Why Insurers Choose ICOLI

What insurance company-owned life insurance is, how it works, and why insurers use it.

Allowable Employee Benefit Obligations

What ICOLI is, and the employee benefit obligations it can informally fund.

Insurance Company Owned Life Insurance (ICOLI) is a life insurance arrangement where the insurance company is both the owner and beneficiary of policies on select senior employees. It is often used to informally fund certain employee benefit obligations in a tax-efficient and capital-efficient way

Types of Employee Benefit Obligations That Can Be Used

ICOLI is typically structured to address general employee benefit costs rather than just executive deferred compensation. Common allowable obligations include:

  • General employee benefits such as health, dental, vision, and other group insurance coverage
  • Retirement plan funding (e.g., 401(k) matching contributions, pension plan costs)
  • Severance and retention benefits for key personnel
  • Other non-qualified benefit expenses that are part of the insurer’s overall benefit plan

These obligations are often aggregate costs that the insurer wants to offset without creating a taxable liability or a direct balance sheet charge.

Economic Benefits Of ICOLI

Tax treatment, RBC treatment, risk management & earnings stabilization

Favorable Tax Treatment

Inside buildup
All gains on all investments within ICOLI compound free of all tax.
Tax-free distributions
Death benefits are tax-free to the company (cash value + mortality component = death benefit).
No DTL
ICOLI inside buildup is non-operating income — no deferred tax liability.

Favorable RBC & rating-agency treatment

NAIC risk-based capital
Capital charge of 0% (N/A) for Life; 5% for P&C / Health companies.
S&P, AM Best BCAR
Market practice of purchasers is consistent with the NAIC RBC model.
ICOLI
Considered informal funding — offsets employee & executive benefit obligations.

Risk management

  • ERM tool to insure against economic loss from premature death of a key employee.
  • Economic hedge / informal funding of deferred compensation or other executive benefit programs.
  • Offset funding costs of employer-sponsored health and welfare plans.

Investment earnings stabilization

  • Volatility-reducing “wraps” can allow book-value accounting on assets within ICOLI that would otherwise receive mark-to-market treatment.

How It Works

From policy issuance to the insurance company balance sheet

Step 1

COLI policies issued by highly rated carriers

Carrier 1, Carrier 2, Carrier 3, Carrier 4, and others

Step 2

Client-selected asset manager

Investments held within the policy’s separate account

Step 3

Expenses include

DAC · M&E · Premium tax · Broker compensation

Expense factors

Age · Tobacco & health · Gender · Size of group

Total ICOLI asset (net crediting rate)

Step 4

Insurance company balance sheet

Admitted asset, immediately accretive to surplus.
RBC charge is 0% for Life, 5% for Health and P&C.
Investment earnings permanently (Stat and GAAP) tax-exempt.

Implementation Timeline

The engagement process, step by step

Step 1 Client

Determine budget & strategy

Typically 2–3% of net admitted assets.

Step 2 Advisor

Define the census

Prepped by Advisor from standard HR data (gender, DOB, citizenship, date of hire, compensation).

Step 3 Advisor

Complete plan optimization

Pro forma built by Advisor.

Step 4 Advisor

Negotiate with carriers & develop solution

No action required from client.

Step 5 Advisor

Summarize & present findings

Compiled and presented by Advisor.

Step 6 Client

Final approval & Board resolution

Client determination authorizing the Transaction.

Step 7 Advisor

Develop & distribute employee communications

Prepared by Advisor.

Step 8 Client

Complete consents via DocuSign

4–5 questions, no medical underwriting.

Step 9 Advisor

Paperwork submission to carriers

Minimal paperwork (10–15 pages); outstanding items resolved.

Step 10 Client

Wire premium to carriers

Capital is deployed into the IDF as scheduled.

Step 11 Advisor

Policy issuance & ongoing admin

Monthly performance and accounting reports shared with client.

Timelines vary by engagement. The primary drivers are the asset-manager selection process and the client’s funding schedule.

