By Stephen Roth and Lorna MacLeod (December 20, 2018, 11:57 AM EST) -- For many life insurance companies, the most burdensome aspect of registering insurance contracts that are not investment company securities with the U.S. Securities and Exchange Commission is the requirement to prepare audited generally accepted accounting principles, or GAAP, financial statements. This requirement is dictated by the fact that these nonvariable insurance contracts must be registered on Forms S-1 or S-3. On Sept. 28, 2018, the staff of the SEC's Division of Investment Management issued a series of letters pursuant to Rule 3-13 of Regulation S-X permitting certain companies to file financial statements prepared in accordance with statutory accounting principles, or SAP financial statements, in lieu of GAAP financial statements in registration statements on Form S-1 for certain index-linked annuity contracts....