Public Policy Comments and Letters

Committee comments on a proposed rule that would lengthen the maximum period of short-term, limited-duration (STLD) insurance through amending the definition of STLD. (April 6, 2018)
Non-Guaranteed Elements Work Group comment letter on the NAIC March 19 draft life insurance buyer's guide.  (April 4, 2018)
Life Experience Committee presentation to NAIC on analysis and comparison of reserves for Guaranteed Issue (GI) plans.  (March 22, 2018)
Financial Reporting Committee questions for consideration by the IFRS Transition Resource Group on IFRS 17 Insurance Contracts. (March 22, 2018)
Life Experience Committee letter to NAIC responding to ACLI comment on accelerated underwriting data elements.  (March 20, 2018)
Workers’ Compensation Committee discussion of comparisons between states of workers’ comp rates. (March 16, 2018)
RBC Tax Reform Work Group comment letter to NAIC on changes to Life Risk-Based Capiutal calculations as a result of tax reform.  (March 16, 2018)
Multiemployer Plans Committee letter to the Joint Select Committee on Solvency of Multiemployer Pension Plans offering the expertise of the Multiemployer Plans Committee as a resource to the Joint Select Committee. (March 12, 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)
Committee comments on the definition of ‘‘Employer’’ under section 3(5) of ERISA—Association Health Plans. (March 5, 2018)
Health Practice Council comments to the Idaho Department of Insurance on allowing health insurers to offer state-based plans that are not compliant with the Affordable Care Act in Idaho. (March 2, 2018)
AG43/C3P2 Work Group comment letter to NAIC on proposed modifications to Actuarial Guideline XLIII and C-3 Phase II. (March 2, 2018)
ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers second exposure draft. (March 1, 2018)
Life Reserves Work Group APF to the NAIC Life Actuarial (A) Task Force regarding changes to VM-20 on aggregation of mortality segments for the purpose of determining credibility.  (February 21, 2018)
Tax Work Group comment letter to the NAIC’s Statutory Accounting Principles (E) Working Group on federal income tax reform. 
(February 16, 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)
C1 Work Group comment letter to the NAIC’s Investment Risk-Based Capital (E) Working Group on proposed risk based capital C1 factors for corporate bonds. 
(February 14, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Interim Consultation Paper on Activities-Based Approach (ABA) to Systemic Risk dated December 8, 2017. (February 13, 2018)
Committee comments to Office of Regulations and Interpretations within the Employee Benefits Security Administration in response to the Department of Labor's proposed rule on the definition of employer—small business health plans. (February 9, 2018)