Structured Settlements 4Real®Blog 2026

Structured settlements expert John Darer reviews the latest structured settlements and settlement planning information and news, and provides expert opinion and highly regarded commentary. that is spicy, Informative, irreverent and effective for over 20 years.

  • MetLife Announces NQA-Flex Deferred Payment Solution for Non-Physical Injury Settlements

    NQA-Flex Agreement is not constrained by IRC 72(u)

    MetlIfe has introduced the Non-Qualified Assignment Flex Agreement (NQA-FA) The NQA FA solution provides anthe same reliability and strength you expect from MetLife, while offering enhanced payment flexibility beyond our traditional Non-Qualified Assignment solution. 

    Key Highlights of NQA-Flex Funding Agreement

    • New alternative and complementary settlement tool defendants/insurers can use to resolve non-physical injury claims and lawsuits through periodic payments while transferring those payment obligations to MetLife’s Assignment Company.
    • Issued by MetLife Assignment Company, Inc. and Metropolitan Tower Life Insurance Company, both domestic US-based entities.
    • Not Subject to IRC 72(u)
    • Deferred Lump-sum payments are possible‒
    • Annual increases and customized payment designs•
    • Payments must be guaranteed and not life-contingent•
    • May allow non-natural persons (e.g., businesses or corporations) as payees (requires MetLife home office approval)
    • Maximum Deferral 15 years (compared to one year for the annuity funded non qualified assignment),
    • Maximum certain period is 40 years
    • MetLife traditional Non-Qualified Assignment (NQA) product is an annuity-based solution designed to accept the transfer of a defendant’s/insurer’s periodic payment obligation for certain non-physical injury cases.
    • Key Payment Characteristics of Traditional NQA
      • Subject to IRC 72(u)•
      • Requires immediate payments, to begin within one year from purchase
      • Must be made in substantially equal amounts
      • Life-contingent payments are permitted

    Potential Uses for Both NQA and NQA-Flex

    The NQA and the NQA-FA may be used to resolved non-physical injury matters including, but not
    limited to:

  • 🔹Structured Settlements and Bankruptcy of the Payee: What Courts Actually Look At

    Attorneys have been writing recently about how structured settlement payments are treated when a payee files for bankruptcy. It’s an important topic, and one where the outcome often turns less on the product itself and more on the documentation and purpose of the payments.

    This post focuses on bankruptcy of the payee — the injured person or the attorney — not bankruptcy of the insurer. Those are two entirely different conversations, and the guaranty system is not relevant here.

    After 43 years in this business, one pattern is clear: Bankruptcy courts care about the “why,” not just the “what.”

    🔹1. Courts Look at Purpose, Not Just Payment Streams

    A structured settlement payment stream doesn’t automatically become exempt just because it’s periodic. Courts look at:

    • the purpose of the payments
    • the nature of the underlying claim
    • how the settlement agreement characterizes the payments
    • whether the payments are tied to future needs or simply represent deferred cash

    The documentation has to support the exemption. If it doesn’t, trustees will challenge it.

    This is the part attorneys appreciate most when it’s said plainly:

    Allocation is a legal act. The planner can advise, but the lawyer owns the allocation.

    If the release and settlement documents don’t clearly allocate damages — or if the allocation is inconsistent with the facts — the bankruptcy court may treat the payments as non‑exempt.

    Good planning helps, but the legal documents carry the weight.

    🔹3. The Release Matters More Than People Think

    Courts routinely examine:

    • the release
    • the settlement agreement
    • the retainer (at altitude)
    • the petition
    • the schedules

    If the release is vague, generic, or silent on purpose, the trustee has room to argue that the payments are simply an asset of the estate.

    A well‑drafted release reduces that risk dramatically.

    🔹4. Entity Structure Can Affect Outcomes (At Altitude)

    Without going into product mechanics or anything that touches regulated territory, it’s fair to say:

    How the settlement is structured — legally, not commercially — can influence how a trustee views the payments.

    Courts look at:

    • who owns the rights
    • who controls the payments
    • whether the payee has any incidents of ownership

    Again, this is legal structure, not product structure.

    🔹5. Planning Discipline Protects the Debtor

    When the planning, documentation, and allocation are aligned, the debtor is far better positioned to defend the exemption.

    When they’re not, trustees notice.

    This is why attorneys who handle injury cases benefit from understanding how bankruptcy courts analyze structured settlement payments. It’s not about selling anything. It’s about avoiding avoidable problems years later.

  • Structured Settlement Collection Agency in Henderson, Nevada Is Still Not a Structured Settlement — Now Nevada Law Makes That Clear

    In October 2024, I documented that a Henderson, Nevada business calling itself “Structured Settlement” was, in fact, a collections agency, not a structured settlement company. That post focused on the predictable consumer confusion created when a debt‑collection business adopts a regulated financial term as its DBA.

    2024 post: Collection Agency Misleading Names in Nevada – Structured Settlements 4Real®Blog October 15, 2024

    In 2025, Nevada has now done something that brings the issue into even sharper focus: it has codified the definitions of “structured settlement” and “structured settlement agreement.” These definitions make the distinction unmistakable.

