is then below the balance required by the contract, ALRe must make up that shortfall within five business days of the trigger. The amount due therefore depends on the shortfall at that point. ¹

A further threshold gives Jackson the option of recapture, taking back the economic risks it previously reinsured: an ECR ratio below 120% or an RBC ratio below 200%, subject to the same persistence condition. The reinsurer’s insolvency, certain failures to pay and other events defined in the treaty can also establish this right. These thresholds come from the published contract, which includes a provision for adapting them if the calculation frameworks change. ¹

Method and scope

Thresholds in the public treaty signed in 2020: ECR and RBC have different definitions and denominators. A breach must persist at the end of the following quarter. The OC top-up depends on the shortfall; recapture is a contractual option. The treaty provides for ratio adaptation if calculation frameworks change.

Jackson can then decide whether to exercise its right. If it proceeds under section 13.03, recapture covers the whole block, with closing scheduled between five and thirty business days after notice. The treaty then governs the closing accounts and settlement between the companies. The right to take the risks back and the work required to complete that settlement are distinct stages. ¹

At settlement, the treaty compares the statutory book value of the retained assets with an exit amount derived from reserves and specified adjustments, including the unamortised ceding commission. ALRe must make up a shortfall with cash or permitted investments valued at fair value; any surplus must be returned to it. The funds-withheld account then ends, supplementary collateral is released under the settlement provisions, and the accounts remain subject to a further adjustment. ¹

From the policyholder’s perspective, Jackson already owed the benefits. Recapture chiefly increases the economic risks Jackson must carry directly and the resources it must devote to managing them. It can retain the assets already in its possession while having to reconsider the hedges, investments, capital and liquidity needed to support the policies. The quality of that preparation determines the practical value of the exit provision. ^{1, 20, 14}

Bermuda brings together several forms of reinsurance

The Jackson structure belongs to a well-documented family of arrangements. In its report published in September 2025, the BMA examined 657 treaty records submitted by 86 entities, generally using year-end 2024 balance sheets, with a few different reporting dates. Some records combine several small treaties. Funds-withheld and modified coinsurance, or ModCo, arrangements together accounted for $429.8 billion of reserves out of a published total of $601.3 billion, approximately 71.5% by our calculation. ²¹

Both structures leave the assets with the ceding insurer; under the mechanism described by the BMA, ModCo also leaves the reserves there. Their combined share of reserves is much greater than their 33.3% share of the treaty records. Pure coinsurance shows the reverse pattern: about 49.6% of records but 9.2% of reserves. The report explains this partly by the inclusion of traditional mortality and longevity covers, which require fewer backing assets. ^{21, 17}

Method and scope

BMA collection based on year-end 2024 reference balance sheets, with some different reporting dates: 657 records submitted by 86 entities, including some aggregations of small treaties. Funds withheld and ModCo: (154 + 65) / 657 = 33.3% of records; (250.6 + 179.2) / 601.3 = 71.5% of reserves. Pure coinsurance: 326 / 657 = 49.6%; 55.6 / 601.3 = 9.2%. Reserves are in billions of US dollars. Rounded rows total $601.4bn against the published $601.3bn total; calculated shares are rounded to one decimal.

These figures direct attention towards rights over assets and the conventions used to value them. They measure reinsurance reserves within a defined data collection; they do not locate every security held across the companies concerned. The method below the figure sets out the numerators, denominators and rounding difference in the original table so that the percentages can be reproduced. ²¹

The public treaty between American General Life and Fortitude Re provides a useful comparison. Its 2020 version also leaves assets with the ceding insurer, in this case in a ModCo account. Several financial thresholds are redacted. The broad structure can be compared, while the precise recapture conditions must be established separately for each agreement. ²⁶

Assessing the protection also means finding the missing documents

The strongest argument for these arrangements lies in their financing capacity. A specialist company can provide capital, organise the management of long-term investments and share risk with other investors. In the June 2020 Jackson announcement, Athene described financing through ACRA, its co-investment platform. The capital to be deployed was announced as 63% funded by third-party investors and 37% by Athene. This was the stated funding split for the transaction and its various components. ^{3, 4}

