Public Policy Comments and Letters

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) public consultation document dated July 31, 2018. (October 19, 2018)
Subcommittee comments on the impact on Health Risk-Based Capital (HRBC) from the Tax Cuts and Jobs Act of 2017 (TCJA). (October 18, 2018)
Annuity Illustration Work Group comment letter to NAIC on proposed changes to Annuity Disclosure Model Regulation #245.  (October 18, 2018)
Life Reserves Work Group revised amendment proposal form on selection of the industry basic table when company experience mortality rates are higher than the industry basic table. (October 3, 2018)
Multiemployer Plans Committee follow-up letter to the Joint Select Committee on Solvency of Multiemployer Pension Plans on key topics discussed during June 22 meeting regarding loan proposals and other solutions for troubled multiemployer pension plans.  (September 26, 2018)
Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on its Scope and Non-Insurance Testing Exposed with Questions document. (September 20, 2018)
Big Data Task Force comments to the  U.S. Senate Committee on Banking, Housing, and Urban Affairs  on their hearing, Fintech: Examining Digitization, Data, and Technology. (September 17, 2018)
Committee and Subcommittee comments on the Centers for Medicare and Medicaid Services’ (CMS) and Department of Health and Human Services’ (HHS) Aug. 10 proposed rule regarding the adoption of methodology for the HHS-operated permanent risk adjustment program. (September 5, 2018)
ERM/ORSA Committee comments to the NAIC’s Financial Regulation Standards and Accreditation (F) Committee on the ORSA Review Timelines exposure. (September 5, 2018)
Life Illustrations Work Group comment letter to NAIC on draft changes to Model #582.  (August 31, 2018)
Macroprudential Task Force comment letter to NAIC on the exposed scope for liquidity stress testing.  (August 31, 2018)
Life and Health Valuation Law Manual Task Force comment letter to Life Actuarial (A) Task Force on recommendations to changes for the 2019 Life and Health Valuation Law Manual.  (August 16, 2018)
Committee on Property and Liability Financial Reporting letter offering comments on the California Department of Insurance’s proposed changes to reporting requirements for large deductibles in workers’ compensation plans. (August 10, 2018)
Academy Past President Mary D. Miller on Friday submitted a comment letter from the Academy to the NAIC regarding the Casualty Actuarial and Statistical Task Force’s exposure draft related to the three-year experience requirement to sign statutory statements. In those comments Miller shared the Academy’s view that the exposure draft describes an approach that will neither clarify nor improve the current requirement. (August 10, 2018)
Notes from the Multiemployer Plans Committee meeting on Feb. 23, 2018 with officials of the Treasury and Labor departments, and Pension Benefit Guaranty Corporation to discuss applications by multiemployer pension plans in critical and declining status to suspend benefits or partition liabilities. This meeting supplements the first meeting between these parties on this topic, which was held on Feb. 22, 2017. (July 31, 2018)
Pension Committee, Public Plans Committee and Multiemployer Plans Committee comment letter to ASB on exposure drafts of proposed revisions to ASOPs 4, 24, and 35. (July 31, 2018)
Letter from Past Academy President Mary D. Miller with comments from the Academy to the National Association of Insurance Commissioners raising several concerns over a revised attestation proposal released for exposure on June 25 by the NAIC’s Casualty Actuarial and Statistical Task Force (CASTF). (July 25, 2018)
Letter from Past Academy President Mary D. Miller with extensive comments from the Academy to the NAIC responding to an exposure draft that the Casualty Actuarial and Statistical Task Force (CASTF) issued on a CAS/SOA proposal regarding CASTF’s “Continued Competence” charge. This is a significant proposal that would affect many actuaries. Comments are due by Monday, July 23. Those interested may wish to consider filing their own comments.
(July 20, 2018)
Extreme Events & Property Lines Committee questions for regulators on private flood insurance, focusing on regulatory issues for consideration as flood insurance coverage moves from a federal program to private coverage, for NAIC review. (July 20, 2018)
C1 Work Group comment letter on alternative C1 bond factors for different levels of statutory reserve offset.  (July 17, 2018)