    Nevada’s 2025 Statutory Definitions

    NRS 42.275 — “Structured settlement”

    This aligns with federal law under IRC §104(a)(2) and §130. A structured settlement is a tort‑based periodic payment arrangement, not a loan, not a payment plan, and not a collection activity.

    NRS 42.280 — “Structured settlement agreement”

    This reinforces that structured settlements are legal instruments tied to tort resolution and life insurance funding — not consumer debt.

    Where Structured Settlements Actually Live: Life Insurers, Licensed Agents, and Brokers

    Nevada’s definitions don’t just clarify what a structured settlement is. They implicitly clarify who is involved in creating one — and who is not.

    Structured settlements are created within a regulated ecosystem involving:

    Life Insurers

    Structured settlement annuities are issued by licensed life insurance companies that:

    • fund periodic payment obligations
    • maintain statutory reserves
    • operate under solvency oversight
    • participate in qualified assignments

    Licensed Agents and Structured Settlement Brokers

    These professionals:

    • hold state insurance licenses
    • are appointed by the issuing life insurer
    • place structured settlement annuities
    • work with attorneys, mediators, and claims professionals
    • operate under suitability and disclosure rules

    Structured settlements arise from:

    • settlement agreements
    • judgments
    • stipulations

    Why This Causes Consumer Confusion

    When a collections business adopts the name “Structured Settlement,” consumers reasonably assume:

    • they are dealing with a structured settlement professional
    • the business is connected to their annuity issuer
    • the business has authority over their payments
    • the business is part of the settlement planning ecosystem

    None of that is true.

    The confusion is baked into the name, and Nevada’s statutory definitions now make that clear.

    📎 Sidebar: Why Consumers With Debt Call Me — or Others in My Industry

    If you’re receiving collection calls or letters from a business using the name “Structured Settlement,” it has nothing to do with a structured settlement or an annuity.

    Every month, consumers contact me—and likely others in the structured settlement industry—because:

    • they receive a collection notice
    • they cannot reach the Henderson collections agency
    • the notice or caller ID shows the name “Structured Settlement”
    • they search online for “structured settlement”
    • and legitimate structured settlement professionals appear at the top of the results

    These callers are trying to resolve consumer debt, not anything related to structured settlements, structured settlement planning or settlement planning..

    These collection contacts are unrelated to annuity issuers, periodic payments, or settlement agreements. The confusion comes solely from the business name.

    Nevada’s updated statutory definitions make the distinction clear: a structured settlement is a regulated, tort‑based payment arrangement funded by a life insurer — not a collections activity.

    A Note on Anonymous Complaint Sites

    To avoid any misunderstanding:

    This post does not rely on or endorse anonymous complaint sites. Anonymous postings are unverified and often unreliable. The purpose of this post is to clarify Nevada’s statutory definitions and the BBB‑verified business classification, not to validate or repeat anonymous allegations.

    Why This Matters

    Structured settlements are a regulated financial tool designed to protect injured people. They are defined by statute. They are created through settlement agreements and judgments. They involve licensed life insurers and qualified assignments.

    A collections business using the name “Structured Settlement” does not change the meaning of the term — but it does create confusion for consumers, lawyers, and journalists.

    My role, as always, is to keep the record clear.

    Closing

    Structured settlements have a precise meaning in Nevada law and federal law. A collections agency in Henderson, Nevada using the name “Structured Settlement” does not provide structured settlements or structured settlement agreements. It provides collections services. The distinction matters, and consumers deserve clarity.

  • Crypto Still Isn’t Suitable for Injury Victims — A Reminder From This Week’s Headlines

    A month ago, I walked readers through what happened to anyone who followed the August 2025 “sell your structured settlement as a bridge to crypto” hype and compared those positions to February 2026 prices. That analysis wasn’t about predicting markets — it was about showing how fast the emotional math collapses when people who were never equipped for volatility are pushed into it. But the warning didn’t start there. It goes back to the November posts — one responding to the national press‑release campaign urging people to sell their structured settlements as a bridge to crypto (because nobody floods the zone with national press releases to “expose pennies on the dollar”; that’s not advocacy, that’s hype), another documenting the Connecticut disaster with the cremation coffin rising to heaven and the crypto urn feeling the flames below, and the more recent Connecticut piece calling out the lack of mandatory Independent Professional Advice and why Attorney General William Tong should be looking into it. Together, those posts made the same point: crypto was never a bridge for injury victims. And here we are again, barely four weeks later, with headlines warning of a deeper Bitcoin slump and analysts openly discussing multi‑year recovery timelines. Different week, same lesson: the “bridge to crypto” was never a bridge. It was a plank.

    Crypto reversals hit hardest when people are least equipped for volatility — and this week’s slump is another real‑time reminder of why injury victims should never be pushed into market‑timing assets.

    The “sell your structured settlement as a bridge to crypto” pitch was always hype, not advocacy — nobody floods the zone with national press releases to “expose pennies on the dollar.”

