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Public Policy Comments and Letters
Printer-friendly versionComments by the Annuity Illustration Subgroup on selected FAQs in the October 18, 2012 Iowa Insurance Division draft memorandum, Fixed Indexed Annuity Illustrations and Iowa Administrative code rules 15.61-.69. (December 11, 2012)
Comments by the Actuarial Guideline 43 / C-3 Phase II Work Group to the NAIC’s C-3 Phase II/AG 43 (E) Subgroup on its November 1, 2012 Work Plan Draft. (December 10, 2012)
Contingent Annuity Work Group comments on the definition of Contingent Deferred Annuities proposed by the ACLI and IRI and exposed by the Contingent Deferred Annuities (A) Working Group. (November 19, 2012)
Committee on Property and Liability Financial Reporting (COPLFR) comment letter to the NAIC's Casualty Actuarial & Statistical Task Force on the Statutory Accounting Principles Working Group's proposed changes to SSAP 65. (November 16, 2012)
P/C Risk-Based Capital Committee report to the NAIC's Solvency Modernization Initiative RBC Subgroup on risk correlation methodologies used to determine regulatory solvency capital requirements in advanced jurisdictions outside the U.S. (November 15, 2012)
Invested Asset Work Group comment letter to the NAIC Risk-based Capital (RBC) Working Group on American Council of Life Insurers’ Commercial Mortgage RBC Proposal. (November 14, 2012)
Life Practice Council comment letter to the NAIC commending the inclusion of a budget item for the purposes of “Actuarial Guideline 38/Principle-Based Reserving Implementation and Monitoring. (November 9, 2012)
Casualty Practice Council Comments to the NAIC's Catastrophe Risk Subgroup on its proposed changes to the Risk-Based Capital formula spreadsheets to incorporate property catastrophe risk. (October 29, 2012)
International Accounting Standards Task Force comments to the International Accounting Standards Board on its working drafts, feedback on the premium-allocation approach decisions, feedback on the Non-Insurance Components and on measuring earned premium under the building block approach. (October 9, 2012)
Comments by Public Plans Subcommittee to the California Actuarial Advisors Panel (CAAP) in response to its discussion draft, Version 9c, Model Actuarial Funding Policies and Practices (MAFPP) for Public Pension and OPEB Plans. (October 3, 2012)
Pension Practice Council comments to Moody’s in response to its proposed adjustments to public pension data reported by US state and local governments, as discussed in a Moody’s report, Adjustments to US State and Local Government Reported Pension Data. (October 2, 2012)
Pension Accounting Committee comments to the Financial Accounting Standards Board (FASB) regarding its proposed Accounting Standards Update: Financial Instruments (Topic 825) – Disclosures about Liquidity Risk and Interest Rate Risk. (October 1, 2012)
Pension Practice Council comments to the Pension Committee of the Actuarial Standards Board regarding its discussion draft, Assessment and Disclosure of Risk Associated with Pension Obligations, Plan Costs, and Plan Contributions. (October 1, 2012)
Casualty, Life, Health, Professionalism, and Financial Reporting Council comments to the NAIC's Corporate Governance Working Group on its Proposed Responses to a Comparative Analysis of Existing U.S. Corporate Governance Requirements. (September 28, 2012)
Financial Reporting Committee comments to the Financial Accounting Standards Board on its exposure draft regarding liquidity risk and interest rate risk disclosures and how the proposed amendments would affect insurance companies. (September 26, 2012)
Reinsurance Committee comments to the Federal Insurance Office on topics relating to reinsurance, including: the purpose of reinsurance, the effect of domestic and international regulation on reinsurance in the U.S., and the coordination of reinsurance supervision nationally and internationally. (August 27, 2012)
Pension Committee comments to the Internal Revenue Service in response to its proposed regulations concerning the prohibited payment option under single-employer defined benefit plans when a plan sponsor is in bankruptcy. (August 20, 2012)
Solvency Committee comments to the IAIS on its Common Framework (ComFrame) paper concerning the relationship between IAIGs and supervisors, and the framework for supervisors to address group-wide activities and risks. (August 16, 2012)
Health Practice Council letter to Sen. Thune and Rep. Boustany clarifying the nature and intent of recent Academy-hosted roundtables focused on addressing the accessibility and affordability of long-term care services. (August 15, 2012)
C1 Work Group draft project plan to the National Association of Insurance Commissioners (NAIC) C1 Factor Review (E) Subgroup that covers the development of the bond Risk-based Capital (RBC) factors and changes to the RBC determination for structured securities. (August 3, 2012)
