Public Policy Comments and Letters

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)
ERM/ORSA Committee comments to the International Association of Insurance Supervisors (IAIS) on its draft issues paper Conduct of Business Risk and its Management. (May 1, 2015)
Financial Reporting Committee comments on the Financial Accounting Standards Board's (FASB) proposed accounting standards update-Derivatives and Hedging (Topic 815): Disclosures about Hybrid Financial Instruments with Bifurcated Embedded Derivatives. (April 30, 2015)
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)