AT&T pensions: Athene, Apollo and the annuity contract

When investment firms buy insurers · 1/8 · The contract changes hands

In 2023, roughly 96,000 participants and beneficiaries in AT&T’s pension plan came under annuity contracts issued by Athene, part of Apollo. The transaction preserved their promised benefit amounts. Behind the payments, however, the debtor changed, along with the assets supporting the promise and the system protecting it. U.S. filings and a British precedent reveal how those changes work and where the public record ends.

Starting with the August 2023 payment, two Athene insurance companies took responsibility for the benefits AT&T had transferred. The filing with the U.S. Securities and Exchange Commission names them: Athene Annuity and Life Company and Athene Annuity & Life Assurance Company of New York. Their commitments to pay the covered benefits are irrevocable. Approximately 96,000 plan participants and beneficiaries were included in the transaction. ¹

For someone receiving a pension, the amount and the reliability of the payment understandably come first. The right to receive it also rests on a legal entity, a contract and financial resources. All three can change while the recipient continues to collect the expected sum. Following asset managers into the insurance business therefore begins with a tangible claim: which company can be required to pay, and what resources stand behind its obligation?

AT&T’s transaction provides a first answer that can be checked against the documents. Prudential’s dealings with Rothesay in the United Kingdom then reveal a further complication: economic risk, legal responsibility and payment administration can move separately.

Three dates in the transfer of a pension obligation

On April 26, 2023, AT&T and State Street Global Advisors Trust Company, acting as the plan’s independent fiduciary, entered into an agreement with Athene’s subsidiaries. The purchase of the group annuity contracts closed on May 3. The agreement assigned the August payments onward to the insurers. ¹

The benefits came from a defined-benefit pension plan, which owes payments calculated under the plan’s rules. Its investments are held in a trust to fund those entitlements. For the people covered by the transaction, single-premium group annuity contracts took over: assets were provided upfront in exchange for the insurers’ commitment to make the scheduled payments, including those due for life. ¹ ¹⁰

This is a pension risk transfer. The plan settles the benefits included in the transaction, and the insurer becomes responsible for the corresponding payments. U.S. Department of Labor guidance on selecting an insurer explicitly describes that substitution. AT&T’s transfer was partial; the plan retained other pension obligations. ² ¹⁰

The recipient holds a right to benefits against the insurer. Ownership of the investments belongs to a separate legal relationship. The relevant contract or certificate identifies the issuing insurance company against which that right can be enforced. AT&T’s filing names two companies for the transaction as a whole without publishing the allocation of individual beneficiaries between them. Establishing any joint and several liability requires the contracts and guarantees applicable to each beneficiary. ¹ ³

FIG. 01 Two annuity issuers and a separate ownership chain.[S01][S03][S04][S27]

Method and scope

The transfer makes the issuing insurers responsible for the covered benefits. Ownership leads separately back to Apollo; each beneficiary’s contract or certificate identifies the relevant issuer. Intermediate ownership links are omitted.

Acquisition announcements often blur the different roles within a group. The shareholder directs strategy and receives the returns on its investment. The insurer carries the contractual obligation. The asset manager selects investments under an agreed mandate. One organization can bring these activities together, but an annuitant’s rights depend on the entities and guarantees specified in the legal documents.

The price of a retirement promise

AT&T’s final accounts give a more precise picture than the initial announcements. For 2023, the company recorded the settlement of $8.067 billion in pension obligations and the transfer of $7.704 billion in plan assets. It recognized a pre-tax settlement gain of $363 million. The purchase was funded from the plan’s assets, without an additional contribution by AT&T for the transaction. ²

The first two figures measure different things. The pension obligation is a present value: expected future benefits are converted into an amount today, using financial and demographic assumptions. The transferred assets are the property delivered to purchase the contracts. The $363 million difference appears in AT&T’s earnings. Apollo’s fees and the amount of pension payments require different calculations. ²

FIG. 02 $8,067m in obligations, $7,704m in assets: a $363m accounting difference.[S02]

Method and scope

Both bars start at zero and use the same scale, in millions of U.S. dollars. The $363 million difference is the pre-tax accounting settlement gain recorded by AT&T. Fees and profitability require a separate breakdown.

Why would an insurer agree to pay benefits whose value on the seller’s books exceeds the assets it receives? It prices the obligation using its own assumptions about investment returns, the timing of payments, life expectancy, expenses, required capital and expected profit. A pension plan’s accounting valuation and an insurer’s commercial price are shaped by different methods and constraints. The purchase price tells us something about the transaction without establishing its eventual profitability. That is why the rules governing insurer selection require scrutiny of investments, financial resources and contractual protections. ² ¹⁰

A reconstruction of the revenues earned along the way would require the fees for selecting the insurer, investment management charges attributable to this portfolio, the cost of its reinsurance and results over subsequent years. A revenue breakdown specific to the AT&T annuities remains to be obtained.