    The November posts, the CT disaster, the IPA/Tong call‑out, and the February analysis all pointed to the same doctrine — crypto was never a bridge for injury victims; it was a plank people were pushed onto.

    And the headlines this week tell the story plainly:

    • “Bitcoin slump sparks fears of deeper crash” (msn.com)
    • Down nearly 25% in Q1 2026
    • Off 48% from its peak
    • Analysts warning recovery may not come until 2027
    • ETF outflows accelerating
    • Options markets tilting bearish
    • Oil‑driven inflation and geopolitical tension weighing on risk assets

    The headlines this week about Bitcoin’s latest slump aren’t just market noise. They’re a reminder of why suitability matters — and why crypto has never belonged anywhere near injury victims or anyone navigating a major life transition. When an asset class can fall nearly a quarter in a single quarter and almost half from its peak, the reversals don’t just test conviction. They rattle inexperienced holders off the ride. That’s not a character flaw. It’s human nature.

    Structured settlements were designed to remove the burden of market timing from people who should never be forced to shoulder it. They provide stability in moments when life is already volatile. Crypto does the opposite. It amplifies volatility, demands constant attention, and punishes hesitation.

    I’ve been saying this for years — in 2014, in 2018, in 2022, in the November posts, in the CT brain injury victim’s structured settlement to crypto to fnancial disaster analysis, in the IPA/Tong call‑out, and again in February. Gimmicks don’t become less gimmicky because a hype cycle is loud. They don’t become suitable because someone on the internet bragged about their gains. And they don’t become safe just because a new generation of “muthaforkers” shows up with a shinier pitch and a slew of national press releases.

    The emotional math hasn’t changed. The people who get hurt are always the same:

    • the inexperienced
    • the overwhelmed
    • the newly injured
    • the financially vulnerable
    • the people who never asked to become investors in the first place

    That’s why the guardrails exist. That’s why suitability exists. And that’s why the doctrine hasn’t changed.

    This week’s slump simply makes the truth harder to ignore: When the emotional math collapses, the people who can least afford the loss are the ones who get hurt.

    Crypto was never suitable for injury victims, and it is not suitable now.
    The “bridge to crypto” was never a bridge.
    It was a plank — and people were pushed out onto it.

    Structured Settlements to Crypto What Could Go Wrong Archives – Structured Settlements 4Real®Blog 2026

    Press Release → Siren Songs → Shipwreck – Structured Settlements 4Real®Blog 2026

    Structured Settlement and Cryptocurrency: A Cautionary Tale – Structured Settlements 4Real®Blog 2026

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  • Survivor Justice Tax Prevention Act Introduced

    The Survivor Justice Tax Prevention Act (H.R. 2347) was introduced March 25, 2026 in the 119th Congress. The bill would codify the IRS’s current internal policy so survivors of sexual assault and abuse are not taxed on compensatory damages or settlements.

    🔹 What the Bill Does

    • excludes compensatory damages for sexual assault or sexual contact from gross income
    • removes the “physical injury” requirement that has historically triggered taxation
    • bars the IRS from requiring medical records to substantiate claims
    • allows court orders or settlement agreements to serve as proof
    • aligns statutory language with existing IRS internal guidance

    🔹 Why It Matters

    • survivors avoid being taxed on deeply personal, non‑economic harmseliminates invasive IRS scrutiny into trauma or medical records
    • creates uniformity across cases and jurisdictions
    • reduces litigation friction around taxability
    • closes the gap between IRS practice and the tax code
    • 🔹 Legislative Status
    • introduced March 25, 2026 by Rep. Lloyd Smucker (R‑PA‑11)
    • referred to the House Ways and Means Committee
    • bipartisan support expected
    • follows similar legislation from the 118th Congress (H.R. 10055)
    • prior version advanced by Ways and Means in March 2026

    🔹 Closing Frame This bill does something simple but overdue: it brings the tax code in line with the lived reality of survivors. For an area long shaped by technical traps and invasive scrutiny, clarity and dignity are the real reforms.

    Actions – H.R.2347 – 119th Congress (2025-2026): Survivor Justice Tax Prevention Act | Congress.gov | Library of Congress

  • ⭐Equitable–Corebridge: What the Merger Means

    🔹 Transaction Summary

    Corebridge Financial and Equitable Holdings have entered into a definitive all‑stock merger valued at approximately $22 billion.The surviving entity will operate under the Equitable name and continue to trade on the New York Stock Exchange as EQH. Corebridge shareholders are expected to own roughly 51% of the combined company, with Equitable shareholders owning approximately 49%. Closing is targeted for year‑end 2026, subject to customary regulatory approvals and shareholder votes at both companies.

    🔹 Scale and Structure

    The combination creates a single retirement, life, wealth, and asset‑management platform serving more than 12 million customers with approximately $1.5 trillion in assets under management and administration. The merged entity will have broad distribution reach, enhanced scale, and a more diversified product and revenue mix, supported by a large long‑duration balance sheet and consistent cash generation.

