Colorado Bankers Life Liquidation: Annuity Money Above the Cap

What older pages get wrong

Search results for this company are mostly scraped company profiles that still describe an active insurer, or older notices written before the liquidation took effect. The primary documents say four different things.

1. It is not in rehabilitation any more. The 2019 rehabilitation ended when the liquidation order became effective on November 30, 2024. A February 13, 2023 FAQ on the Department’s site still said the companies “remain in rehabilitation”; that was true then.
2. The effective date is November 30, 2024, not 2022 and not June 2024. The order was signed on December 30, 2022. The Department’s March 5, 2024 press release, after the Court of Appeals ruling, said the order would become effective on June 30, 2024. The North Carolina Supreme Court resolved the parent company’s appeals on August 23, 2024, according to the Connecticut Insurance Department, and the effective date became November 30, 2024.
3. Guaranty coverage already started. Coverage by state guaranty associations is “determined by the state life and health insurance guaranty association, not the Liquidator”, and the associations were activated on November 30, 2024. The covered policies moved to Continental General on January 1, 2026.
4. The uncovered part is a separate, frozen estate claim. It is administered by the Liquidator, through a separate Company portal, and cannot be withdrawn, surrendered or annuitized while the moratorium stands.

The case is the Commissioner of Insurance of North Carolina against Southland National Insurance Corporation, Southland National Reinsurance Corporation, Bankers Life Insurance Company and Colorado Bankers Life Insurance Company, Wake County Superior Court, 19 CVS 008664-910. Bankers Life Insurance Company (BLIC) was liquidated by the same order. Southland National Insurance Corporation, the sister company, was liquidated separately on May 2, 2023.

Timeline from the court and Department documents

What the guaranty association covers, and what is left

Each state, the District of Columbia and Puerto Rico has a life and health insurance guaranty association. NOLHGA, the national organization that coordinates them, wrote an FAQ for this liquidation (dated September 10, 2024). Its Q12 gives the common limits, and its Q15 gives a worked example.

NOLHGA’s own example: an annuity worth $400,000 when the order became effective, in a state with a $250,000 limit, leaves $150,000 uncovered, which “likely would be a claim against the insolvency estate.” In North Carolina, whose limit is $300,000 for all benefits on one life, the same contract would leave $100,000 uncovered (our arithmetic, using the North Carolina figure in our state guaranty limits table). Limits differ by state, so look up yours there or on the NOLHGA site.

Three details change the arithmetic. First, the limit applies to present value on the date the order became effective, not to what you paid. Second, if you hold an annuity and a life policy at CBL, in most states the combined cap is $300,000. Third, benefits CBL paid before liquidation (for example under the earlier partial-withdrawal programs) “do not count against the Guaranty Association’s statutory coverage limits but will be applied in determining the remaining benefits available under the policy,” according to the Receiver’s report.

What you can and cannot do now

The estate behind the uncovered claims

The Receiver files a quarterly report with the Wake County court. The newest one on the Department’s CBL page on November 9, 2026 is the amended report as of September 30, 2025, filed on July 24, 2026. Its financial statements are unaudited and use the liquidation basis of accounting.

What the table shows, in our arithmetic: the Class 1 and 2 lines add up to about $1.565 billion, and assets of $603.7 million are 38.6% of that. The policyholder line is $120.6 million, 7.7% of the Class 1 and 2 total. The guaranty associations’ claim is $1.27 billion, because they step into the shoes of the policyholders they pay. The November 21, 2024 order says policyholders’ uncovered claims, the associations’ subrogation claims and the associations’ reasonable administrative expenses “are all class two claims” and must be paid “on a prorata basis”, with no subcategories. So one percentage would apply to all of them. We do not turn the 38.6% into a forecast, because the report does not do so: the claims of the associations will move as they pay benefits, the order contemplates a fixed ceiling on the associations’ administrative expense that had not been reported as agreed, and the assets do not yet include any collection of the January 2026 judgment.