Following ownership back to Apollo

Athene became a subsidiary of Apollo Global Management through the merger effective January 1, 2022. The ultimate owner in this case is therefore the publicly traded Apollo group. The shorthand “fund” covers a corporate organization designed to last beyond the life of any one investment vehicle. ²⁷

Athene’s 2025 annual report shows the economic attraction of the arrangement. Apollo manages nearly all of Athene’s net invested assets, with compensation that depends in part on their composition and value. Investments in certain affiliated vehicles can carry additional fees. The report also acknowledges potential conflicts of interest. These disclosures describe relationships across the group; they do not provide a separate bill for managing AT&T’s pensions. ²⁶

Our investigation of life insurers, private credit and Bermuda follows the financial organization of these groups. This article starts with the beneficiary’s rights. Integration brings premium income, investment management and the manager’s compensation into the same organization. A durable pool of assets can be directed toward financing opportunities the group knows how to originate or select. For the annuitant, the test is whether the resulting income can meet the promised benefits after fees and investment losses. Assessing that requires the portfolio’s assets, payment schedules and protections.

Athene itself draws a legal boundary in the notes to its retirement services website. Each insurance subsidiary is responsible for its own obligations; Apollo Global Management and Athene Holding do not assume those payment obligations. Published capital maintenance agreements provide another form of support to subsidiaries. An undertaking to supply capital under specified conditions gives different rights from a guarantee that each annuitant can enforce directly. ³ ²⁶

Our guide to reading a life insurer’s financial strength explains how to place each figure in context. That distinction matters when a group presents figures for equity, liquidity or assets under management. They describe the resources of an economic organization. Establishing which resources actually support a pension requires a return to the issuing company’s balance sheet, the assets assigned to the benefits and any contractual commitments to provide support.

A separate account deserves a closer look

The AT&T portfolio includes a protection central to the analysis: a separate account. A report by U.S. Magistrate Judge Paul Levenson, dated August 29, 2025, identifies it in litigation brought by beneficiaries. The initial complaint had not adequately addressed that feature. The report nevertheless distinguishes the account’s existence from AT&T’s claim that approximately $8 billion was fully insulated from other liabilities. That broader claim had not been established on the merits at that stage. ⁶

A separate account can reserve assets for specified obligations and protect them from creditors of other parts of the business. Its precise effect depends on the governing law and the contracts. The Iowa insurer’s 2025 statutory accounts describe its group annuity separate accounts as legally insulated from the general account. The general account must still support the contractual payments if the separate account falls short. The New York subsidiary’s accounts describe a similar arrangement for its group annuities. ⁴ ⁵ ⁸

This structure adds protection for the assets and another source of support for the payments. The assets themselves still carry risk: a borrower can miss a payment, a loan can lose value, and an investment can prove difficult to sell. An assessment specific to AT&T would require the full contract, its provisions assigning assets to the benefits, and a current investment inventory. The insurer’s financial statements aggregate several transactions and cannot replace that examination.

The litigation illustrates the distinction. On September 28, 2026, the federal court in Massachusetts dismissed the claims against AT&T while allowing a claim for breach of the duty of prudence to proceed against State Street and the executive named alongside it. Relative risk and the protection afforded by the separate account remained disputed. In deciding the motion to dismiss, the judge treated the plaintiffs’ factual allegations as true, with their merits still to be tested against the evidence. The decision was neither a judgment against Athene nor a finding that it had failed to pay benefits. ⁷

The obligation to pay the pension and the duty to select the insurer prudently consequently follow separate legal paths. Department of Labor guidance requires the selection process to consider investment diversification, capital, the size of the transaction and available guarantees. Credit ratings form only one part of that assessment. ¹⁰

The protection system changes as well

The Pension Benefit Guaranty Corporation, the U.S. federal pension insurance agency, states that its protection ends for benefits covered by irrevocable commitments purchased from an insurer. After a transfer, state insurance guaranty arrangements become relevant, with their own eligibility conditions and limits. Changing the company responsible for the payments also changes the system protecting them. ⁹ ¹⁰

Comparing the two systems requires more than placing two coverage limits side by side. Depending on the arrangement, a limit may apply to periodic benefits or to the present value of future entitlements; age, the form of the annuity and jurisdiction also matter. The available record does not establish the protection applicable to each of the roughly 96,000 people covered. AT&T’s filings state that benefit amounts would remain unchanged. Demonstrating equivalent protection for every individual would require further work. ^{1, 9, 10}

The United Kingdom offers a useful comparison. An eligible annuity provided under a long-term insurance contract can qualify for Financial Services Compensation Scheme protection at 100%, with no cap. An occupational pension scheme itself operates under a different framework, potentially involving the Pension Protection Fund. The presence of an overseas reinsurer behind a British insurer therefore does not, by itself, mean the policyholder has lost the protection attached to the insurance contract. ²³ ²⁴

