Casualty Comments and Letters

Casualty Practice Council letter to the U. S. House of Representatives on pending flood insurance legislation. (November 8, 2017)
Committee on Property and Liability Financial Reporting comment letter to NAIC's Actuarial Opinion Working Group on the impact of life insurance Valuation Manual changes on P/C insurers' Statements of Actuarial Opinion that include accident and health (A&H) and long-term care (LTC) lines of business. (October 18, 2017)
The Committee on Property and Liability Financial Reporting’s comment letter to the NAIC’s Statutory Accounting Working Group, questioning the proposed new definition of reinsurance risk transfer in SSAP No. 62R: Property and Casualty Reinsurance. (October 4, 2017)
Casualty Practice Council comment letter to members of the U.S. House of Representatives urging reauthorization and revision of the National Flood Insurance Program. (August 30, 2017)
Casualty Practice Council comment letter to the U.S. Senate Committee on Banking, Housing, and Urban Affairs urging reauthorization and revision of the National Flood Insurance Program. (August 23, 2017)
Comment letter submitted jointly by the P/C RBC Committee and the Health Solvency Subcommittee regarding changes to corporate bond factors being considered by the NAIC’s Investment Risk-Based Capital Working Group. (July 25, 2017)
COPLFR's comment letter to the NAIC's Title Insurance Financial Reporting Working Group regarding proposed changes to reporting of reserves in the title statement of actuarial opinion (July 14, 2017)
Casualty Practice Council comments on the ASB's third exposure of the proposed Actuarial Standards of Practice (ASOP), Estimating Future Costs for Prospective Property/Casualty Risk Transfer and Risk Funding. (April 27, 2017)
Workers' Compensation Committee comment letter to California's Offfice of Self-Insured Plans regarding guidance on actuarial reports on self-insured workers' compensation plans. (March 30, 2017)
Joint Property and Casualty Risk-Based Capital Committee and Health Solvency Subcommittee letter to the NAIC's Operational Risk Subgroup on proposed changes to the operational risk factor in risk-based capital (RBC) formulas for property/casualty and health. (December 19, 2016)
Casualty Practice Council (CPC)  and Committee on Property and Liability Financial Reporting (COPFLR) letter to the Actuarial Standards Board commenting on the third exposure draft for the proposed Actuarial Standard of Practice (ASOP) on modeling. (October 14, 2016)
Financial Reporting Committee (FRC) and Committee on Property and Liability Financial Reporting (COPLFR) comments to the SEC on its concept release on the modernization of certain disclosure requirements in Regulation S-K. (July 21, 2016)
Comment letter from the Committee on Property and Liability Financial Reporting (COPLFR) to the NAIC noting inconsistencies in the instructions for certification of loss reserves for international insurers. (July 7, 2016)
Casualty Practice Council and P/C Extreme Events Committee letter to U.S. Senate Banking, Housing and Urban Affairs Committee on HR 2901, The Flood Insurance Market Parity and Modernization Act, concerning an expanded role for private insurers in the flood insurance marketplace. (May 25, 2016)
Solvency Committee comments to the NAIC's Investment Risk-Based Capital (E) Working Group on its "Way Forward" exposure document. (May 19, 2016)
Casualty Practice Council and P/C Extreme Events Committee letter to U.S. House of Representatives on HR 2901, The Flood Insurance Market Parity and Modernization Act, concerning an expanded role for private insurers in the flood insurance marketplace. (April 26, 2016)
Casualty Practice Council comments on the Actuarial Standards Board's (ASB) second exposure draft of the proposed actuarial standards of practice for Property/Casualty Ratemaking. (April 21, 2016)
Comments to the NAIC executive committee by the Price Optimization Task Force on changes made to the proposed Price Optimization White Paper. (March 15, 2016)
Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC’s Actuarial Opinion (C) Working Group on the Actuarial Opinion Instructions. (February 12, 2016)
Senior Property/Casualty Fellow Jim MacGinnitie comments to the NAIC/IAIABC Joint (C) Working Group on the 2015 Workers’ Compensation Large Deductible Study draft. (February 5, 2016)