Public Policy Comments and Letters

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)
Financial Reporting Committee letter to the Financial Accounting Standards Board on its insurance contracts project, encouraging convergence for long-duration contracts but also highlighting issues that may need to be addressed if targeted improvements instead of the building block approach are pursued. (June 30, 2014)
Financial Reporting Committee letter to the Financial Accounting Standards Board on its insurance contracts project, encouraging convergence for long-duration contracts but also highlighting issues that may need to be addressed if targeted improvements instead of the building block approach are pursued. (June 30, 2014)
Tax Work Group comment letter to NAIC Health Actuarial Task Force on tax implications of 2013 Individual Disability Income Valuation Tables. (June 26, 2014)
Life Practice Council comment letter to the NAIC Principle-based Reserving Implementation (EX) Task Force on June 4 exposure of the Rector Report.
(June 25, 2014)
Casualty Practice Council comments on Casualty Actuarial Society’s Statement of Principles on P&C Ratemaking revised draft. (June 20, 2014)
Health Practice Financial Reporting Committee comments to the NAIC on new accounting proposals for the risk-sharing programs of the Affordable Care Act. (June 20, 2014)
Stress Testing Work Group comments on NAIC Life Risk-Based Capital Working Group stress testing proposal.
(June 18, 2014)
C-3 Work Group report on recommended approach for updating regulatory Risk-Based Capital requirements for interest rate risk for fixed annuities and single premium life insurance (C-3 Phase I).
(June 12, 2014)
Auto Insurance Committee comments to the Federal Insurance Office on issues surrounding monitoring the availability and affordability of auto insurance. This includes how to define affordability and what measurements to use when monitoring to what extent low- and moderate-income consumers have access to affordable auto insurance. (June 9, 2014)
Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisors' (IAIS) Memo on a proposed approach for a global insurance capital standard. (June 6, 2014)
Separate Account Product Work Group comment letter to the NAIC Separate Account Risk Working Group on its revised recommendations for separate accounts exposed May 7, 2014.
(June 5, 2014)
Solvency Committee comments to members of the U.S. House of Representatives supporting passage of the Insurance Capital Standards Clarification Act of 2014 (S.2270/H.R.4510), which clarifies that the Fed has the authority to differentiate between banks and insurers in terms of capital requirements. (June 5, 2014)
Risk Management and Financial Reporting Council comments to NCOIL's International Issues Task Force with recommendations on three international priorities that NCOIL should address in 2014. (June 2, 2014)
Reinsurance Work Group comment letter to the NAIC Emerging Actuarial Issues Working Group on the exposed Reinsurance Ceded Interpretation Question.
(June 2, 2014)
Pension Committee comments to the Society of Actuaries’ Retirement Plans Experience Committee on the RP-2014 and MP-2014 exposure drafts. (May 29, 2014)
Life Illustrations Work Group comment letter to the Life Actuarial Task Force on ACLI proposal for an Actuarial Guideline for Indexed Universal Life Illustrations.
(May 23, 2014)
ORSA Subgroup comments to the NAIC's Risk-Focused Surveillance Working Group on draft ORSA guidance that will be included in the Financial Analysis Handbook and the Financial Condition Examiners Handbook. (May 16, 2014)
Life Practice Council comment letter to the Life Actuarial Task Force on ACLI’s proposed small company exemption to VM-20.
(May 15, 2014)