Public Policy Comments and Letters

Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) proposed amendments to auditor’s use of the work of specialists. (August 29, 2017)
Life Reserves Work Group (LRWG) comment letter to the National Association of Insurance Commissioners’ Life Actuarial Task Force exposed VM-20 Amendment Proposal Form (APF) on term insurance riders, labeled VM Maintenance Agenda Item 2017-40. (August 28, 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)
Pension Committee comment letter to the ERISA Advisory Council on the Annual Funding Notice Under ERISA Section 101(f). (August 16, 2017)
Life Experience Committee amendment proposal form to the NAIC's Life Actuarial Task Force to implement guaranteed issue mortality tables under current formula requirements. (August 4, 2017)
Life Experience Committee amendment proposal form to the NAIC's LIfe Actuarial Task Force to implement guaranteed issue mortality tables under principle-based reserve requirements. (August 4, 2017)
Intersector Group notes of its May 2017 meeting with the Pension Benefit Guaranty Corporation.
(August 3, 2017)
Intersector Group notes of its May 2017 meeting with the Treasury Department and Internal Revenue Service. (August 3, 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)
Health Practice Council letter to the U.S. Senate on potential adverse consequences of legislation to eliminate the Affordable Care Act’s (ACA) individual mandate. (July 25, 2017)
C1 Work Group comments to the NAIC's Investment Risk-Based Capital Working Group (IRBC) on their recent proposal on RBC requirements for real estate. (July 24, 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)
Financial Regulatory Task Force comments to the U.S. House Financial Services Committee on H.R. 3110, Financial Stability Oversight Council Insurance Member Continuity Act. (July 14, 2017)
Accelerated Underwriting Project Oversight Group (reporting to the Academy's Life Experience Committee and SoA's Preferred Mortality Oversight Group) comments to NAIC's Life Actuarial Task Force (LATF) discussing future experience study data elements. (July 14, 2017)
VM-31 Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on an amendment to eliminate the summary of methods and assumptions that covers multiple product groups in the executive summary.  (July 10, 2017)
Health Financial Reporting and Solvency Committee comments to NAIC Statutory Accounting Principles Working Group in Form A Maintence Maintenance Agenda Submission Form. (July 7, 2017)
Indivdiual and Small Group Markets Committee and Medicaid Subcommittee comments on the Better Care Reconciliation Act (BCRA) of 2017, the proposed legislation to repeal and replace provisions in the Affordable Care Act. (June 30, 2017)
Non-Guaranteed Elements Work Group comments to the New York Department of Financial Services on re-proposed 11NYCRR 48 (insurance regulation 210) on life insurance and annuity non-guaranteed elements. (June 22, 2017)
C1 Work Group comments to the NAIC with revised recommendations on corporate bond risk-based capital (RBC) factors based on changes to the representative portfolio. (June 8, 2017)
Medicare Subcommittee comments to House Ways and Means Health Subcommittee on preserving and strengthening the Medicare program.
(June 1, 2017)