Public Policy Comments and Letters

Life Reserves Work Group (LRWG) comments to the NAIC’s Life Actuarial Task Force (LATF) on currently exposed amendment proposal forms on term and universal life insurance with secondary guarantees. (April 25, 2016)
Pension Accounting Committee comments to the Financial Accounting Standards Board on its exposure draft on changes to the disclosure requirements for defined benefit plans.
(April 25, 2016)
Risk Sharing Subcommittee letter to the Centers for Medicare & Medicaid Services (CMS) with comments on its recent discussion paper, HHS-Operated Risk Adjustment Methodology. The letter includes comments on partial year enrollment, use of pharmacy data, use of concurrent versus prospective model, high-risk enrollee pooling, recalibration of the model, and the transfer formula.  (April 22, 2016)
Casualty Practice Council comments on the Actuarial Standards Board's (ASB) second exposure draft of the proposed actuarial standards of practice for Property/Casualty Ratemaking. (April 21, 2016)
Health Care Receivables Factors Work Group recommendation on credit risk factors for health care receivables to the NAIC’s Health Risk Based Capital (E) Work Group. (April 15, 2016)
Premium Review Work Group letter to CCIIO with comments on the 2017 unified rate review template (URRT). (March 30, 2016)
Health Solvency Subcommittee letter to the NAIC’s Health Risk-Based Capital (E) Working Group with comments on Proposal 2016-01-H’s individual premiums and claims footnote. (March 28, 2016)
Role of the Actuary Subgroup comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on revisions to Section VM-31 of the Valuation Manual applicable to qualified actuaries for clarification and consistency with the Standard Valuation Law. (March 25, 2016)
Joint Academy Life Experience Committee and SOA Preferred Mortality Oversight Group comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on the removal of the provisions for unisex rates as applied to reserves. (March 17, 2016)
Senior Pension Fellow Ted Goldman comments to the Senate Finance Committee on its hearing, “The Multiemployer Pension Plan System: Recent Reforms and Current Challenges.”
(March 17, 2016)
Comments to the NAIC executive committee by the Price Optimization Task Force on changes made to the proposed Price Optimization White Paper. (March 15, 2016)
Life Illustrations Work Group comments to the NAIC’s IUL Illustration (A) Subgroup on revisions to Actuarial Guideline (AG) 49. (March 14, 2016)
Role of the Actuary Subgroup comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on revisions to the Corporate Governance Guidance Appendix, Section VM-G, of the Valuation Manual applicable to qualified actuaries for clarification and consistency with the Standard Valuation Law. (March 10, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's V-22 Subgroup of the Life Actuarial Task Force on statutory regulations regarding the determination of statutory valuation interest rates. (February 23, 2016)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed accounting standards update, Fair Value Measurement (Topic 820): Disclosure Framework. (February 18, 2016)
Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC’s Actuarial Opinion (C) Working Group on the Actuarial Opinion Instructions. (February 12, 2016)
Senior Property/Casualty Fellow Jim MacGinnitie comments to the NAIC/IAIABC Joint (C) Working Group on the 2015 Workers’ Compensation Large Deductible Study draft. (February 5, 2016)
Committee on Property and Liability Financial Reporting (COPLFR)  comments to the NAIC’s Statutory Principles (E) Working Group on the proposed Clarification of Accounting Treatment for Fees Incurred for Salvage/Subrogation Recoveries. (February 3, 2016)
Life Illustrations Work Group (LIWG) comments to the NAIC’s Life Insurance and Annuities (A) Committee on the new working group formed to explore disclosures required in Model #580 and #582. (January 29, 2016)
Actuarial Guideline 43/C-3 Phase II Work Group comments to the NAIC on the variable annuities blanks proposal exposed on Nov. 19. (January 29, 2016)