Casualty Comments and Letters

Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force exposure draft containing potential changes to the P/C Statement of Actuarial Opinion Instructions to address the CASTF’s “Attestation” charge. (May 11, 2018)
Comment letter from  Senior Casualty Fellow Kevin Ryan to the International Association of Insurance Supervisors on climate change risks to the insurance sector. (April 27, 2018)
Workers’ Compensation Committee discussion of comparisons between states of workers’ comp rates. (March 16, 2018)
Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force’s (CASTF) exposure draft on the appointed actuary’s public attestation and supporting confidential documentation. (March 7, 2018)
Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force’s (CASTF) request for comments on the three-year experience period—seeking proposals. (March 7, 2018)
COPLFR letter to the NAIC's Casualty Actuarial and Statistical Task Force, with survey findings regarding reports for currency conversion and intercompany quotashare pooling. (February 15, 2018)
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)