Mechanics Of ICOLI Over Time

Illustrative cash surrender value & death benefit growth

For a pool of insured lives, cash surrender value and death benefit grow tax-free for decades. As lives pass, death benefits are paid to the company — so the in-force CSV and death benefit eventually decline while cumulative death benefit paid keeps compounding.

Accounting Treatment

Statutory & GAAP accounting for ICOLI

Admitted asset

COLI surrender value is considered an Admitted Asset* on the balance sheet.

Stat
Aggregate write-ins other than invested assets (Line 25)
GAAP
Other asset

Change in value

Any changes in the value of the asset are recognized on the income statement.

Stat
Net investment income via aggregate write-ins for invested income
GAAP
Other income (FASB ASC 325-30)

* In accordance with SSAP No. 21 (6), “Life Insurance Policies” as defined by IRC § 7702 are considered an Admitted Asset.

STAT Statutory accounting — NAIC annual statement presentation.

Premium Payment Debit Credit
Aggregate write-ins for other than invested assets $185,000,000
Cash $185,000,000
To record the payment of premium in cash value life insurance
Period increase / decrease in cash surrender value Debit Credit
Aggregate write-ins for other than invested assets $12,500,000
Aggregate write-ins for other income $12,500,000
To record the periodic change in cash surrender value
Receipt of death proceeds Debit Credit
Cash $5,000,000
Aggregate write-ins for other than invested assets $3,000,000
Aggregate write-ins for miscellaneous income $2,000,000
To record the receipt of a death benefit

GAAP US GAAP presentation — FASB ASC 325-30.

Premium Payment Debit Credit
Investment in ICOLI $185,000,000
Cash $185,000,000
To record the payment of premium in cash value life insurance
Period increase / decrease in cash surrender value Debit Credit
Investment in ICOLI $12,500,000
Increase / decrease on investment in COLI $12,500,000
To record the periodic change in cash surrender value
Receipt of death proceeds Debit Credit
Cash $5,000,000
Other asset – life insurance $3,000,000
Miscellaneous income – non-taxable $2,000,000
To record the receipt of a death benefit

Consent Process

How employee consent is collected & documented

NAIC Regulatory Affirmation

Citations reaffirming ICOLI’s regulatory treatment

The accounting and capital treatment of ICOLI has been reviewed and reaffirmed by the NAIC. The citations below trace that treatment back to source.

Admitted asset status

The NAIC’s own reasoning for admitted-asset status treats an insurer-owned policy’s cash value like a cash deposit realizable on demand — admitted net of any outstanding policy loans and surrender charges.

Source: NAIC Statutory Issue Paper No. 87 — Other Admitted Assets, underlying SSAP No. 21R

Risk-based capital charge

The Life RBC formula assigns a static 0% C-1 asset charge to policy cash value for life and health insurers (5% for P&C) — with no look-through to the underlying investment allocation inside the policy.

Source: NAIC Life Risk-Based Capital formula (Life/Fraternal RBC Instructions)

Federal legitimacy layer

Beyond NAIC accounting and capital treatment, the practice sits on a federal statutory foundation. The Pension Protection Act of 2006 codified “COLI Best Practices” in Internal Revenue Code Section 101(j) — governing insurable interest, notice-and-consent, and highest-compensated-employee eligibility limits.

Source: Pension Protection Act of 2006; Internal Revenue Code §101(j)

ICOLI adoption has grown steadily rather than emerging as a fringe strategy — industry data shows the number of holders up roughly 58% and aggregate ICOLI cash surrender value up roughly 32% since 2012.

Citations

  • NAIC Statutory Issue Paper No. 87 — Other Admitted Assets content.naic.org
  • NAIC SSAP No. 21R — Other Admitted Assets (AP&P Manual)
  • NAIC Life Risk-Based Capital formula, Life/Fraternal RBC Instructions
  • Pension Protection Act of 2006; IRC §101(j) — COLI Best Practices

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