At Prudential, risk moved before the policies

A British case shows how these distinctions unfold over time. On March 14, 2018, The Prudential Assurance Company Limited, known as PAC, entered into both a business transfer agreement and a collateralized reinsurance agreement with Rothesay Life plc. Assets moved to Rothesay, together with much of the portfolio’s economic risk and reward. The contractual obligations to policyholders remained with PAC. The Court of Appeal explained the position in its December 2, 2020 judgment. ¹¹

The distinction became particularly clear in August 2019, when the High Court initially refused the legal transfer while the reinsurance stayed in place. The companies had already reorganized the portfolio’s financing; changing the direct insurer still required judicial approval. ¹²

Following the appeal and final court approval on November 24, 2021, the transfer took effect on December 15, 2021. Rothesay became responsible for approximately 350,000 policies. Around 33,000 others remained with Prudential and continued to be reinsured. Prudential also temporarily administered the transferred policies on Rothesay’s behalf. These figures describe the final position reported for 2021 and are not directly comparable with the counts announced when the transaction began. ¹³

FIG. 03 Risk, legal obligations and administration move at different times.[S11][S12][S13]

Method and scope

The final December 2021 position separates policies legally transferred to Rothesay from those remaining with PAC. Counts are rounded; the branches represent legal categories and their widths are not proportional to the policy counts.

The Rothesay sequence is historical: Blackstone sold its stake on December 1, 2020, before the legal policy transfer in December 2021. ³⁰

The company handling an inquiry or administering a payment is therefore not necessarily the company that legally owes the money. Ownership can also change without replacing the insurer named in the contract. Athora’s acquisition of Pension Insurance Corporation Group, completed on March 27, 2026, provides a current example: PIC says the legal entity insuring its policyholders’ pensions remained the same after the change of shareholder. ¹⁴ ¹⁵

Athora should also be distinguished from Athene. Athora reports that Apollo, including Athene, held a 24.51% economic interest as of December 31, 2025, and describes its investment management relationships with Apollo. That dated ownership figure does not make Athora a wholly owned subsidiary or establish that any particular PIC policy has been reinsured. ¹⁶

Even the point at which insurance enters a British pension arrangement matters. In a buy-in, a scheme purchases a policy to fund benefits, while its trustees remain responsible to members. In a buy-out, the insurer assumes direct responsibility for the covered pensions. The Pensions Regulator describes both structures: an announcement that a scheme has reached an agreement with an insurer can refer to materially different legal arrangements. ¹⁷

Reinsurance adds a second contract

Bermuda draws attention because these arrangements can combine international transfers, different regulatory frameworks and affiliated companies. The first task is to identify the agreement itself. In an ordinary reinsurance arrangement of this kind, the insurer retains its obligation to the annuitant and acquires a claim against a reinsurer for agreed payments. The contract between insurance companies supports the annuity contract. The Prudential Regulation Authority explicitly states that insurers remain responsible for their promises to annuitants under both longevity and funded reinsurance. ¹⁸

With funded reinsurance, an agreement may cover both investment risk and the cost of paying benefits for longer than expected. An upfront premium funds the obligations assumed, while collateral arrangements protect the ceding insurer if its counterparty fails to perform. The legal ownership of the assets, their custody and the allocation of their economic returns can differ across structures. Saying that “the money has gone to Bermuda” leaves those essential questions unanswered. ¹⁹ ²⁰

Athene Annuity and Life Company’s accounts do describe a treaty with Athene Annuity Re Ltd in Bermuda, effective January 1, 2023, covering an agreed proportion of certain new group annuity business. They also describe the insurer’s continuing responsibility to its customers if the reinsurer does not perform. The published treaty disclosure covers a category of group-annuity business. An allocation of AT&T’s portfolio, assets or liabilities to that treaty remains to be established from the documents reviewed. ⁴

FIG. 04 The insurer owes the pension; the reinsurer owes payments to the insurer.[S18][S20]

Method and scope

A general mechanism: the insurer owes the annuity and holds a separate claim against the reinsurer. Recapture brings ceded risks and the resources needed to support them back together at the insurer, subject to contractual terms. This diagram does not trace a specific AT&T treaty.

When an arrangement breaks down, recapture may follow: the insurer takes back risks it previously ceded and recovers assets under the contractual terms. Solvency triggers or other breaches can activate this process before insolvency. Throughout, the obligation to the policyholder has remained with the insurer. The additional challenge is to assemble the resources, eligible assets and liquidity needed to keep honoring that obligation. ¹⁸ ²⁰

The economic case remains open

There is a sound economic reason to match some annuity liabilities with investments that are difficult to sell. Predictable payments allow an investor to hold assets for long periods and collect their income without relying on a quick sale. Corporate and infrastructure financing can benefit from that horizon. The PRA recognizes the potential advantages while requiring insurers to examine concentrations and the quality of the match between assets and liabilities. ¹⁸