The authors of a Bank for International Settlements paper describe several possible motives for funded reinsurance: pooling management resources, accessing capital, drawing on investment expertise, or benefiting from differences in tax and prudential regimes across jurisdictions. These motives can coexist. Determining their relative contribution to the eventual return on the Jackson treaty would require a breakdown that the public documents assembled here do not provide. ³⁰

Supervisors now scrutinise these relationships closely. An April 2025 BMA notice describes prior approval for block transactions by the commercial long-term reinsurers concerned, a process in place since January 2023. The review covers contracts, collateral, investment mandates and a reconciliation of asset requirements across jurisdictions. This procedure covers new block transactions and amendments to existing blocks; its timetable must be distinguished from the signing of the Jackson deal in 2020. ¹⁹

In the United Kingdom, the PRA expects insurers to have an executable recapture plan setting out legal steps, asset movements and the ability to manage the recovered portfolio. Its consultation of 29 April 2026 also proposes revising the treatment of the claim on the reinsurer. The consultation closed on 31 July 2026; as of this investigation’s cut-off date, I found no final decision in the official sources consulted. This British work helps explain the risk under examination while remaining separate from the framework governing the American contract. ^{14, 12}

For Jackson–Athene, the available documents establish the division of responsibilities, the existence of the reported collateral and the main recapture conditions in the published text. The complete investment guidelines, trust agreement, investment management agreement and detailed collateral statements at a common date would allow the investigation to go further. Several exhibits were expressly omitted from the public filing, and the September 2020 amendment shows that some have changed. ^{1, 5, 9}

Following the savings therefore means following a chain of rights. Jackson remains responsible to the policyholder, ALRe commits to Jackson, Apollo manages investments, and collateral supports that second promise. Assessing the strength of the arrangement requires reading the place of incorporation alongside the contract, the composition of the assets and the practical ability to use them when payment falls due.

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Documentary investigation closed on 23 October 2026. The text and source notes distinguish published treaty provisions, accounting disclosures and scenarios. BMA percentages are calculated from published rounded values, with scope and denominators set out below the figure. Missing schedules and documentary limitations are identified. This investigation is based on the cited documents.

Further reading: the first investigation into AT&T pensions, Bermuda and the cost of recapture, and the guide to reading a life insurer’s financial strength.

Sources

The notes give each document’s date, scope and limitations. Company communications are attributed to the interested parties.

1. S01 · Jackson Financial Inc. / SEC EDGAR · 2021-03-22 · Accessed: 2026-10-23Coinsurance Agreement between Jackson National Life Insurance Company and Athene Life Re Ltd.
   Passages and scope

   Agreement signed 18 June 2020; effective 1 June 2020; this copy filed 22 March 2021.

   Sections 1.01, 2.01, 2.04, 2.06, 5.04 and 6.01–6.02; Articles IX–X; Sections 13.03–13.07; Article XIV; Section 18.06.

   Sets out Jackson and ALRe responsibilities, combined funds-withheld coinsurance and coinsurance, asset ownership, Apollo’s initial mandate, collateral and recapture terms.

   Schedules and exhibits are not reproduced. Section 6.02(d) contains an apparent cash-shortfall inconsistency, which is not silently corrected. Thresholds are contractual and may be adjusted under Section 10.05(c).

   Official copy consulted

2. S02 · Prudential plc · 2020-06-18 · Accessed: 2026-10-23Prudential plc announces $27.6 billion US reinsurance agreement alongside $500 million equity investment by Athene into its US business
   Passages and scope

   Announcement 18 June 2020; IFRS amounts as of 31 March 2020.

   Transaction details; Reinsurance of $27.6 billion; footnotes 1–2.

   Announces $27.6bn reinsured liabilities and $28.2bn reference assets, alongside a separate $500m equity investment. Describes portfolio exclusions.

   Company statement and initial estimates. IFRS amounts are not directly comparable with later US GAAP liabilities and do not establish a physical movement of securities to Bermuda.

