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May 2, 2026

ICOLI Peer Review Analysis

Common sense wins. Strong balance sheets do not happen by accident. And in this business, the future belongs to the institutions that fund tomorrow’s promises before those promises come due.

When you review the top U.S. life insurance carriers, one truth stands out quickly: the strongest players do not treat Insurance Company Owned Life Insurance (ICOLI) as an afterthought. They use it as a strategic balance-sheet asset. At Schiff Executive Benefits, that is exactly the lens we bring to every review. We reverse engineer goals, measure available capacity, and help leadership teams make decisions that restore alignment and retention.

Executive Summary

Analysis of Insurance Company Owned Life Insurance (ICOLI) holdings for the top 50 U.S. life insurance carriers. Focus: comparing admitted ICOLI assets against statutory surplus to identify industry benchmarks and individual carrier purchase capacity.

This report is designed for a peer review setting. It is formal in structure, practical in tone, and built to support executive discussion. The central question is simple: how are leading carriers using ICOLI to support long-term executive liabilities and non-qualified plan obligations while maintaining strong capital positions?

The answer matters. If the institutions that manufacture and distribute life insurance are also deploying it as a strategic internal asset, that is not coincidence. That is a benchmark.

Professional executive desk with financial reports illustrating strategic ICOLI utilization and corporate benefit planning.

Report Scope and Benchmark Framework

This analysis compares admitted ICOLI assets to statutory surplus across the top 50 U.S. life insurance carriers. The purpose is twofold:

  • Identify where leading carriers currently sit on the ICOLI utilization curve
  • Highlight potential additional purchase capacity based on peer positioning
  • Provide a practical reference point for executive benefit funding discussions
  • Frame ICOLI as a strategic tool rather than a passive holding

In plain English, this is about more than rankings. It is about capacity. It is about solvency. And it is about whether a carrier is using one of the most efficient balance-sheet tools available to support long-duration obligations.

Full Comparison Data Table: Top 50 U.S. Life Insurance Carriers

Carrier ICOLI Admitted / Estimated Holdings Peer Review Observation
Prudential Peer review benchmarked Major carrier; benchmark participant in admitted ICOLI to surplus comparison
New York Life $4.6 Billion One of the clear industry leaders in admitted ICOLI holdings
MetLife $4.1 Billion Top-tier benchmark carrier with substantial admitted ICOLI deployment
MassMutual $3.0 Billion Leading mutual carrier with meaningful ICOLI position
Northwestern Mutual Peer review benchmarked Large mutual benchmark; strong relevance for comparative capacity review
TIAA Peer review benchmarked Significant institutional benchmark participant
Corebridge Peer review benchmarked Relevant large-carrier comparison point for executive liability funding
Lincoln Peer review benchmarked Established benchmark carrier in the non-qualified funding conversation
Athene Peer review benchmarked Active participant in large-carrier capital efficiency comparisons
Jackson Peer review benchmarked Useful benchmark for admitted asset utilization review
Manulife Peer review benchmarked Large-scale peer reference point
Equitable Peer review benchmarked Relevant benchmark for executive benefit funding strategy
Nationwide Peer review benchmarked Large diversified participant in peer analysis
Principal Peer review benchmarked Strong comparative relevance for non-qualified liability funding
Brighthouse Peer review benchmarked Included as part of top-carrier benchmarking set
Pacific Life Peer review benchmarked Major life carrier and useful peer capacity reference
Transamerica Peer review benchmarked Included in admitted ICOLI benchmark analysis
Allianz Peer review benchmarked Large institutional comparison point
Great-West Peer review benchmarked Relevant strategic funding benchmark
Global Atlantic Peer review benchmarked Included in peer review universe
Voya Peer review benchmarked Useful benchmark for executive liability funding discussions
Sammons Peer review benchmarked Included in top-carrier comparison set
Thrivent Peer review benchmarked Mutual benchmark participant
Talcott Peer review benchmarked Included in comparative review
Ameriprise Peer review benchmarked Relevant participant in peer benchmark data set
State Farm Peer review benchmarked Significant carrier included for industry comparison
Guardian Peer review benchmarked Important mutual benchmark reference
Protective Peer review benchmarked Included in comparative capacity review
Western & Southern Peer review benchmarked Relevant participant in the top-50 peer group
Securian Peer review benchmarked Included in executive liability funding comparison
American Family Peer review benchmarked Top-50 benchmark participant
Mutual of Omaha Peer review benchmarked Material benchmark reference for admitted holdings review
Cigna Peer review benchmarked Included in broader peer analysis
Aetna Peer review benchmarked Included in comparative review framework
Unum Peer review benchmarked Relevant top-50 benchmark participant
AFLAC Peer review benchmarked Included in carrier peer group analysis
Humana Peer review benchmarked Included in broad comparative benchmark
UnitedHealthcare Peer review benchmarked Large-scale comparison point within review set
F&G Peer review benchmarked Included in peer review benchmark
Genworth Peer review benchmarked Included in carrier comparison set
Ohio National Peer review benchmarked Relevant benchmark participant
National Life Group ~$615 Million Meaningful existing holdings with visible room for strategic expansion
Ameritas Peer review benchmarked Capacity identified for an additional $400 Million purchase
Kansas City Life Peer review benchmarked Included in comparative review
Horace Mann Peer review benchmarked Included in top-50 benchmark set
Primerica Peer review benchmarked Included in broad carrier comparison
Penn Mutual Peer review benchmarked Mutual benchmark participant
Midland National Peer review benchmarked Included in peer capacity review
Security Benefit Peer review benchmarked Included in top-carrier analysis
Southern Farm Bureau Peer review benchmarked Included in final comparison set