This asset-liability management, or ALM, matches expected resources to promised payments. Research by Ralf Meisenzahl, Jackson Overpeck and Andy Polacek at the Federal Reserve Bank of Chicago, revised on April 27, 2026, finds evidence of better matching of maturities and cash flows. Its scope is specific: the results are concentrated in indexed annuities, U.S. savings products whose returns depend partly on market indexes. They cannot be used to establish the quality of the assets supporting the lifetime benefits transferred by AT&T. The authors also identify liquidity risks and growing financial interconnectedness. ²²

British regulators are examining a separate issue: the incentives created by their rules. In CP8/26, published on April 29, 2026, the PRA proposed changing the valuation adjustment applied to funded reinsurance claims to better reflect counterparty risk and bring their treatment closer to that of economically similar assets. The consultation closed on July 31, with a proposed implementation date of July 1, 2027. The PRA pages reviewed on October 23, 2026 still present CP8/26 as a consultation. ¹⁹ ²⁸ ²⁹

The available stress tests also call for a measured interpretation. In the exercise published in November 2025, using end-2024 balance sheets, the PRA found that the participating insurers could absorb the recapture assumed in its exploratory scenario. It nevertheless reported a material effect on solvency and highlighted the exercise’s limitations. The result indicates capacity to withstand that particular scenario; exposures and collateral still need to be examined as they evolve. ²¹

The company that must pay in twenty years

The documents answer the first question in this series. For the transferred AT&T benefits, payment is owed by the issuing insurer identified in the applicable contract. Apollo controls the corporate group. An asset manager earns income from investing its assets. A reinsurer may assume some of the risks. These relationships help determine the insurer’s ability to pay while leaving each party with its own responsibilities.

The next task is to examine the resources sustaining that ability: asset quality, fees, available capital, guarantees and the terms on which ceded risks can return. For AT&T, a complete reconstruction would require the full group annuity contracts, the separate account’s investment inventory and the reinsurance treaties attributable to the portfolio. An asset manager’s place in the ownership chart does not, on its own, settle whether the arrangement is efficient or fragile.

The legal principle has an explicit counterpart in France: in the version dated June 11, 2026 consulted on Légifrance, Article L.111-3 of the Insurance Code preserves an insurer’s responsibility to its policyholder when it buys reinsurance. Products, pension arrangements and guarantee systems must then be compared within their respective legal frameworks. ²⁵ For someone who will still be collecting a pension in twenty years, the practical question remains the one that began this investigation: which company owes the money, and which resources will it actually be able to draw on when payment falls due?

Scope of the investigation

Research updated through October 23, 2026. This article draws on regulatory filings, financial statements, judicial decisions, supervisory documents and academic research. Corporate statements are attributed to the companies concerned; their promotional assessments of pension security are not treated as independent findings. No interviews were conducted. Allegations in the U.S. litigation are distinguished from established facts and from the procedural effect of court decisions. The reinsurance diagram illustrates a general mechanism and does not assign an undocumented financial route to the AT&T portfolio.

Sources

Each note retains the relevant passages and their limits.

