Public Policy Comments and Letters

P/C Risk-Based Capital Committee comment letter to the National Association of Insurance Commissioners on the Reinsurance Association of America's updated proposal on credit risk factors. (May 12, 2014)
AG 43/C-3 Phase II Work Group comment letter to NAIC on ACLI proposals for modification of reserve and capital requirements for contingent deferred annuities. (May 8, 2014)
Intersector Group notes to the Pension Practice Council from its March 2014 meeting with the Treasury Department and Internal Revenue Service. (May 1, 2014)
Intersector Group notes to the Pension Practice Council from its March 2014 meeting with the Pension Benefit Guaranty Corporation. (May 1, 2014)
Principle-based Reserve Strategy Subgroup (PBRSS) comment letter to the NAIC suggesting topics to be discussed at a potential interim meeting of the PBR Implementation (EX) Task Force.
(April 23, 2014)
Risk Sharing Work Group letter to CCIIO with comments on a proposed rule related to exchanges and market reforms for 2015, specifically addressing ACA risk-sharing mechanisms. (April 21, 2014)
Pension Practice Council letter to congressional leaders on proposals to raise revenue from the private sector pension system to offset unrelated spending increases. (April 17, 2014)
Pension Finance Task Force letter on proposals to extend the pension funding rules enacted under MAP-21. (April 17, 2014)
Life Capital Adequacy Subgroup comments on the NAIC Operational Risk Subgroup’s March 20 exposure of a revised proposal that suggests a new “C-5” factor in the NAIC Life Risk-Based Capital formula to provide for operational risk.
(April 15, 2014)
Principle-based Reserves Strategy Subgroup comments clarifying the suggestion to eliminate the net premium reserve (NPR) component of VM-20 in previous comments on Feb. 17 Report of Rector & Associates to the Principle-Based Reserving Implementation (EX) Task Force.
(April 11, 2014)
Letter to congressional leaders regarding the sunset of certain multiemployer provisions in the Pension Protection Act of 2006 that will expire at the end of 2014. (March 31, 2014)
Contingent Annuity Issues Work Group responses to questions from the NAIC regarding the reserving and capital requirements for contingent annuities.
(March 21, 2014)
Principle-Based Reserve Strategy Subgroup comments on the exposed Feb. 17, 2014, Report of Rector & Associates, Inc. to the Principle-Based Reserving Implementation (EX) Task Force.
(March 21, 2014)
Letter from Health Solvency Work Group to NAIC Health Risk-Based Capital Working Group regarding the effect of the 3Rs on risk-based capital. (March 11, 2014)
ORSA Subgroup comments to the NAIC on its Guidance Manual for the Own Risk and Solvency Assessment (ORSA), noting that revisions made in the March 2014 draft provides clarity for those developing ORSA reports. (March 5, 2014)
Pension Committee Comments on the Internal Revenue Service Notice 2014-5, Temporary Nondiscrimination Relief for Closed Defined Benefit Plans and Request for Comments. (February 28, 2014)
Natural Catastrophe Subcommittee letter to U.S. House members on repealing some premium increases mandated by the Biggert-Waters Flood Insurance Reform Act of 2012. (February 26, 2014)
Financial Reporting Committee letter to the Financial Accounting Standards Board on proposed wording to clarify the methodology used in determining the "top down" discount rate. (February 12, 2014)
Life Reserves Work Group revised amendment proposal regarding treatment of due premiums in VM-20 reserve calculation.
(February 5, 2014)
Academy comments to NAIC’s Joint Qualified Actuary (A/B/C) Subgroup on definitions of “qualified actuary” as prescribed by the NAIC.  (February 3, 2014)