Public Policy Comments and Letters

The Casualty Practice Council, Health Practice Council, Life Practice Council, and Risk Management and Financial Reporting Council comments to the National Association of Insurance Commissioners (NAIC) on its Financial Condition (E) Committee questionnaire that examines the reasons for single-state solutions to help regulators develop a process for creating a uniform framework for state-based regulation. (July 27, 2015)
Medicaid Subcommittee comment letter to Centers for Medicare and Medicaid Services (CMS) on proposed rules about Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid managed care, CHIP delivered in managed care, Medicaid and CHIP comprehensive quality strategies, and revisions related to third party liability. (July 27, 2015)
Amendment Proposals on New CSO Tables in Valuation Manual
Joint American Academy of Actuaries Life Experience Committee and Society of Actuaries Preferred Mortality Oversight Group amendment proposals to the Life Actuarial Task Force on VM-02 Section 5A, VM-20 Sections 3 and 6, VM-M Section 1.H, and VM-A to the Valuation Manual regarding adoption of new CSO tables. (July 23, 2015)
Individual Disability Tables Work Group comments on the “The Individual Disability Valuation Standard Report” of the Joint American Academy of Actuaries/Society of Actuaries Individual Disability Tables Work Group. (July 22, 2015)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on issues raised during the May 21, 2015 educational session related to retrospective unlocking in long-duration contracts. (July 22, 2015)
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)