3. S03 · Athene Holding Ltd. · 2020-06-18 · Accessed: 2026-10-23Athene Announces Fixed Annuity Reinsurance Transaction with Jackson National Life Insurance Company
   Passages and scope

   Transaction announced 18 June 2020; planned capital deployment over 12–18 months.

   Paragraphs on ACRA, total capital deployment and continued contract servicing; footnote 1.

   Distinguishes approximately $26.7bn statutory reserves from $27.6bn IFRS liabilities. Announces capital funding split 63% external investors and 37% Athene.

   The split concerns announced capital for several transaction components, including the equity investment. It does not allocate direct payment obligations to policyholders.

4. S04 · Athene Holding Ltd. · 2020-06-18 · Accessed: 2026-10-23Athene Enters Into Fixed Annuity Reinsurance Agreement with Jackson National
   Passages and scope

   Transaction presentation 18 June 2020.

   PDF pages 3, 5, 6 and 9; footnotes on reserves, ACRA and ceding commission.

   Describes reserve cession to ACRA and the announced economic participation; presents an initial estimated $1.25bn ceding commission.

   Company presentation, not a retrocession contract. Use the subsequently disclosed $1,196.3m commission in S08. Text extraction incompletely represents some graphic elements.

5. S05 · Jackson Financial Inc. / SEC EDGAR · 2021-03-22 · Accessed: 2026-10-23Amendment No. 1 to Coinsurance Agreement
   Passages and scope

   Amendment No. 1 signed 30 September 2020; Jackson copy filed 22 March 2021.

   Sections 1.01–1.04 and 2.03.

   Adds excess margin collateral to the required-trust formula and replaces investment guidelines C-1/C-2 and the required-balance statement form.

   Replacement schedules and exhibits are not reproduced. S09 is another copy of the same amendment, not a second amendment.

6. S06 · Jackson Financial Inc. / SEC EDGAR · 2026-02-24 · Accessed: 2026-10-23Jackson Financial Inc. : Form 10-K for the year ended 31 December 2025
   Passages and scope

   Year ended 31 December 2025; filed 24 February 2026.

   MD&A Investments (PDF p.74), Policy and Contract Liabilities (PDF p.81); Note 8 Reinsurance; Exhibit index 10.3 and 10.3a (PDF p.213).

   Reports $13.0bn liabilities reinsured by Athene and $11.6bn cash and investments managed by Apollo. Exhibit index references the treaty and Amendment No. 1.

   Reinsured liabilities and managed assets have distinct perimeters. The funds-withheld table combines Athene and Swiss Re; these aggregates do not establish an Athene coverage ratio.

   Official copy consulted

7. S07 · Jackson Financial Inc. / SEC EDGAR · 2026-08-03 · Accessed: 2026-10-23Jackson Financial Inc. : Form 10-Q for the six months ended 30 June 2026
   Passages and scope

   Six months ended 30 June 2026; filed 3 August 2026.

   Note 8 Reinsurance, p.56 (PDF p.60); MD&A Investments, p.113 (PDF p.117); Policy and Contract Liabilities, p.121 (PDF p.125).

   Confirms Jackson’s ownership and possession of investments. Reports $10.5bn managed by Apollo, $11.9bn Athene-reinsured liabilities, $1.1bn letters of credit and approximately $57m trust book value. The latest complete 10-Q found as of 23 October 2026 covers June 2026; Jackson’s 6 October announcement schedules third-quarter results for 3 November after the US market closes.

   Amounts differ in nature and scope. The trust supplements funds withheld; letters of credit are not cash already held. Consolidated tables include Swiss Re.

   Official copy consulted

   Q3 schedule announced on 6 October 2026

8. S08 · Jackson National Life Insurance Company / SEC EDGAR · 2026-04-15 · Accessed: 2026-10-23Jackson National Life Insurance Company : 2025 statutory audited financial statements
   Passages and scope

   Statutory accounts at 31 December 2025; KPMG opinion 20 March 2026; filed 15 April 2026.

   Note 7 Reinsurance, p. 52; Note 3 Investments, p. 34; audit opinion.