Strategic Insights

The market leaders are not using ICOLI casually. They are using it deliberately to fund long-term executive liabilities, support deferred compensation obligations, and create a more efficient funding mechanism for non-qualified plans. That matters because executive benefit promises are easy to make in a good year. Funding them responsibly over time is the real discipline.

What makes ICOLI especially attractive in the carrier environment?

  • Balance-sheet efficiency: ICOLI can help offset long-duration executive obligations with a purpose-built asset.
  • 0% RBC charge: Under applicable treatment, ICOLI can offer highly favorable capital treatment, which is a major reason sophisticated carriers continue to use it.
  • Tax-advantaged growth: Policy cash value growth improves internal asset efficiency versus many taxable alternatives.
  • Death benefit recovery: The life insurance chassis provides long-term cost recovery that supports employer economics.
  • Plan funding flexibility: ICOLI works especially well when paired with non-qualified deferred compensation, supplemental executive retirement plans, and other targeted retention designs.

This is where the Schiff Method matters. We do not start with a product. We start with the goal. Then we reverse engineer the structure around the liability, the timeline, the culture, and the economics. That is how you build a plan that is not only technically sound, but also practical inside a real company with real people and real constraints.

If you are reviewing admitted ICOLI relative to surplus, you are really asking a sharper question: how much strategic capacity remains before a carrier reaches its own comfort threshold? That is the kind of question that keeps a peer review meeting productive.

Selected Carrier Commentary

New York Life

At $4.6 Billion in admitted ICOLI, New York Life stands out as one of the clearest industry benchmarks. Size alone does not tell the story. What matters is what that size signals: long-term confidence in ICOLI as a funding vehicle for executive liabilities and institutional promises.

MetLife

At $4.1 Billion, MetLife reflects the same disciplined use of ICOLI as a strategic balance-sheet asset. This is not window dressing. This is infrastructure.

MassMutual

At $3.0 Billion, MassMutual remains firmly in the top tier. The carrier’s position reinforces the broader takeaway that large, well-capitalized institutions continue to rely on ICOLI where efficiency and long-term liability management matter.

National Life Group

With approximately $615 Million in holdings, National Life Group shows meaningful participation while still leaving visible room for expansion relative to likely peer capacity bands.

Ameritas

Ameritas is especially notable from a peer review standpoint because our analysis indicates capacity for an additional $400 Million purchase. That does not mean a carrier should buy simply because it can. It means there is room to evaluate whether strategic underutilization is leaving value on the table.

Why This Matters Beyond the Carrier Space

Even though this report focuses on insurance carriers, the lesson travels well. The same core logic applies when corporations and partnerships use COLI to attract, retain, and reward key talent, fund non-qualified obligations, and prepare for the business “What Ifs” that can hit without warning.

That is why the peer review process is valuable. It turns abstract strategy into measurable comparison. It helps answer questions like:

  • Are we underutilizing a highly efficient funding tool?
  • Are we carrying long-term executive liabilities without a matching asset?
  • Are we solving retention problems in a cost-effective way?
  • Are we planning for replacement cost, retirement income, or ownership transition before the point of no return?

For leaders thinking bigger about non-qualified benefit design, The Perfect Plan® conversation is always about alignment first. Strategy second. Product last.

Conclusion

ICOLI continues to be a primary strategic vehicle for cost-effectively managing executive benefits and non-qualified liabilities across the life insurance sector.

That is the big takeaway from this peer review analysis. The strongest carriers continue to use ICOLI because it works. It supports long-term promises. It helps preserve capital efficiency. And it gives leadership teams a disciplined way to fund obligations before those obligations become pressure points.

If you want to evaluate how these same planning principles translate into executive benefit strategy, non-qualified design, or COLI implementation, we would be glad to walk through it with you. You can also explore more insights on our posts page or join us at The Perfect Plan®.

Restoring Alignment and Retention.