One more number we could not reconcile. The report’s schedule of affiliated investments shows an actual cost of $952,914,205 and a book carrying value of $891,689,762 at both June 30 and September 30, 2025, mostly loans to companies affiliated with the former parent. The balance sheet has no line of that size, and the report does not explain how the schedule ties to it. The report also records that the revolving line of credit to Academy Financial Assets, with principal and capitalized interest of $39.9 million, matured on June 27, 2020 and is in default; CBL holds a January 2022 federal judgment for the full balance.

Litigation that could add to the estate (company parties only)

A related item in the same report: on August 6, 2025 the court entered a consent order on distributing the proceeds of a sale of the Clanwilliam companies to the federal Special Master handling restitution, to be paid to identified victims “including the Plaintiffs’ uncovered policyholders”. The report gives no amount. Where the money from these cases lands, and when, is not stated.

The November 30, 2026 bar date

The Notice to Potential Claimants says any claim against CBL, its assets or the Liquidator must be brought as a proof of claim “no later than November 30, 2026.” It lists litigants with suits pending against CBL, anyone who asserted a written claim during the rehabilitation, anyone with a potential claim not yet asserted, and unpaid tax authorities. The separate Notice of Liquidation says the Liquidator is “NOT requiring policyholders claiming cash surrender values or other investment values in life insurance and annuities to file a proof of claim.” The notice adds that “health insurance and Death benefit claims will be paid in the normal course to the extent covered by a state life and health insurance guaranty association.” If you are unsure whether your claim is a plain policy claim, ask the Special Deputy Liquidator in writing before the date: the address is in the notices (207 W. Millbrook Road, Suite 210, #323, Raleigh, North Carolina 27609).

What a reader can do with this

This is analysis of public documents, not investment, legal or tax advice.

1. Split your balance into covered and uncovered. Take your account value at November 30, 2024, the limit of the state where you lived that day, and the combined cap if you also hold life insurance at CBL. The difference is your exposure to the estate. Our guaranty limits table lists the limit by state.
2. Find out which portal holds which part. The covered part is administered through the guaranty association process; the uncovered part sits in the Company portal run for the Liquidator. NOLHGA says to expect separate notices.
3. Keep every statement and notice. Your claim was fixed as of November 30, 2024. Account statements from that date and any pre-liquidation partial-withdrawal payments are the evidence of the remaining claim.
4. Check the tax side before any surrender of the covered part. A surrender or exchange of the covered portion can have tax consequences, as NOLHGA says. Our pages on deferred annuity taxation and inherited annuities explain the rules.
5. Mark November 30, 2026 if you have any claim that is not a plain policy-value claim, and watch for the next quarterly report and any notice of a court-ordered pro rata distribution, which the Liquidator says it will announce.

For what advisers charge for this kind of review, see what a financial advisor costs for real estate investors.

FAQ

Sources, read on November 9, 2026: North Carolina Department of Insurance, Estates Under Administration page and the CBL documents posted there (Policyholder Liquidation Notice, Liquidation Notice to Potential Claimants, Informational Notice, Publication Notice, Liquidation FAQs of January 15, 2025, CBL and BLIC FAQs updated February 13, 2023); Order Granting Joint Motion for Moratorium on Uncovered Policy Obligations During Liquidation, Wake County Superior Court, 19 CVS 008664-910, signed November 21, 2024; Receiver’s Quarterly Reports as of June 30, 2025 and (amended) September 30, 2025; NOLHGA, CBL and BLIC Frequently Asked Questions, September 10, 2024; NCDOI press release of March 5, 2024; Connecticut Insurance Department, Colorado Bankers Life Insurance Company page; Coverager, “Continental General assumes 91,000 policies from Guaranty Associations” (reporting the company’s February 12, 2026 announcement). The liquidation order itself is a scanned image and was not machine-readable; its dates are taken from the Department’s notices.