   Discloses an initial $1,196.3m ceding commission, $109.7m trust book value at year-end 2025 and $9,258.6m debt securities under the Athene treaty at statutory carrying value.

   Statutory measures differ from US GAAP amounts. Debt securities are not all account assets. The initial ceding commission is distinct from management fees.

9. S09 · Athene Holding Ltd. / SEC EDGAR · 2020-11-03 · Accessed: 2026-10-23Amendment No. 1 to Coinsurance Agreement : Athene filing with omission notices
   Passages and scope

   Amendment No. 1 signed 30 September 2020; Athene copy filed 3 November 2020.

   Sections 1.03–1.04; final omission notices: Schedule 5.02(b)(ii), Exhibit C-1 and Exhibit C-2.

   States that the Required Balance Statement form and pre-/post-trigger investment guidelines are omitted under Regulation S-K Item 601(a)(5).

   The notice identifies exactly those three attachments. It does not identify investment-management Exhibit E. Public omission does not establish misconduct in investment management.

   Official copy consulted

10. S10 · Athene Holding Ltd. / SEC EDGAR · 2026-02-25 · Accessed: 2026-10-23Athene Holding Ltd. : Form 10-K for the year ended 31 December 2025
    Passages and scope

    Year ended 31 December 2025; filed 25 February 2026; tax event described for January 2026.

    ACRA description; Common Stock; Note 13 Income Taxes; MD&A Bermuda Corporate Income Tax.

    Describes ACRA 1 economic interests of 37% for ALRe and 63% for ADIP I, alongside voting rights. Tax disclosures identify withdrawal of ACRA’s election into Bermuda CIT.

    ACRA program totals and fees are not specific to Jackson. The consolidated 953(d) tax line does not prove an ALRe election; withdrawal of ACRA’s election does not mean repeal of the law.

    Official copy consulted

11. S11 · Athene Holding Ltd. / SEC EDGAR · 2023-08-07 · Accessed: 2026-10-23ACRA 2 Master Framework Agreement
    Passages and scope

    Framework agreement effective 1 July 2023; filed 7 August 2023.

    Recitals defining ALRe, AARe and ACRA 2 vehicles.

    Recitals identify Athene Annuity Re Ltd. (AARe), distinct from ALRe, as having elected US tax treatment under Section 953(d).

    Concerns ACRA 2, a different vehicle generation from the Jackson case. Establishes AARe’s stated status in 2023, not every subsequent ALRe tax election.

    Official copy consulted

12. S12 · Prudential Regulation Authority / Bank of England · 2026-04-29 · Accessed: 2026-10-23CP8/26 – Funded reinsurance
    Passages and scope

    Consultation closed 31 July 2026; proposed calculation implementation on 1 July 2027; proposed savings-provision cutoff on 30 September 2026

    Paragraphs 1.5, 1.15–1.16, 3.5–3.6, 3.10 and 3.30–3.35

    Proposes a reinsurance-recoverable valuation adjustment to reflect default and downgrade risk; gives estimated capital comparisons.

    Regulatory proposal. Searches of official publications and the current SS5/24 page consulted on 23 October 2026 did not identify a final decision; this finding is limited to the sources inspected. The estimates do not describe the Jackson treaty.

13. S13 · Prudential Regulation Authority / Bank of England · 2024-07-26 · Accessed: 2026-10-23SS5/24 – Funded reinsurance: current and past versions
    Passages and scope

    Page accessed on 23 October 2026; current version published on 23 October 2025 and effective from 27 October 2025.

    Current version; Past versions

    Identifies the current SS5/24 version and update chronology.

    The current-version page is evidence of status; an unsuccessful search does not prove that a decision does not exist.

14. S14 · Prudential Regulation Authority / Bank of England · 2025-10-23 · Accessed: 2026-10-23SS5/24 – Funded reinsurance, October 2025
    Passages and scope

    Effective from 27 October 2025; designated current when checked on 23 October 2026

    Paragraphs 2.6–2.7A and 2.15–2.23; printed pages 5 and 7–9

    Collateral policy, worst permitted collateral portfolio, recapture plan, matching-adjustment permissions and board decisions.