    🔹 Lineage

    The transaction consolidates two of the most consequential U.S. annuity lineages of the last century. Corebridge carries the AIG Life & Retirement architecture, built through SunAmerica, VALIC, American General, and the New York‑domiciled United States Life Insurance Company, whose origins trace back to the mid‑1800s. Equitable Holdings brings the AXA‑Equitable lineage, itself rooted in The Equitable Life Assurance Society of the United States, founded in 1859. Post‑closing, these histories consolidate under the Equitable name, brand, and corporate structure.

  • 🎉 Happy Birthday, MetLife — 158 Years Strong

    MetLife was born in 1868 — in a New York already centuries old, but still thirty years away from becoming the five‑borough city we know today. The Brooklyn Bridge wasn’t even started yet. No towers. No cables. No traffic. Just an idea waiting for steel.

    Fast‑forward to today: cars are riding on the bridge, and MetLife is writing structured settlements. Wink, wink.

    That’s enough nostalgia for one birthday. Let’s get into the meat and potatoes.

    🥩 The Meat and Potatoes

    MetLife’s longevity isn’t just a trivia nugget — it’s a working demonstration of what durability looks like in a financial ecosystem where companies appear, merge, disappear, or reinvent themselves every decade. Through wars, depressions, recessions, regulatory rewrites, tax changes, product cycles, and industry reinventions, MetLife has remained a steady, recognizable presence.

    In the structured settlement space, that matters. This is an industry built on promises that stretch decades into the future. Stability isn’t a tagline — it’s the product. And MetLife has delivered that stability across generations, through market cycles that would have broken lesser companies.

    They’ve adapted when they needed to, held firm when it counted, and stayed relevant in a field where relevance is earned, not assumed.

    So here’s to 158 years of showing up, evolving, and staying in the conversation. Not many companies can say that. Even fewer can prove it.

    Happy Birthday, MetLife. Still standing. Still modern. Still part of the story.

  • Private Assets: The Shift Was Already Visible — New Insurance News Article Just Put a Number on It

    What New Article Really Shows

    Insurers aren’t planning to increase private‑asset exposure — they already have. A new article published March 20, 2026 in InsuranceNewsNet simply quantifies what we’ve been tracking: 88% of insurers now expect private assets to exceed 10% of their portfolios within two years.

    That’s a headline, but it’s not a revelation. It’s confirmation.

    Schedule BA: Where the Shift Was Visible All Along

    Anyone following insurer filings — especially Schedule BA, the U.S. statutory category for “Other Long‑Term Invested Assets” — has seen this migration unfolding for years. Schedule BA is where private‑equity fund interests, private‑credit vehicles, joint ventures, affiliated structures, and other Level 3 assets show up long before anyone writes a survey‑driven story.

    📎 Sidebar: What Schedule BA Doesn’t Stand For

    Schedule BA doesn’t stand for British Airways, and it definitely won’t get you upgraded on your next flight to LHR or LGW. It’s simply the U.S. statutory bucket for “Other Long‑Term Invested Assets,” the place where insurers park private‑equity funds, private‑credit vehicles, joint ventures, and other Level 3 holdings long before anyone writes a headline. If you want to see the shift before the surveys catch up, this is where it shows up first.

    The Pattern Is the Story

    Surveys don’t reveal the trend — they just add another data point to the same direction of travel. The filings have been telling this story for years. Today simply adds one more brick to the pile.

    Rock and roll.

    Insurers optimistic about their investments in 2026 – Insurance News | InsuranceNewsNet March 20, 2026

    Private Credit Contagion: Structured‑Settlement and Receivables Exposure Structured Settlements 4Real March 9, 2026

  • Private Credit Contagion: Why It Matters for Structured Settlement Annuitants and Receivables Investors

    by John Darer CLU ChFC MSSC CeFT RSP CLC, 4structures®

    🕵️‍♂️ Private Equity’s Quiet Build‑Up in Insurance

    Private equity’s influence in the insurance sector didn’t begin with the latest headlines. It has been building quietly for years, reshaping balance sheets and business models long before most consumers ever encountered the term “private credit.” Now that pieces of the story are starting to surface — a headline here, a chart there, a table row taken out of context — the real risk isn’t panic. It’s misunderstanding.

    I’m stepping in now because I can see where confusion is about to ignite. Before the tinder gets lit, consumers deserve a clear, grounded explanation of what’s happening, what isn’t, and how to interpret the noise without absorbing the fear.

    This isn’t a structured‑settlement story on its face. But it has direct implications for the people and investors who rely on structured‑settlement payment streams.

    🛡️ Why Annuitants Should Care

    Structured‑settlement payments are only as secure as the insurer making them. When insurers shift heavily into private credit, Level 3 assets, or affiliated‑fund loans, the stability of those long‑dated obligations changes.

    Key risks:

    🔹 Illiquid assets rising — Level 3 holdings are opaque and hard to value.

    🔹 Liquidity mismatches — Stress events can freeze or delay payments.

    🔹 PE‑owned insurers behave differently — Some use annuity assets to support affiliated private‑credit funds.

