Public Policy Comments and Letters

Nonforfeiture Modernization Work Group comments related to cancellation benefits on contingent deferred annuities (CDAs) to the NAIC CDA (A) Working Group (CDAWG). (October 20, 2015)
AG 43/C-3 Phase II Work Group comments on the "Variable Annuities Framework for Change" to the NAIC’s Variable Annuities Issues (E) Working Group. (October 16, 2015)
Active Benefits Subcommittee letter to the IRS regarding Notice 2015-52 on the excise tax for high-cost employer-sponsored health coverage under the Affordable Care Act (ACA). (October 1, 2015)
Principle-Based Reserves Strategy Subgroup comments to Reinsurance Task Force on XXX/AXXX Credit for Reinsurance Model Regulation Draft. (September 30, 2015)
Life Illustrations Work Group (LIWG) comments to the Life Insurance and Annuities (A) Committee regarding illustration issues that could be reviewed by the proposed Illustration Review (A) Working Group. (September 30, 2015)
VM-22 drafting subgroup of the Annuity Reserve Work Group (ARWG) comments to LATF’s VM-22 subgroup on sections of VM-22 that cover all non-variable annuities and deposit funds. (September 29, 2015)
Solvency Committee written testimony for the U.S. House Financial Services Subcommittee on Housing and Insurance's hearing on "The Impact of Domestic Regulatory Standards on the U.S. Insurance Market." (September 29, 2015)
C1 Work Group (C1WG) comments on the ACLI’S proposed Life Insurer C-1 Asset Risk-Based Capital Requirement – Real Estate that was exposed by the NAIC Investment Risk-Based Capital Working Group. (September 29, 2015)
Pension Committee comments to the Pension Benefit Guaranty Corporation (PBGC) regarding the proposed changes to the §4010 reporting requirements.
(September 25, 2015)
Premium Review Work Group letter to CCIIO with suggested changes to the unified rate review template (URRT) and rating methodology. (September 22, 2015)
Life Practice Council comments to the NAIC’s Principle-Based Reserving Implementation (EX) Task Force on its “Substantially Similar Terms and Provisions” to Determine the Valuation Manual Operative Date exposure draft. (September 17, 2015)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposal to limit unlocking the assumptions and discount rates for long-duration insurance contracts to only the fourth quarter. (September 16, 2015)
Reinsurance Committee comments to the National Association of Insurance Commissioners (NAIC) on the draft Certified Reinsurers and Passporting Public Document. (September 11, 2015)
Price Optimization Task Force comments to the NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on its Price Optimization White Paper, which was exposed at the NAIC’s summer national meeting. (September 10, 2015)
Auto Insurance Committee comments to the Federal Insurance Office on monitoring the affordability of auto insurance. (August 31, 2015)
Multiemployer Subcommittee comments to the IRS and Treasury on proposed regulations on suspensions of benefits under the Multiemployer Pension Reform Act of 2014.
(August 19, 2015)
Solvency Committee comments to the National Association of Insurance Commissioners (NAIC) on the Discussion Draft on Approaches to a Group Capital Calculation dated July 23, 2015. (August 7, 2015)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Higher Loss Absorbency Capacity for Global Systemically Important Insurers (G-SIIs) public consultation document dated June 25, 2015. (August 6, 2015)
Price Optimization Task Force comments to NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on the recommendations section of its “Price Optimization White Paper.” (July 31, 2015)
Terrorism Risk Insurance Subcommittee comments to NAIC’s Blanks Working Group on its terrorism risk insurance supplement and instructions draft. (July 30, 2015)