    UK supervisory expectations; they are not the terms of the US Jackson treaty.

15. S15 · Prudential Regulation Authority / Bank of England · 2025-11-17 · Accessed: 2026-10-23Life Insurance Stress Test: 2025 Results
    Passages and scope

    Balance sheets at 31 December 2024; exploratory recapture scenario after market stress

    Annex 2: Exploratory scenario findings – FundedRe recapture

    £12.3bn of liabilities recaptured in the scenario; SCR ratio from 154% to 144% for participating recapturers; exposures absorbable at year-end 2024.

    Scenario with no assigned probability; subset of firms, unnamed counterparties, no currency shock and mostly matching-adjustment-eligible collateral.

16. S16 · Prudential Regulation Authority / Bank of England · 2025-01-16 · Accessed: 2026-10-23LIST 2025: Scenario Specification, Guidelines and Instructions
    Passages and scope

    Stress-test methodology applied to balance sheets at 31 December 2024

    Section C, printed pages 21–23; summary pages 5–6

    Defines the exploratory recapture of the most financially material counterparty after the core scenario.

    Assumptions prescribed for an exercise; not forecasts or official probability calibrations.

17. S17 · Bermuda Monetary Authority · 2024-09-06 · Accessed: 2026-10-23Collateral Structures in the Bermuda Long-term Insurance Market
    Passages and scope

    Structure data for 2020–2023, especially year-end 2023; practices and supervision described in September 2024

    Tables 1–2, pp. 2–3; mechanism and safeguards, pp. 4–6; limitations, pp. 11–14

    FWH/ModCo retain assets with the cedant while economic risk passes to the reinsurer. The BMA explains collateral benefits and conditions for effectiveness.

    Report by the jurisdiction’s supervisor. Observed practices, not universal terms. Asset-based table; some rounded shares sum to 101%.

18. S18 · Bermuda Monetary Authority · 2025-03-21 · Accessed: 2026-10-23Insights and Reflections on Asset Intensive Reinsurance in Bermuda
    Passages and scope

    Regulator’s position and analysis published March 2025; some statistics concern year-end 2023

    Executive summary pp. 3–4; prudential framework pp. 7–9; ICP13 pp. 11–13

    Capital-capacity argument and description of supervisory controls and cooperation.

    The defence of Bermuda’s market must be attributed to the BMA; it does not establish the safety of a particular treaty.

19. S19 · Bermuda Monetary Authority · 2025-04-02 · Accessed: 2026-10-23Notice: Prior Approval of New Long-Term Block Reinsurance Transactions
    Passages and scope

    Process applied since January 2023; April 2025 notice clarifying scope and reconciliations

    Pages 1–3; appendix pp. 4–7, especially items 7, 10–14 and 18

    Prior approval of new blocks and modifications; review of treaties, collateral, mandates, fees, capital and reconciliation of total asset requirements.

    Does not establish that the process introduced in 2023 applied to Jackson’s 2020 treaty. The individual approval file is not supplied.

20. S20 · International Association of Insurance Supervisors · Accessed: 2026-10-23Insurance Core Principles and ComFrame : ICP13
    Passages and scope

    Online version accessed 23 October 2026; page update date not identified

    ICP13.0.4 and 13.5.2–13.5.5

    Distinguishes economic risk transfer from novation; insurer retains obligations to policyholders and faces potential liquidity risk.

    International standards and guidance, distinct from applicable law and treaty terms.

21. S21 · Bermuda Monetary Authority · 2025-09-15 · Accessed: 2026-10-232025 Global Financial Crisis Stress Test – Long-Term Reinsurers
    Passages and scope

    Balance sheets at 31 December 2024, with a few different year ends; 106 stress participants and 86 providing treaty data

    Table 5.2 p. 25; collection p. 23; reference date p. 8; results pp. 3–8

    Reserve structure across 657 treaty records. Published whole-number shares: FWH 42%, ModCo 30%, other collateral 10%, pure coinsurance 9%, trust 9%. The article recalculates grouped shares to one decimal from published amounts.