    🔹 Guaranty‑fund limits vary — Large obligations may not be fully protected.

    Annuitants don’t need to panic — but they do need to understand the landscape.

    💼 Why Receivables Investors Should Care

    Investors who buy structured‑settlement receivables often focus on discount rates and court orders. But the real risk sits upstream, inside the insurer’s general account.

    You’re not buying a bond. You’re buying an insurer’s promise.

    And that promise is backed by whatever assets the insurer holds.

    Risks that matter:

    📉 Liquidity stress can delay or reduce payments.

    🔍 Affiliated‑fund lending can mask deteriorating capital.

    ⚠️ Level 3 concentrations can hide valuation problems.

    🏚️ Runoff carriers may lack diversification.

    🏦 PE‑owned insurers may be more exposed to contagion.

    🛑 Guaranty‑fund caps may not cover the full receivable, or at all.

    The secondary market rarely prices these risks correctly.

    🔄 Case Study: Liberty → Lincoln → Protective → Resolution Life

    A real‑world example shows how structured‑settlement blocks migrate — and why investors must track the current risk‑bearing entity.

    1. Liberty Life Assurance Company of Boston (Original Issuer)

    Wrote structured‑settlement annuities for decades.

    2. Acquired by Lincoln Financial Group (2018)

    Lincoln purchased Liberty’s life and annuity business.

    3. Lincoln Reinsured the Block to Protective Life

    Protective became the reinsurer and took over customer service.

    4. Protective Ceded $9.7 Billion of Reserves to Resolution Life (2025)

    This included:

    • structured‑settlement annuities
    • secondary guaranteed universal life policies

    Protective retains administration, but Resolution Life now holds the economic exposure.

    Why Protective Did It

    💡 Reduce market risk 💡 Free up capital 💡 Support future acquisitions 💡 Strengthen core retail businesses

    Who Is Resolution Life?

    A global in‑force specialist managing closed blocks of life and annuity liabilities.

    Who Is Dai‑ichi Life Holdings?

    A major Japanese life‑insurance group and parent of Protective Life.

    📊 Structured‑Settlement Carrier Snapshot (Private‑Credit & Level 3 Exposure)

    All information in this section is drawn from public, regulator‑facing disclosures that every life insurer files, including statutory annual statements, NAIC investment schedules, SEC 10‑K filings (for public companies), and parent‑company asset‑management reports. The categories shown — such as private credit, Level 3 assets, and affiliated‑fund investments — reflect standard reporting classifications used across the industry. No inference of risk, instability, or concern is intended; the table simply summarizes information that insurers themselves report in their required filings.

    ACTIVE WRITERS (A–Z)

    • American General Life Insurance Company (Corebridge Financial)
    • Berkshire Hathaway Life Insurance Company of Nebraska
    • Independent Life Insurance Company
    • Metropolitan Life Insurance Company (MLIC)
    • Metropolitan Tower Life Insurance Company (MTL)
    • New York Life Insurance Company
    • Pacific Life Insurance Company
    • Prudential Insurance Company of America
    • Puritan Life Insurance Company of America
    • United of Omaha Life Insurance Company
    • USAA Life Insurance Company
    • United States Life Insurance Company in the City of New York (USLNY)

    Footnotes for Active Writers (Alphabetical, PE‑Contagion Context + Level 3 Exposure)

    American General Life Insurance Company (Corebridge Financial) Corebridge is the AIG life‑and‑retirement spin‑off. While still a balance‑sheet insurer, it has increased allocations to private‑credit strategies and uses reinsurance partners with private‑equity affiliations. Exposure is moderate but rising. Corebridge’s private‑credit allocations include Level 3 components.

    American National Insurance Company (ANICO) Entered the structured‑settlement market in Q2 2025 and is an active writer. A traditional balance‑sheet insurer with meaningful private‑credit exposure but no private‑equity ownership. American National carries higher Level 3 exposure than Athene, placing it structurally above Athene in contagion sensitivity.

    Athene Annuity and Life Company Active structured‑settlement writer with material relevance for private‑credit contagion mapping. Athene Annuity and Life Company is an active structured‑settlement writer and a major issuer of fixed and retirement annuities. As part of Apollo’s retirement‑services platform, AAALC operates within a balance‑sheet model deeply integrated with private‑credit origination, asset‑backed finance, and affiliated reinsurance structures. The company maintains significant Level 3 exposure, consistent with its alternative‑asset‑driven investment strategy. AAALC’s scale, investment profile, and reinsurance architecture make it a key node in any analysis of potential transmission pathways between private‑credit stress and the insurance sector.

    Berkshire Hathaway Life Insurance Company of Nebraska A balance‑sheet insurer with minimal private‑equity influence. Berkshire’s investment strategy is internally controlled and avoids PE‑style leverage. Low contagion exposure.

    Independent Life Insurance Company Privately owned by Independent Insurance Group and not private‑equity‑owned. Uses significant reinsurance but maintains a conservative investment posture and a structurally simple balance sheet. Active SS‑exclusive writer. Low contagion exposure.

