Public Policy Comments and Letters

Financial Regulatory Task Force comments to the U.S. Senate on S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act. (January 17, 2018)
Big Data Task Force comments to the NAIC's Big Data (EX) Working Group on recent exposures.  (January 12, 2018)
Role of the Actuary Subgroup Amendment Proposal Form to the NAIC Life Actuarial (A) Task Force on the definition of Actuarial Opinion.  (January 11, 2018)
Non-Guaranteed Elements Work Group comment letter to the NAIC's Life Insurance Buyer's Guide (A) Working Group on the CEJ Expanded Outline Exposure Draft. (January 3, 2018)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed updates to market risk benefits in the accounting for long-duration contracts. (December 18, 2017)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed updates to the accounting for long-duration contracts. (December 15, 2017)
Non-Guaranteed Elements Work Group Comment Letter to NAIC Life Insurance Buyer's Guide (A) Working Group on "10 Things You Should Know Before Purchasing Life Insurance" exposure draft.  (December 14, 2017)
Health Practice Council comments to the U.S. House and Senate on the potential inclusion of individual mandate repeal in The Tax Cuts and Jobs Act. (December 12, 2017)
Life Practice Council comment letter to NAIC Financial Condition (E) Committee raising concerns over the process by which the NAIC is developing changes to the statutory framework for variable annuities (VAs), including both C-3 Phase II for risk-based capital (RBC) and Actuarial Guideline (AG) 43 reserve requirements. (November 28, 2017)
Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2019 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, special enrollment periods, essential health benefits, minimum essential coverage, and medical loss ratios.
(November 27, 2017)
Health Practice Council comments to the U.S. Senate on a proposal in the Tax Cuts and Jobs Act to eliminate the ACA's individual mandate. (November 21, 2017)
Multiemployer Plans Committee comments to the Pension Benefit Guaranty Corporation (PBGC) on modifications to the instructions for the 2017 Schedule MB (Multiemployer Defined Benefit Plan Actuarial Information) of the Form 5500.
(November 20, 2017)
Casualty Practice Council letter to the U. S. House of Representatives on pending flood insurance legislation. (November 8, 2017)
Health Practice Council comments on the October 12 executive order. (November 7, 2017)
Life Reinsurance Work Group comment letter to the NAIC’s Life Actuarial (A) Task Force on yearly renewable term reinsurance premiums under Section 20 of the Valuation Manual.  (November 7, 2017)
The Life Products Committee comment letter to the Actuarial Standards Board regarding a proposed actuarial standard of practice (ASOP) on pricing of life insurance and annuity products. 
(October 31, 2017)
Pension Committee comments to the AICPA Employee Benefit Expert Panel on the current ASC 960 reporting standards for defined benefit pension plans. (October 27, 2017)
Pension Practice Council comment letter to Missouri State Employees’ Retirement System Board on the newly-adopted Terminated-Vested Member Buyout Program.
(October 23, 2017)
Non-Guaranteed Elements Work Group comment letter on the NAIC’s Life Insurance Buyer’s Guide (A) Working Group discussion draft. (October 19, 2017)
Non-Guaranteed Elements Work Group comment letter on the NAIC’s Life Insurance Buyer’s Guide (A) Working Group discussion draft. (October 19, 2017)