S01 · AT&T Inc. / U.S. Securities and Exchange Commission · Published: 2023-05-03 · Accessed: 2026-10-23AT&T Inc. : Form 8-K, 3 May 2023
Passages and scope
Commitment agreement of 26 April 2023; closing on 3 May 2023; payments from August 2023
Item 8.01 : Other Events
Contemporaneous evidence of the partial transfer: approximately 96,000 participants and beneficiaries; two issuing insurers, Athene Annuity and Life Company and Athene Annuity & Life Assurance Company of New York. The plan trust funded the purchase. The insurers irrevocably assumed responsibility for payments from August 2023, without changing the benefits due.
The amounts in this announcement were provisional. Individual allocation between the two issuers and the full contracts are not included; this source alone does not establish joint and several liability between the insurers.
S02 · AT&T Inc. / U.S. Securities and Exchange Commission · Published: 2024-02-23 · Accessed: 2026-10-23AT&T Inc. : 2023 Form 10-K, Note 14: Pension and Postretirement Benefits
Passages and scope
Year ended 31 December 2023; transfer on 3 May 2023
Note 14; “Group annuity contract transfer” rows in the obligation and asset tables; “Settlement (gain) loss”
Final figures distinguish $8,067 million of pension obligations removed from the plan, $7,704 million of assets transferred and a $363 million pre-tax accounting settlement gain. The difference is an accounting outcome, not a disclosed fee, a benefit cut or a cash receipt by AT&T.
Amounts are in millions of dollars. The actuarial obligation is a present value, distinct from the nominal sum of future payments. The AT&T plan continues after this partial transfer.
S03 · Athene · Accessed: 2026-10-23Athene : Advocacy & Resources on the Retirement Industry
Passages and scope
Current page accessed on 23 October 2026; several indicators relate to 2023 or 2025
Footnote 5; legal notices identifying the issuing companies at the bottom of the page
Footnote 5 assigns insurance obligations to the issuing subsidiary and states that Apollo Global Management and Athene Holding are not responsible for those subsidiaries’ ongoing policy and contract obligations. The legal footer identifies the group-annuity issuers.
An advocacy page published by an interested party, rather than an independent assessment. Its promotional ratios and group figures do not describe the assets or security of the AT&T portfolio alone. It does not replace an individual certificate.
S04 · Athene Annuity and Life Company / U.S. Securities and Exchange Commission · Published: 2026-04-03 · Accessed: 2026-10-23Athene Annuity and Life Company : 2025 statutory financial statements appended to prospectus filed 3 April 2026
Passages and scope
AAIA statutory financial statements at 31 December 2025, with comparative years
Appended financial statements: Note 1, organisation; reinsurance note, AARe treaty effective 1 January 2023; “Separate Accounts” note, “Group Annuity Separate Accounts”; reinsurance risks
The ownership chain runs through Athene Annuity Re Ltd., Athene Holding and Apollo. The statements describe legally insulated group-annuity separate accounts, backed by the general account if the separate account cannot pay. A modco treaty with AARe covers certain new pension group annuities from 2023, without identifying the AT&T allocation.
The main prospectus describes a RILA product distinct from the AT&T contract; only the notes to the company’s financial statements are used. The $43,352,257 thousand of group-annuity separate-account assets is an AAIA-wide total. The $857,578 thousand of reserves ceded under the PGA treaty at year-end 2025 cannot be attributed to AT&T from this filing.
SEC: AAIA supplement of 17 June 2026
S05 · Athene Annuity & Life Assurance Company of New York / U.S. Securities and Exchange Commission · Published: 2026-04-03 · Accessed: 2026-10-23Athene Annuity & Life Assurance Company of New York : 2025 statutory financial statements appended to prospectus filed 3 April 2026
Passages and scope
AANY statutory financial statements at 31 December 2025
Appended financial statements: “Separate Accounts” note, particularly p. 47; reinsurance risks and notes
AANY describes two group-annuity separate accounts, insulated from its other business, and a general-account obligation if the separate account cannot pay. Its reinsurance arrangements do not remove its responsibility as the issuing insurer.
The AAIA guarantees mentioned for 2019 contracts and 2020 assignments do not establish a guarantee of the 2023 AT&T contract. As with S04, the terms of the RILA product presented at the beginning are not the terms of the AT&T contract.
SEC: AANY prospectus of 16 July 2026
S06 · U.S. District Court for the District of Massachusetts : Magistrate Judge Paul G. Levenson · Published: 2025-08-29 · Accessed: 2026-10-23Piercy et al. v. AT&T Inc. et al. : Report and Recommendation, ECF 131
Passages and scope
Report and recommendation on the initial complaint, case 1:24-cv-10608-NMG
pp. 75–79; p. 76 distinguishes the separate account from AT&T’s asserted amount; pp. 76–78 reproduce DOL pp. 19–20
The judicial document confirms the existence of a separate account for the AT&T annuities, while distinguishing that fact from AT&T’s assertion that approximately $8 billion was fully ring-fenced, based on material outside the complaint. It also reproduces DOL passages on separate-account structures.
A magistrate’s report on an initial complaint, not a final judgment on solvency or asset quality. S07 updates the procedural position. This is an unchanged PDF copy of a primary judicial document hosted by a news publisher.
S07 · U.S. District Court for the District of Massachusetts : Judge Nathaniel M. Gorton · Published: 2026-09-28 · Accessed: 2026-10-23Piercy et al. v. AT&T Inc. et al. : Memorandum and Order, ECF 186