    Metropolitan Life Insurance Company (MLIC) MetLife’s flagship life insurer and one of its two active structured‑settlement writers. MetLife is not PE‑owned. Certain blocks have been reinsured to Global Atlantic (Apollo‑owned), creating indirect PE adjacency. Contagion exposure is low‑to‑moderate. MetLife has indirect Level 3 adjacency through Global Atlantic.

    Metropolitan Tower Life Insurance Company (MTL) Second active structured‑settlement chassis within MetLife. Shares the same indirect PE adjacency through MetLife’s reinsurance with Global Atlantic. Contagion exposure is low‑to‑moderate. MetLife has indirect Level 3 adjacency through Global Atlantic.

    New York Life Insurance Company Mutual insurer with no private‑equity ownership or influence. Conservative investment posture and minimal reliance on external reinsurers. Low exposure.

    Pacific Life Insurance Company Balance‑sheet insurer with diversified investments. Some reinsurance relationships touch PE‑linked entities, but Pacific Life retains control of its structured‑settlement liabilities. Moderate exposure. Pacific Life maintains moderate Level 3 exposure tied to private‑credit allocations.

    Prudential Insurance Company of America Prudential has executed reinsurance transactions with Fortitude Re (Carlyle‑linked), creating indirect PE adjacency. Core operations remain balance‑sheet driven. Moderate exposure. Prudential has indirect Level 3 adjacency through Fortitude Re’s private‑credit portfolio.

    Puritan Life Insurance Company of America Privately held and not private‑equity‑owned. Conservative investment posture with limited external reinsurance activity. Puritan’s structured‑settlement business is modest in scale but internally controlled. Low contagion exposure.

    United of Omaha Life Insurance Company Mutual insurer with no private‑equity ownership. Conservative investment posture and minimal external reinsurance reliance. Low exposure.

    United States Life Insurance Company in the City of New York (USLNY) NY‑domiciled Corebridge affiliate. Shares Corebridge’s moderate private‑credit exposure due to group‑level investment strategy and reinsurance relationships. Corebridge’s private‑credit allocations include Level 3 components.

    USAA Life Insurance Company Member‑owned insurer with no private‑equity ownership. Conservative investment strategy and limited use of external reinsurers. Low exposure.

    🗂️Sources — Active Writers

    • American General Life Insurance Company (Corebridge Financial) Ownership and group structure sourced from Corebridge Financial public filings and AIG separation disclosures. Private‑credit allocations and affiliated‑reinsurance relationships referenced from Corebridge statutory filings and rating‑agency reports (AM Best, S&P). Level 3 exposure derived from Corebridge statutory annual statements (Fair Value Measurements note and investment schedules).
    • American National Insurance Company (ANICO) Brookfield Reinsurance completed its $5.1 billion all‑cash acquisition of American National on May 25, 2022, at $190 per share (Brookfield Reinsurance completion announcement; Insurance Business America transaction coverage). Private‑credit allocations and Level 3 exposure derived from American National statutory annual statements (Fair Value Measurements note, Schedule BA, and related investment schedules).
    • Athene Annuity and Life Company Ownership and private‑credit strategy sourced from Apollo Global Management and Athene public filings. Level 3 exposure derived from Athene statutory filings and GAAP fair‑value hierarchy disclosures.
    • Berkshire Hathaway Life Insurance Company of Nebraska Ownership and investment posture sourced from Berkshire Hathaway statutory filings and Berkshire Hathaway Inc. annual reports. “Actively paused” issuance posture based on market‑wide structured‑settlement activity and Berkshire’s selective‑issuance history. No material Level 3 exposure relevant to contagion mapping.
    • Independent Life Insurance Company Ownership and business model sourced from Independent Insurance Group disclosures. Reinsurance structure and investment posture derived from statutory filings. No material Level 3 exposure relevant to contagion mapping.
    • Metropolitan Life Insurance Company (MLIC) Ownership and group structure sourced from MetLife Inc. public filings. Reinsurance relationships with Global Atlantic (Apollo‑owned) sourced from MetLife disclosures and regulatory filings. Level 3 adjacency derived from Global Atlantic statutory filings and fair‑value hierarchy notes.
    • Metropolitan Tower Life Insurance Company (MTL) Same ownership and reinsurance context as MLIC. Level 3 adjacency derived from Global Atlantic statutory filings and fair‑value hierarchy notes.
    • New York Life Insurance Company Ownership and investment posture sourced from New York Life public filings and statutory statements. No material Level 3 exposure relevant to contagion mapping.
    • Pacific Life Insurance Company Ownership and investment posture sourced from Pacific Life public filings and statutory statements. Private‑credit allocations and Level 3 exposure derived from Pacific Life statutory filings (Fair Value Measurements note and investment schedules).
    • Prudential Insurance Company of America Reinsurance transactions with Fortitude Re (Carlyle‑linked) sourced from Prudential public filings and regulatory disclosures. Level 3 adjacency derived from Fortitude Re statutory filings and fair‑value hierarchy notes.
    • Puritan Life Insurance Company of America Ownership and investment posture sourced from Puritan Life statutory filings. No material Level 3 exposure relevant to contagion mapping.
    • United of Omaha Life Insurance Company Ownership and investment posture sourced from Mutual of Omaha public filings and statutory statements. No material Level 3 exposure relevant to contagion mapping.
    • United States Life Insurance Company in the City of New York (USLNY) Ownership and group structure sourced from Corebridge Financial disclosures. Private‑credit allocations and Level 3 exposure derived from Corebridge statutory filings.
    • USAA Life Insurance Company Ownership and investment posture sourced from USAA public filings and statutory statements. No material Level 3 exposure relevant to contagion mapping.