    Reserves, not assets; some small treaties aggregated. Published total of $601.3bn versus a $601.4bn sum of rounded rows. Scope differs from the BMA year-end 2023 asset table. Capital stress does not directly assess liquidity and operations.

22. S22 · Prudential Regulation Authority / Bank of England · 2026-04-29 · Accessed: 2026-10-23PRA publishes plans to support resilience in the life insurance industry
    Passages and scope

    Announcement of consultation CP8/26 on 29 April 2026

    News release and links to CP8/26

    Accessible account of proposed changes to funded-reinsurance treatment.

    Announcement of proposals, not a final decision; use CP8/26 for exact provisions and dates.

23. S23 · Athene Co-Invest Reinsurance Affiliate 1A Ltd.; dépôt BMA · 2025-07-02 · Accessed: 2026-10-23Athene Co-Invest Reinsurance Affiliate 1A Ltd. : Consolidated Financial Statements 2024
    Passages and scope

    Financial statements as of 31 December 2024 and 2023, audit report dated 25 April 2025; BMA upload 2 July 2025

    Notes 1, 5 and 12; pp. 11, 35 and 45

    Describes ACRA formation, economic interests and the 2021 reorganisation; confirms modco arrangements between ALRe and ACRA 1A.

    Jackson is not named in this edition. Contemporary evidence of the Jackson block retrocession is in S25.

24. S24 · Athene Life Re Ltd.; dépôt BMA · 2022-07-01 · Accessed: 2026-10-23Athene Life Re Ltd. : Consolidated Financial Statements 2021
    Passages and scope

    Financial statements as of 31 December 2021 and 2020, audit report dated 27 April 2022; BMA upload 1 July 2022

    Notes 6 and 13; pp. 51–52 and 58–61

    ALRe consolidated context, ACRA economic ownership and reinsurance transaction disclosures.

    Consolidated accounts; do not alone isolate the Jackson retrocession. Use S25 for that evidence.

25. S25 · Athene Co-Invest Reinsurance Affiliate 1A Ltd.; dépôt Companies House FC035962 · 2021-07-28 · Accessed: 2026-10-23Athene Co-Invest Reinsurance Affiliate 1A Ltd. : Consolidated Financial Statements 2020 and 2019
    Passages and scope

    Financial years 2020 and 2019; audit report dated 20 April 2021; Companies House filing 28 July 2021

    Note 1 p. 11; note 5 p. 33; note 8 p. 34; note 12 p. 40 (PDF pages 14, 36, 37 and 43)

    Explicit evidence of a modco retrocession, effective 1 June 2020, to ACRA 1A of 100% of the Jackson risks assumed by ALRe. The accounts also report ALRe holding 36.55% of economic interests and 100% of voting rights, versus ADIP holding 63.45% of non-voting economic interests.

    Scanned accounts, with key pages visually checked on 23 October 2026. The accounts also call the Jackson–ALRe treaty modco, whereas the primary treaty defines a combined funds withheld coinsurance and coinsurance basis; retain the primary treaty’s terminology for that first leg. The detailed ALRe–ACRA treaty was not obtained. The transaction table on p. 33 and total restricted assets on p. 40 cover several blocks, not Jackson alone.

26. S26 · American International Group, Inc. / SEC EDGAR · 2020-08-04 · Accessed: 2026-10-23Amended and Restated Combination Coinsurance and Modified Coinsurance Agreement : American General Life Insurance Company / Fortitude Reinsurance Company, Ltd.
    Passages and scope

    Amended agreement executed 2 June 2020, effective 1 June 2020; original agreement signed 12 February 2018, effective 1 January 2017

    Exhibit 10.1; §§ 4.1, 4.3–4.4, 5.1, 9.1–9.5 and 10.5; especially contract pages 32–40 and article IX

    Documents another retained-asset arrangement: AGL keeps legal title and control of ModCo account assets while Fortitude bears their economic investment risk. The agreement sets out the trust, withdrawal rights, top-up obligations and recapture remedies.

