Public Policy Comments and Letters

Risk Management and Financial Reporting Council (RMFRC) comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers discussion draft. (July 21, 2015)
Lifetime Income Risk Task Force comments to the Department of Labor regarding the proposed regulations defining fiduciaries and conflict of interest.
(July 20, 2015)
Pension Committee comments to the IRS regarding the timing for release of the mortality tables under §§430(h)(3) and 417(e) of the Internal Revenue Code for 2016.  (July 17, 2015)
The Financial Reporting Committee, Pension Accounting Committee, Casualty Committee on Property and Liability Financial Reporting, Health Financial Reporting and Solvency Committee, and Life Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) “The Auditor's Use of the Work of Specialists” consultation paper. (July 15, 2015)
Risk Management and Financial Reporting Council letter to the Federal Reserve Board on issues related to a “margin over current estimate” (MOCE) for international insurance capital standards. (July 14, 2015)
Terrorism Risk Insurance Subcommittee comments to NAIC on its “Terrorism Risk Insurance Supplement and Instructions” draft. (July 6, 2015)
Price Optimization Task Force comments to NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on the second exposure of its “Price Optimization White Paper.” (July 2, 2015)
Academy comments to NAIC’s Casualty Actuarial and Statistical Task Force on its review of the Society of Actuaries’ (SOA) general insurance track request. (June 29, 2015)
Financial Regulatory Task Force (FinReg) letter to the U.S. House Financial Services Committee (HFSC) on the Financial Stability Oversight Council (FSOC) 2015 annual report. (June 17, 2015)
Deposit Fund Subgroup letter to NAIC Life Actuarial (A) Task Force recommending edits to model regulation 695 concerning synthetic guaranteed investment contracts (GICs). (June 15, 2015)
Catastrophe Risk Subcommittee of the P/C Risk-Based Capital (RBC) Committee comments to the NAIC’s Catastrophe Risk Subgroup on the proposal to revise the calculation of catastrophe risks R6 and R7 for the 2015 reporting year. (June 12, 2015)
Intersector Group notes of its April 2015 meeting with the Treasury Department and Internal Revenue Service.  (June 2, 2015)
Intersector Group notes of its April 2015 meeting with the Pension Benefit Guaranty Corporation (PBGC). (June 2, 2015)
Pension Committee comments to the Actuarial Standards Board (ASB) on its exposure draft, “Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.” (June 1, 2015)
Public Plans Subcommittee comments to the Actuarial Standards Board (ASB) on its exposure draft, “Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.” (May 29, 2015)
RBC Catastrophe Risk Subcommittee comments to NAIC’s Catastrophe Risk (E) Subgroup on revised Form PR026 for the 2015 reporting year. (May 22, 2015)
Health Solvency Work Group comment letter to the NAIC's Investment Risk-Based Capital Working Group on the evaluation of asset risk factors for the health risk-based capital formula. (May 20, 2015)
Nonforfeiture Modernization Work Group comment letter to NAIC Life Actuarial (A) Task Force on exposed edits to the standard nonforfeiture law for annuities regarding requirements for contingent deferred annuities (CDA). (May 13, 2015)
Risk Management and Financial Reporting Council comments to the International Association of Insurance Supervisors (IAIS) on Insurance Core Principle (ICP) 8: Risk Management and Internal Controls. (May 12, 2015)
Risk Sharing Work Group letter to CCIIO on the methodology proposed to evaluate the sufficiency of EDGE server data. (May 8, 2015)