Public Policy Comments and Letters

PBR Strategy Subgroup comment letter to NAIC Life Actuarial Task Force (LATF) on AG 48 exposure draft. (September 17, 2014)
Contingent Annuity Work Group comments to NAIC Contingent Deferred Annuity Working Group on regulatory guidelines for CDAs. (September 12, 2014)
Reinsurance Committee comments to the NAIC's Reinsurance (E) Task Force on the exposure draft, Securities Listed by the Securities Valuation Office, that specifically address the security provided for the purpose of collateralizing reinsurance obligations. (September 5, 2014)
Financial Reporting Committee letter to the International Accounting Standards Board on the treatment of participating contracts within the IFRS Foundation's insurance contracts project that includes discussions on book-yield and effective-yield approaches. (September 2, 2014)
The Joint Committee on Retiree Health letter to the Governmental Accounting Standards Board commenting on proposed statements of accounting and financial reporting by governmental employers for other postemployment benefits (OPEBs). (August 29, 2014)
The Pension Committee's Public Plans Subcommittee letter to the Governmental Accounting Standards Board commenting on an Exposure Draft on accounting and financial reporting for pension plans that are not administered through trusts and amendments to certain provisions of GASB Statements 67 and 68. (August 29, 2014)
Pension Committee letter to the Internal Revenue Service and Treasury Department on guidance needed regarding the Highway and Transportation Funding Act of 2014. (August 26, 2014)
Nonforfeiture Modernization Work Group update to the NAIC Life Actuarial Task Force. (August 15, 2014)
AG33 Non-Elective Task Force letter to NAIC Life Actuarial Task Force on Actuarial Guideline XXXIII. (August 15, 2014)
Principle-Based Reserves Strategy Subgroup comment letter to NAIC Life Actuarial Task Force on the Net Premium Reserve component of the Rector report. (August 12, 2014)
Solvency Committee comments to the National Association of Insurance Commissioners on the International Association of Insurance Supervisors' revised proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (August 4, 2014)
Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors' revised proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (August 4, 2014)
Pension Practice Council letter to Congressional leaders on concerns about proposals to raise revenues by changing private sector pension law to offset unrelated spending increases. (July 25, 2014)
Pension Finance Task Force letter to Congressional leaders on concerns about proposals to raise revenues by changing private sector pension law to offset unrelated spending increases. (July 25, 2014)
ORSA Subgroup comments to the NAIC's Risk-Focused Surveillance Working Group on the second exposure draft of ORSA guidance, which will be included in the Financial Analysis Handbook and the Financial Condition Examiners Handbook. (July 22, 2014)
Casualty Practice Council comments to U.S. House leaders on the TRIA Reform Act of 2014 in support of reauthorizing the terrorism risk insurance program and maintaining a government backstop for a peril that is difficult to fully insure in the private market. (July 16, 2014)
Pension Committee comment letter to National Conference of Insurance Legislators on proposed Pension De-Risking Model Act. (July 11, 2014)
Casualty Practice Council comments to Senate leaders on the Terrorism Risk Insurance Reauthorization Act of 2014 in support of reauthorizing the terrorism risk insurance program and maintaining a government backstop for a peril that is difficult to fully insure in the private market. (July 10, 2014)
Committee on Property and Liability Financial Reporting comment letter to the NAIC's Casualty Actuarial and Statistical Task Force on proposed changes to IRIS ratios 11, 12, and 13, which would add adjusting and other expenses to the basis for calculating these ratios. (July 10, 2014)
Medicaid Work Group request to the Centers for Medicare and Medicaid Services for specific guidance on the Affordable Care Act's Health Insurance Providers fee and how it affects the Medicaid program. (July 7, 2014)