Public Policy Comments and Letters

Committees comment on the proposed rule regarding Health Reimbursement Arrangements (HRAs), that would create two new types of HRAs—Integrated HRAs and Excepted Benefit HRAs—which would allow employers to provide HRAs that could be used to pay for individual plan premiums and out-of-pocket health costs.  (December 13, 2018)
Non-Guaranteed Elements Work Group comment letter to NAIC on their proposal for a life insurance online guide landing page.  (November 28, 2018)
Retirement System Assessment and Policy Committee letter to Congress on the Retirement Enhancement and Savings Act of 2018.  (November 16, 2018)
Letter from Academy Past President Mary D. Miller to NAIC with comments on CASTF’s draft 3-year experience proposal. (November 8, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Risk-based Global Insurance Capital Standard Version 2.0 (ICS 2.0) public consultation document dated July 31, 2018. (October 30, 2018)
Life Operational Risk Work Group follow-up letter to NAIC on exposed Life Risk-Based Capital growth charge proposal.  (October 29, 2018)
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)