    🏷️ Legacy Structured‑Settlement Block Holders (Alphabetical Order)

    All information in this section is drawn from public regulatory filings, statutory annual statements, parent‑company disclosures, and rating‑agency reports. Legacy carriers listed here no longer write new structured‑settlement business but continue to administer or hold legacy obligations. No inference of risk or instability is intended; this section summarizes publicly reported ownership, runoff status, and block‑migration history.

    AIG Life Insurance Company (Legacy — Not Corebridge)

    AIG Life Insurance Company was the historical AIG entity that wrote structured‑settlement annuities. This entity is not part of Corebridge Financial and is distinct from American General Life (AGL), United States Life of New York (USLNY), and VALIC, which are the active Corebridge writers today. AIG Life exited the structured‑settlement market years ago. Its remaining long‑duration liabilities were transferred to Fortitude Re, a runoff specialist owned by Carlyle and T&D Holdings.

    Allstate Life Insurance Company / Allstate Life of New York → Everlake Life / Wilton Re

    Allstate exited the life and annuity business through two transactions:

    • Allstate Life Insurance Company (ALIC) was sold to Blackstone and renamed Everlake Life Insurance Company.
    • Allstate Life Insurance Company of New York (ALNY) was sold to Wilton Re, which now administers the New York structured‑settlement block. Both Everlake and Wilton Re operate in runoff.

    Amica Life Insurance Company

    Amica previously wrote structured settlements but exited the market. It continues to administer its small legacy block.

    CNA (Continental Casualty Company)

    CNA exited structured‑settlement issuance years ago. Its legacy obligations remain on the books and are administered internally.

    Everlake Life Insurance Company (formerly Allstate Life Insurance Company)

    Everlake is the renamed Allstate Life Insurance Company, acquired by Blackstone. It does not write new structured‑settlement business and administers the legacy Allstate block (excluding New York, which went to Wilton Re).

    Genworth Life Insurance Company

    Genworth exited the structured‑settlement market long ago. The company remains in runoff and continues to administer its legacy obligations.

    Hartford Life Insurance Company

    Hartford sold its annuity and life blocks to Talcott Resolution (now owned by Sixth Street). Hartford no longer writes structured settlements; Talcott administers the legacy obligations.

    John Hancock Life Insurance Company

    John Hancock exited the structured‑settlement market and continues to administer its legacy block internally.

    MassMutual

    MassMutual previously wrote structured settlements but exited the market. It continues to administer its legacy obligations.

    Prudential of Japan

    Prudential’s U.S. entities no longer write structured settlements. The Japanese subsidiary historically held certain structured‑settlement obligations; these remain in runoff.

    Symetra Life Insurance Company

    Symetra exited structured‑settlement issuance after its acquisition by Sumitomo Life. It continues to administer its legacy block.

    Travelers Life & Annuity

    Travelers exited the structured‑settlement market decades ago. Its obligations were assumed by MetLife as part of the Travelers acquisition.

    Wilton Re (Wilcac Life, Wilton Reassurance Life of New York, etc.)

    Wilton Re does not write new structured‑settlement business. It is a legacy block acquirer, specializing in assumption reinsurance and runoff. Wilton Re subsidiaries administer structured‑settlement blocks acquired from Allstate NY, Transamerica, and others. Wilton Re is owned by CPP Investments.

    📁 Legacy Sources

    Ownership, runoff status, and block‑migration history sourced from:

    • Statutory annual statements
    • NAIC filings
    • Parent‑company disclosures
    • Rating‑agency reports (AM Best, S&P, Fitch)
    • Public acquisition and assumption‑reinsurance announcements (Allstate → Everlake; Allstate NY → Wilton Re; AIG Life → Fortitude Re; Hartford → Talcott Resolution)

    🎯 What Readers Should Take Away

    Whether you’re an annuitant, attorney, planner, or receivables investor, the message is simple:

    • Know your carrier
    • Know their ownership
    • Know their exposure.

    Private credit isn’t inherently bad.

    But opacity, leverage, and long‑duration promises don’t mix well.

    This piece gives readers the context they need — without overwhelming them.

    Abstract highlights

    • Shows that life insurers have increased their lending in the private placement market over the past decade, totaling $849 billion, or 14%, on life insurers’ balance sheets in 2024. A substantial part of the growth stems from private credit extension to financial borrowers and to privately placed asset-backed securities.
    • Authors document that private equity-owned (PE-owned) life insurers drive these trends. Authors also provide evidence that these investments have about 80 basis points higher spreads compared to public bonds and foster PE-owned insurers’ growth in the annuities market.
    • A one standard deviation increase in financial private placement investments is associated with 0.05 percentage points higher market share in the annuities market.

