Public Policy Comments and Letters

Risk Management and Financial Reporting Council and Financial Reporting Committee comments to the Federal Insurance Office (FIO) on U.S. GAAP loss recognition testing and Insurance Core Principle (ICP) 14 current estimates. (April 27, 2015)
Deposit Fund Subgroup comment letter to NAIC Life Actuarial (A) Task Force on exposed edits to the model regulation for synthetic guaranteed investment contracts (GIC). (April 22, 2015)
Price Optimization Task Force comments to NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on its Price Optimization White Paper. (April 15, 2015)
Life Illustrations Work Group comment letter to NAIC Life Actuarial (A) Task Force on proposed actuarial guideline for indexed universal life illustrations. (April 14, 2015)
Casualty Practice Council comments to NAIC’s Casualty Actuarial and Statistical Task Force on the CPC’s process for approving member actuaries to sign P/C NAIC opinions. (April 9, 2015)
Pension Practice Council and Multiemployer Subcommittee comment letter to the IRS and Treasury regarding the Request for Information on Suspensions of Benefits under the Multiemployer Pension Reform Act of 2014 (MPRA).  (April 7, 2015)
Pension Practice Council and Multiemployer Subcommittee comment letter to the Pension Benefit Guarantee Corporation regarding the Request for Information on Partitions and Facilitated Mergers under the Multiemployer Pension Reform Act of 2014 (MPRA). (April 6, 2015)
Risk Sharing Work Group letter to CMS with comments on the 2014 medical loss ratio (MLR) annual reporting form. (March 31, 2015)
Nonforfeiture Modernization Work Group update to the NAIC Life Actuarial (A) Task Force at the NAIC Spring 2015 National Meeting. (March 27, 2015)
Financial Regulatory Task Force comments to the Financial Stability Oversight Council (FSOC) on the impact of insurance asset management products and activities to U.S. financial stability. (March 23, 2015)
Life Capital Adequacy Committee (LCAC) comment letter to the NAIC Life Risk-Based Capital (E) Working Group regarding the latest exposure drafts related to the XXX/AXXX reinsurance framework. (March 20, 2015)
P/C Risk-Based Capital (RBC) Committee comment letter to the National Association of Insurance Commissioners’ Property/Casualty Risk-Based Capital Working Group on methods of properly quantifying reserve and premium underwriting factors. (March 13, 2015)
Life Illustrations Work Group comment letter to NAIC Life Actuarial (A) Task Force on exposed actuarial guideline for indexed universal life illustrations. (March 11, 2015)
The Terrorism Risk Insurance Subcommittee of the Casualty Practice Council sent a comment letter to the Federal Insurance Office of the Department of the Treasury regarding the process by which terrorist events are certified for purposes of triggering the Terrorism Risk Insurance Program (as recently amended). (March 6, 2015)
Casualty Practice Council comment letter to Actuarial Standards Board on exposure draft of a proposed Actuarial Standard of Practice (ASOP) on modeling. (March 4, 2015)
Pension Committee comment letter to the Actuarial Standards Board (ASB) regarding the second exposure draft of the proposed Actuarial Standard of Practice (ASOP) on modeling standards.  (March 1, 2015)
Health Practice Council comments urging HHS to consider implementing measures to counter the potential adverse consequences on health insurance premium rate filings in the event the Supreme Court rules for the petitioners in King v. Burwell. (February 24, 2015)
PBR Strategy Subgroup and Life Reinsurance Work Group comment letter to NAIC PBR Implementation (EX) Task Force on exposure of XXX/AXXX reinsurance supplemental proposal. (February 23, 2015)
Solvency Committee comments to the International Association of Insurance Supervisors on the Risk-based Global Insurance Capital Standard public consultation document dated Dec. 17, 2014. (February 6, 2015)
Pension Committee comment letter to the IRS regarding the use of mortality tables to calculate pension funding requirements for the years after 2015. (February 5, 2015)