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Few points here: Full disclosure, I do not work for Athene or hold any of their equity.
-For context, absolutely no insurance company targets 100% of Company Action Level (CAL). It just doesn’t happen and anyone who did would not write a cent of premium. If you look at the broad life and annuity market the minimum RBC target for respectable companies is roughly 350% with A and higher rated companies targeting 400% RBC.
-Yes the 35Bn sits across AAIA and the various other US and Bermuda entities. That said, Iowa is the the Group Regulator for the Athene Group and has line of sight into the Bermuda companies and has a regulatory college with the BMA. The holding company has a Capital Maintenance agreement with AAIA, and their other US subsidiaries to keep them capitalized to a given level. So even though some of the capital is offshore, it’s overseen by the Iowa regulatory authority specifically.
-The mechanics of the reinsurance treaty matter here as well. These are typically modified coinsurance arrangements in which the assets reside on the direct writer’s balance sheet in a custodial account. This is generally preferred for ceding companies as they have more line of sight on the assets (it’s their balance sheet) and they retain impairment rights on those assets (this matters more for true third party reinsurance but the point remains).
-In the event of statutory losses (from adverse reserve development or asset underperformance or default) these accounts would need to be topped up to the statutory value of the ceded reserves (it’s essentially a maintenance margin for reinsurance arrangements) via a settlement process.
-Therefore in the scenario you mentioned in which actual impairment (not Mark to Market paper losses on Bonds and other Fixed Income assets), the Bermuda companies would be obligated to fund the deficits caused by those losses on a monthly basis. This is how essentially any life or annuity reinsurance treaty would work.
-All told, the question of the specifics is a fair one but the facts don’t justify citing a 70x leverage number because there is no legal way for the Bermuda capital to be used for anything other than funding losses in the reinsurance arrangements (due to group supervision, dividend restrictions and capital maintenance agreements).
Since you’re concerned about the level of disclosure in Bermuda, I’ve linked to their Bermuda groups Financial Condition Report, which has some helpful data.
Regarding disclosure, the BMA is requiring companies to provide the same details on assets and liabilities that US Statutory Filers are required to submit as well. This is going live in 2026 based on the Year End 2025 financial position of Bermuda companies.