    Comparative contract, separate from Jackson–Athene. Several thresholds and schedules are redacted. Article V coinsurance provisions must not be applied to the ModCo account. The manager named in 2020 does not establish the current manager’s identity.

27. S27 · HM Revenue & Customs · 2019-08-05 · Accessed: 2026-10-23LAM10050 : Reinsurance: Accounting for reinsurance arrangements: ‘deposit back’ and ‘funds withheld’
    Passages and scope

    Online manual accessed 23 October 2026; manual-level update displayed as 21 November 2023

    Life Assurance Manual, LAM10050; definitions of both structures and final paragraph on net settlements

    Explains how funds withheld leave the premium and assets with the cedant and how premiums, claims and investment returns can be periodically net-settled. Describes the insurer–reinsurer contractual relationship and the reinsurer’s counterparty risk.

    UK tax manual used to explain the general mechanism; not a legal opinion on the US treaty. The displayed update date is for the manual and does not establish that this section changed on that date.

28. S28 · Corebridge Financial, Inc. / SEC EDGAR · 2026-08-05 · Accessed: 2026-10-23Corebridge Financial, Inc. : Form 10-Q, 30 June 2026, Note 7: Reinsurance
    Passages and scope

    Financial statements at 30 June 2026; VALIC ModCo recapture effective 1 January 2025

    Note 7, Fortitude Re subsection; paragraphs on AGL/USL agreements, VALIC recapture and ModCo accounting; asset-composition table

    Confirms AGL and USL ModCo agreements with Fortitude and the cedant’s continued ownership and balance-sheet recognition of supporting assets. Reports VALIC recapture effective 1 January 2025 and a $45m pre-tax charge. Assets supporting the Fortitude arrangements are presented by carrying and fair value.

    Tables aggregate several agreements rather than only the 2020 AGL contract. The passage does not disclose the reason for VALIC’s recapture and therefore does not establish a Fortitude default. Interim note from a 10-Q filing, distinct from audited annual statements.

29. S29 · Corebridge Financial, Inc. / SEC EDGAR · 2026-02-11 · Accessed: 2026-10-23Corebridge Financial, Inc. : Form 10-K 2025, Note 7: Reinsurance
    Passages and scope

    Year ended 31 December 2025; comparison at 31 December 2024; VALIC recapture effective 1 January 2025

    Note 7, Fortitude Re and Reinsurance Security subsections; asset-composition table

    Describes ownership of retained ModCo assets, treatment of investment returns and the reinsurance asset. Reports approximately $24.1bn of liabilities ceded to Fortitude at year-end 2025. Confirms VALIC’s recapture and explains that reinsurance leaves Corebridge’s direct obligations to beneficiaries in place.

    Consolidated Corebridge scope and several treaties; amounts must not be attributed solely to the 2020 AGL agreement. Carrying values, fair values and ceded liabilities use different measures. The reason for VALIC’s recapture is not disclosed in this passage.

30. S30 · Fabian Garavito, Ulf Lewrick, Tomas Stastny et Karamfil Todorov : BIS Quarterly Review · 2024-09-16 · Accessed: 2026-10-23Shifting landscapes: life insurance and financial stability
    Passages and scope

    Analysis published in September 2024

    Sections Asset-intensive reinsurance – risk-sharing and other incentives; Financial stability considerations.

    Describes funded-reinsurance motivations: centralised management, capital access, investment expertise and tax or prudential differences; discusses counterparty and liquidity risks.

    Authors’ analysis. General mechanisms do not quantify the Jackson treaty’s return or the contribution of each incentive to it.

31. S31 · Government of Bermuda · 2023-11-15 · Accessed: 2026-10-23Bermuda Corporate Income Tax
    Passages and scope

    Tax introduced with effect from 1 January 2025; page updated 12 October 2026

    Main overview and last-updated date.

    Confirms introduction of Corporate Income Tax from 2025. Context for avoiding projection of a 2020 tax description onto 2026.

    Does not establish ALRe’s effective tax rate or the Jackson treaty’s tax treatment. Legal domicile, tax residence and tax elections are distinct.