© 2019-2020 National Association of Insurance Commissioners 8 109/254/201920
(37) RBC Debt Service Computation This amount is the amount of 12 monthly principal and interest payments required to amortize the Total Loan Balance
(13) usin
a S
andardized A
ortization period of 300 months and the Annual Loan Interest Rate (17).
(38) RBC DCR Computation This is the ratio of the Net Operating Income (36) divided by the RBC Debt Service (37) rounded down to 2 decimal
laces. See Note 3 below for special circumstances.
(39) NCREIF Price Index at
Valuation
Computation The value of the NCREIF Price Index on the last day of the calendar quarter that includes the date defined in (21) and
(22).
(40) Contemporaneous
Prope
t
Value
Computation The Property Value (20) times the ratio (rounded to 4 decimal places) of the Price Index current to the Price Index at
valuation (39).
(41) RBC LTV Compu
ation The Total Loan Value (13) divided
the Contemporaneous Value (40) rounded to the nearest percent.
(42) CM Category Computation The risk category determined by applying the DCR (38) and the LTV (41) to the criteria in Figure (4), Figure (5) or
Fi
ure (6). See Notes 2, 3, 4, 5, and 6
elow for special circumstances.
Note 1: Net Operating Income (NOI): The majority of commercial mortgage loans require the borrower to provide the lender with at least annual financial statements. The NOI
would be determined at the RBC calculation date based on the most recent annual period from financial statements provided by the borrower and analyzed based on accepted
industry standards. The most recent annual period is determined as follows:
If the borrower reports on a calendar year basis, the statements for the calendar year ending December 31 of the year prior to the RBC calculation date will be used. For
example, if the RBC calculation date is 12/31/2012, the most recent annual period is the calendar year that ends 12/31/2011.
If the borrower reports on a fiscal year basis, the statements for the fiscal year that ends after June 30 of the prior calendar year and no later than June 30 of the year of the
RBC calculation date will be used. For example, if the RBC calculation date is 12/31/2012, the most recent annual period is the fiscal year that ends after 6/30/2011 and no
later than 6/30/2012.
The foregoing time periods are used to provide sufficient time for the borrower to prepare the financial statements and provide them to the lender, and for the lender to
calculate the NOI.
The accepted industry standards for determining NOI were developed by the Commercial Mortgage Standards Association now known as CRE Financial Council (CREFC). The
company must develop the NOI using the standards provided by the CREFC Methodology for Analyzing and Reporting Property Income Statements v.5.1. (www.crefc.org/irp).
These standards are part of the CREFC Investor Reporting Package (CREFC IRP Section VII.) developed to support consistent reporting for commercial real estate loans owned
by third party investors. This guidance would be a standardized basis for determining NOI for RBC.
The NOI will be adjusted to use a 3 year rolling average for the DSC calculation. For 2013, a single year of NOI will be used. For 2014, 2 years will be used, weighted 65% most
recent year and 35% prior year. Thereafter, 3 years will be used weighted 50% most recent year, 30% prior year, and 20% 2
nd
prior year. This will apply when there is a history
of NOI values. For new originations, including refinancing, the above schedule would apply by duration from origination. For the special circumstances listed below, the specific
instructions below will produce the NOI to be used, without further averaging.
For purposes of the NOI inputs at (14), (15), (16), and the computation of a Rolling Average NOI at (36), an insurer may report 2020 NOI (i.e., NOI for any 12-month fiscal
period ending after June 30, 2020 but not later than June 30, 2021) as the greater of: (1) actual NOI as determined under the CREF-C IRP Standards or (2) 85% of NOI
determined for the immediate preceding fiscal year’s annual report. This guidance with respect to 2020 NOI applies to the application of the 2020 NOI in risk-based capital
reporting for 2021, 2022, and 2023. In cases where an insurer reports 85% of 2019 NOI as the 2020 NOI input, the insurer should retain information about actual 2020 NOI in its
workpapers so that the information can be readily available to regulators.