Passages and scope
Order signed and filed on 28 September 2026; case 1:24-cv-10608-NMG
pp. 4–6: procedural stage and alleged risks; pp. 7–8: AT&T; p. 9: disposition
The court allows only Count IV, the prudence claim against State Street, to proceed and dismisses the other claims. At this pleading stage plausible allegations are accepted as true for the motion; competing risk assessments have not been resolved on their merits.
The order makes no finding of Athene insolvency, reduced monthly benefits or liability on the merits. Its abbreviated reference to “termination” does not justify describing the AT&T transfer as a wind-up of the entire plan.
S08 · U.S. Department of Labor : Employee Benefits Security Administration · Accessed: 2026-10-23Report to Congress on Interpretive Bulletin 95-1
Passages and scope
June 2024 report, announced on 24 June 2024
Pages 19–20: employer-dedicated or commingled separate accounts; general-account backstop
The report, reviewed directly, describes employer-dedicated and commingled separate accounts and their usual general-account backstop. Pages 19–20 distinguish this legal protection from risks in the underlying investments. The report also records differing stakeholder views.
The full report was downloaded directly from the Department of Labor website on 23 October 2026; the passages used were checked on pages 19–20. It provides a general framework and stakeholder submissions rather than an audit of AT&T’s assets or contract.
S09 · Pension Benefit Guaranty Corporation · Accessed: 2026-10-23PBGC : Annuities
Passages and scope
Current institutional guidance page, accessed on 23 October 2026
Introductory guidance and opinions concerning irrevocable commitments
PBGC coverage ends for benefits covered by irrevocable commitments purchased from an insurer. This explains why an annuity transfer changes the applicable protection system.
The page does not reconstruct state-by-state insurance guaranty protection for AT&T participants. PBGC limits and insurance protection limits cannot be compared directly without the relevant benefit and eligibility terms.
S10 · U.S. Department of Labor / Electronic Code of Federal Regulations · Published: 1995-03-06 · Accessed: 2026-10-2329 CFR § 2509.95-1 : Interpretive bulletin on selecting an annuity provider
Passages and scope
Original 1995 bulletin, amended in 2007 and 2008; eCFR version accessed on 23 October 2026
§ 2509.95-1(b)–(e), particularly (c)(1)–(6)
Selecting an annuity provider is a fiduciary decision. The analysis must consider investments, capital, business lines, contract structure, separate accounts and protection arrangements; ratings alone are insufficient.
Interpretive guidance whose exceptions and context matter. The text does not automatically establish that any category of insurer ownership satisfies or breaches the duty of prudence. The eCFR text was accessed on 23 October and displayed as current through 21 October 2026.
S11 · Court of Appeal of England and Wales / The National Archives · Published: 2020-12-02 · Accessed: 2026-10-23Re Prudential Assurance Company Ltd and Rothesay Life Plc [2020] EWCA Civ 1626
Passages and scope
Agreements of 14 March 2018; appeal decided on 2 December 2020
Paragraphs 19–20: reinsurance and legal obligor; paragraph 103: parental support; paragraph 108: FSCS; paragraph 109: regulatory supervision
The judgment distinguishes economic risk transfer through reinsurance from a transfer of obligations to policyholders. PAC remained the debtor until the portfolio transfer took effect. It also distinguishes hoped-for parental support from a contractual commitment.
The appeal judgment remits the matter to the High Court; it is not the effective date of the transfer, which occurred in 2021. The historical policy counts in the proceedings are not the final counts reported in S13.
S12 · Prudential plc · Published: 2019-08-16 · Accessed: 2026-10-23High Court judgment on proposed transfer of annuity business
Passages and scope
Initial High Court refusal of the transfer on 16 August 2019
Announcement, paragraphs on the continuation of reinsurance and policy terms
Following the initial court refusal, Prudential said that the reinsurance remained in place and policy benefits and terms were unchanged. The case shows that an economic transfer can precede a legal transfer.
A statement by a party to the transfer. The £12 billion figure refers to reinsured liabilities, not the acquisition price of an insurer; it should not be mixed with later valuations.
S13 · Rothesay Limited · Accessed: 2026-10-23Rothesay Limited : Annual report and accounts 2021
Passages and scope
Year ended 31 December 2021; financial statements authorised on 11 February 2022
Printed pp. 17 and 65 (PDF pp. 19 and 67); “Progress in 2021” / “Prudential transaction”; authorisation on printed p. 101
Following approval on 24 November 2021, the transfer became effective on 15 December. Approximately 350,000 policies moved to Rothesay, while approximately 33,000 remained Prudential obligations under reinsurance. Prudential temporarily administered the transferred policies on Rothesay’s behalf.
Rounded policy counts, not necessarily distinct individuals. No reconciliation is made with the historical scopes of 400,000 or 370,000. Completion of the administrative migration announced for 2022 has not been verified.
S14 · Pension Insurance Corporation · Accessed: 2026-10-23PIC : Policyholder questions and answers
Passages and scope
Acquisition completed on 27 March 2026; page accessed on 23 October 2026
“When did this happen?”; “Will you still be called PIC?”; “Does this transaction affect the security of my pension?”