    US life insurers head offshore as private credit upends industry from Moodys Special Report Three steps life insurers are taking to thrive in a changing industry June 2, 2025

    • Partnering with alternative asset managers: Seeking better investment returns than were available from public fixed income investments, insurers began to team up or merge with private equity firms (also called alternative asset managers).
    • Shedding unprofitable businesses: Life insurers free up capital and reduce tail risk by offloading capital intensive, non-core business.
    • Moving nearly $800 billion in reserves offshore to affiliates: Sending the largest share to Bermuda, life insurers stay competitive and keep profits in house. Additionally, they have grown their own investment capabilities.
    • Why it matters: The new business model has thrived, but risks may surface due to lack of transparency and exposure to counterparty risk.

    Last updated March 26, 2026







  • By John Darer® CLU ChFC MSSC CeFT RSP CLTC

    No. New York’s pension and annuity exclusion under NY Tax Law §612(c)(3‑a) applies only to qualified pension and annuity income. Structured attorney fees are non‑qualified deferred compensation, not employee‑based retirement income, and therefore do not qualify. This interpretation has remained consistent since TSB‑M‑81(19)R(1) (NYS Dept. of Taxation, 1982).

    🎂 Age Requirement

    The taxpayer must be 59½ or older during the tax year.

    💵 Amount of Exclusion

    The exclusion remains $20,000 per taxpayer. A 2025–2026 bill proposing an increase to $30,000 was stricken and did not become law.

    🧾 Federal AGI Requirement

    The income must be included in federal AGI before it can be subtracted on the New York return.

    📘 What Qualifies as Pension & Annuity Income

    New York allows the exclusion for:

    • periodic payments for services performed as an employee before retirement (NY Tax Law §612(c)(3‑a));
    • traditional IRA distributions included in federal AGI;
    • 401(k), 403(b), and 457(b) plan distributions;
    • Keogh (HR‑10) plan distributions;
    • employer‑purchased annuity contracts.

    These categories align with federal definitions of qualified plan distributions, which in 2026 follow updated IRC §415 limits (e.g., defined benefit limit $290,000; defined contribution limit $72,000; elective deferral limit $24,500; catch‑up $8,000) .

    🚫 What Does NOT Qualify

    structured attorney fees;

    non‑qualified annuities purchased personally;

    payments derived from contributions made after retirement;

    Roth IRA qualified distributions (not included in AGI);

    A structured attorney fee is:

    • self‑employment income, not employee wages;
    • non‑qualified deferred compensation, not a pension;
    • not paid from a qualified plan under IRC §§401–408;
    • not employer‑funded;
    • taxable when received, but still ordinary income.

    New York’s exclusion applies only to employee‑based retirement income, and the Department of Taxation has never expanded the definition to include structured fees. The controlling interpretation remains TSB‑M‑81(19)R(1).

    A structured attorney fee is a non‑qualified deferred compensation arrangement in which a lawyer elects to receive contingent fees over time. Key features include:

    • the election must occur before settlement is finalized;
    • payments must be part of the settlement agreement;
    • funding is typically through a qualified assignment;
    • payments are taxable when received, not when earned;
    • the arrangement is not ERISA, not a pension, and not a qualified plan.

    Structured fees are useful for cash‑flow smoothing and tax‑timing, but they do not convert into “pension income” under New York law.

    Several companies offer alternative attorney‑fee deferral programs, including market‑based deferrals, trust‑based structures, and non‑annuity assignment arrangements. Programs such as Jurisprudent and OptCapital fall into this category. While these platforms differ in how deferred fees are invested or administered, New York treats all of them the same way for tax purposes. They are all non‑qualified deferred compensation, not employer‑sponsored retirement plans, and therefore do not qualify for New York’s $20,000 pension and annuity exclusion (NY Tax Law §612(c)(3‑a); TSB‑M‑81(19)R(1)). The branding, investment strategy, or platform used does not convert attorney fees into “pension income” under New York law.

    💬 Can a New York attorney structure fees if the funds are already in an IOLTA account?

    No. Constructive receipt has occurred; deferral is no longer possible.

    💬 Can a New York partnership deduct structured fees paid to partners?

    No. Payments to partners are treated as distributive share or guaranteed payments.

    💬 Can a sole proprietor deduct structured fees paid to themselves?

    No. You cannot deduct payments to yourself.

    💬 Are structured attorney fees subject to ERISA?

    No. They are non‑qualified arrangements.

    💬 Are structured attorney fees “pension plans”?

    No. They do not meet the definition of a qualified pension, annuity, or retirement plan under federal or New York law.

    Retired New York lawyers cannot use the $20,000 pension and annuity exclusion for structured attorney fee income. The exclusion remains limited to qualified retirement income, and structured fees remain ordinary income when received, regardless of age or payment form.

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