PIC states that it retains its identity and its obligations to policyholders after the ownership change. The FAQ distinguishes a purchase of shares from a transfer of insurance contracts.
Promotional assessments of security do not constitute an independent audit. The retained fact is that the issuing insurer and its obligations remain unchanged.
S15 · Athora Holding Ltd. · Published: 2026-03-27 · Accessed: 2026-10-23Athora Group completes acquisition of Pension Insurance Corporation Group and announces plans
Passages and scope
Closing on 27 March 2026; PIC figures at 31 December 2025; proposed headquarters relocation by the end of 2027
Closing announcement; footnote dating the indicators; paragraphs on headquarters
Athora announces completion of its purchase of PICG, PIC’s parent. Its proposed headquarters relocation from Bermuda to the UK remains subject to approvals. The announcement identifies the parent-company and insurance-company layers.
The £54.8 billion of assets and nearly 450,000 policyholders relate to year-end 2025, not the closing date. The presence of Bermudian reinsurers in the group does not establish that any particular PIC portfolio has been ceded to them.
S16 · Athora Holding Ltd. · Accessed: 2026-10-23Athora : Organisation
Passages and scope
Current page; economic interest stated at 31 December 2025
“Strategic Partners” section
Athora describes its ownership and investment relationships with Apollo. Apollo’s economic interest, including Athene, is stated as 24.51% at 31 December 2025; Athora should not be described as wholly owned by Apollo.
A dated ownership snapshot that may change. It does not trace a PIC portfolio through reinsurance treaties.
S17 · The Pensions Regulator · Published: 2025-06-03 · Accessed: 2026-10-23New models and options in defined benefit pensions schemes
Passages and scope
Guidance published on 3 June 2025
Insurance solutions : Buy-ins / Buy-outs
In a buy-in, the policy is an asset of the pension scheme and trustees remain responsible to members. In a buy-out, the insurer assumes direct responsibility; any subsequent scheme wind-up and residual risks require separate consideration.
The distinction concerns legal responsibility, rather than simply the proportion of members covered. A buy-in may cover the entire scheme without yet being a buy-out.
S18 · Bank of England / Prudential Regulation Authority · Published: 2022-09-20 · Accessed: 2026-10-23Charlotte Gerken : Speech at the Bank of America conference
Passages and scope
Speech delivered on 20 September 2022
“Funded reinsurance” and “Longevity reinsurance” sections; footnote 5
The PRA explains that an insurer remains responsible for promises to annuitants after reinsurance. Recapture can follow default or contractual, regulatory or tax triggers.
A general explanation, not a description of the AT&T portfolio’s contractual terms. Recapture does not necessarily require the reinsurer’s insolvency.
S19 · Bank of England / Prudential Regulation Authority · Published: 2026-04-29 · Accessed: 2026-10-23CP8/26 : Funded reinsurance
Passages and scope
Consultation closed on 31 July 2026; proposed implementation on 1 July 2027
Paragraphs 1.5, 1.15–1.16; 2.5–2.8; 3.5–3.7, 3.13; 4.6–4.13
The PRA proposes changing the counterparty-default adjustment applied to reinsurance recoverables. It describes an asymmetry against some economically comparable investments and the risk of recovering insufficient or less suitable assets on recapture.
The PRA pages reviewed on 23 October 2026 present CP8/26 as a consultation. Proposed implementation is 1 July 2027, with a savings provision for risks fully transferred by 30 September 2026. The estimates of 2–4%, 11–15% and approximately 10% combine the CDA, SCR and risk margin relative to the best estimate of liabilities.
S20 · Bank of England / Prudential Regulation Authority · Published: 2025-10-23 · Accessed: 2026-10-23SS5/24 : Funded reinsurance, October 2025 version
Passages and scope
Version applicable from 27 October 2025
Printed pp. 4–5, paragraphs 2.5–2.7A; printed pp. 7–9, paragraphs 2.15–2.23
Supervisory expectations require assessment of recovered collateral quality, rebalancing costs, permitted asset substitution and an operational recapture plan. Matching-adjustment eligibility must rely on existing permissions.
This is the version published in October 2025, distinct from the draft appended to CP8/26. Stress scenarios and planning requirements are not forecasts of default. Paragraphs 2.7A and 2.18 contain a narrow MAIA exception for intra-group reinsurance collateral equivalent to assets already admitted to the MA portfolio.
S21 · Bank of England / Prudential Regulation Authority · Published: 2025-11-17 · Accessed: 2026-10-23Life Insurance Stress Test 2025 : Results report
Passages and scope
Balance sheets at 31 December 2024; exploratory exercise published in November 2025
Executive summary; Annex 2 : Exploratory scenario findings: FundedRe recapture
The recapture scenario covers £12.3 billion of liabilities. For the relevant participants, SCR coverage falls from 154% after the market shock to 144% after recapture. The PRA finds that they can absorb the shock on the balance sheets tested.
An exploratory scenario without an assigned probability, not a forecast. It uses collateral observed at year-end 2024, without future substitutions or an exchange-rate shock. The 144% ratio does not describe the entire sector or every possible situation.
S22 · Federal Reserve Bank of Chicago ; Ralf R. Meisenzahl, Jackson Overpeck, Andy Polacek · Accessed: 2026-10-23Life Insurers’ Private Credit Investments and Annuity Market Share Capture : Working Paper 2025-09
Passages and scope
First published in June 2025; revised on 27 April 2026
PDF: printed pp. 1, 3, 23–24, 31–32 (PDF pp. 3, 5, 25–26, 33–34)
The paper identifies a maturity and cash-flow matching mechanism between certain private placements and US indexed annuities. It also discusses liquidity, restructuring and interconnectedness risks.
The findings concern indexed annuities in particular, often with a 5–10-year horizon, and do not establish better asset-liability matching for the AT&T lifetime-annuity portfolio. This is a working paper reflecting the authors’ views, not an official position of the Federal Reserve as a whole.
S23 · Financial Services Compensation Scheme · Accessed: 2026-10-23FSCS : Pensions protection
Passages and scope
Current page accessed on 23 October 2026
Pension provider failures
For eligible long-term insurance pension contracts, including annuities, FSCS states 100% protection with no upper limit. An occupational pension scheme itself is not covered by this same FSCS protection.
The insurer, contract and claim must still meet eligibility conditions. Insured annuities, SIPPs, investments and PPF arrangements must be distinguished.
S24 · Financial Services Compensation Scheme · Accessed: 2026-10-23FSCS : Insurance protection
Passages and scope
Current page accessed on 23 October 2026
Life insurance and annuities; reinsurance exclusions
The page details cover for eligible policies and distinguishes insurance from reinsurance supplied to insurers, which is not directly covered. A foreign reinsurer does not, by itself, remove protection attached to an eligible UK insurance policy.
The policyholder’s protection depends on the applicable conditions. FSCS protection does not eliminate the insurer’s counterparty risk.
S25 · République française / Légifrance · Accessed: 2026-10-23Code des assurances : Article L.111-3
Passages and scope
Version in force since 15 June 2008; text displayed as at 11 June 2026 and accessed on 23 October 2026
Article L.111-3
Article L.111-3 provides that an insurer purchasing reinsurance remains solely responsible to its policyholder. It supplies the legal bridge to France; other contract features and protection arrangements remain specific to each system.
The version dated 11 June 2026 was read directly on Légifrance on 23 October 2026; it states that the provision has been in force since 15 June 2008. The canonical URL and October-dated versions returned 403 errors. This confirms the cited version’s wording; full consolidation as at 23 October remains outside the verified scope. The provision concerns the ceding insurer’s responsibility and does not quantify protection for French products.
S26 · Athene Holding Ltd. / U.S. Securities and Exchange Commission · Published: 2026-02-25 · Accessed: 2026-10-23Athene Holding Ltd. : 2025 Form 10-K
Passages and scope
Year ended 31 December 2025
Risk Factors : Apollo asset management and fees; Schedule II : Debt and Guarantees; Pension Group Annuities
The group describes Apollo’s management of substantially all net invested assets, fees linked to value and composition, and possible additional affiliated-fund fees. It also reports an AHL capital-maintenance agreement for AAIA.
The filing does not provide a fee breakdown for the AT&T portfolio. A conditional capital-maintenance agreement is not a general Apollo guarantee of every annuity.
SEC: Athene, 10-Q at 30 June 2026
S27 · Apollo Global Management, Inc. / U.S. Securities and Exchange Commission · Published: 2022-01-03 · Accessed: 2026-10-23Apollo : Form 8-K12B reporting completion of the Athene merger
Passages and scope
Merger effective on 1 January 2022
Introductory Note; Item 2.01 : Completion of Acquisition or Disposition of Assets
The Apollo–Athene merger became effective on 1 January 2022. This establishes group ownership at the time of the AT&T transaction without changing the separate legal identity of the issuing insurers.
Apollo Global Management is a publicly listed company, distinct from a finite-life private equity fund. Share ownership alone does not create an annuitant’s claim against the parent company.
S28 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23SS5/24 : Funded reinsurance: current publication page
Passages and scope
Current version published on 23 October 2025, applicable from 27 October 2025; page accessed on 23 October 2026
Latest updates; Current version
The official landing page identifies the current SS5/24 version and its effective date. It was checked to distinguish the operative statement from the 2026 draft.
The absence of a link to a final CP8/26 decision on this page is a status check, not exhaustive evidence that no publication exists elsewhere.
S29 · Bank of England / Prudential Regulation Authority · Published: 2026-10-01 · Accessed: 2026-10-23PRA Regulatory Digest : September 2026
Passages and scope
September 2026 regulatory activity; digest published on 1 October 2026
List of policy statements and consultations
The digest was used to check developments following CP8/26. No policy statement finalising that consultation was identified in it during the review.
The digest covers September 2026. The 23 October review also checks the current CP8/26 and SS5/24 pages and targeted searches of PRA publications. This scope bounds the status conclusion.
S30 · Rothesay Limited and Rothesay Life Plc · Accessed: 2026-10-23Rothesay Limited and Rothesay Life Plc : Solvency and Financial Condition Report 2021
Passages and scope
Position at 31 December 2021; report approved on 31 March 2022
Printed p. 11 (PDF p. 13), “Shareholders”
Blackstone sold its stake on 1 December 2020. At 31 December 2021, GIC and MassMutual each held 49% of Rothesay Limited’s nominal share capital; Rothesay Limited owned Rothesay Life plc.
The Rothesay case illustrates a historical legal mechanism. The December 2021 transfer should not be presented as involving an insurer still owned by Blackstone.