Public Policy Comments and Letters

Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on the group capital calculation and the proposed adjustments for comparability and consistency. (May 26, 2017)
Operational Risk Work Group comments to the NAIC on the implementation of the Life Risk-Based Capital operational risk factor.  (May 25, 2017)
Health Practice Council comments to Senate Finance Committee on improving the individual health insurance market and changing the approach to Medicaid funding.
(May 23, 2017)
Financial Regulatory Task Force comments to U.S. House leadership on H.R. 10, the Financial CHOICE Act of 2017, noting that if Congress chooses to establish an Office of the Independent Insurance Advocate, that office should include an Office of the Actuary. (May 19, 2017)
Pension Committee comment letter to the IRS and Treasury on the projection of benefits under cash balance plans with variable interest credits. (May 12, 2017)
Life Reserves Work Group amendment proposal form to the National Association of Insurance Commissioners Life Actuarial Task Force regarding the VM-20 wording on modeling of policy loans and separate account assets. (May 12, 2017)
Stop-Loss Work Group comments to the NAIC’s Capital Adequacy (E) Task Force concerning calibration of risk factors in the Stop-Loss Factors Report. (May 9, 2017)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the revised Insurance Core Principles (ICPs) and ComFrame material integrated with ICPs’ public consultation package dated March 3, 2017. (May 8, 2017)
Pension Committee comment letter to the Actuarial Standards Board (ASB) on the proposed Actuarial Standard of Practice (ASOP), Setting Assumptions.
(May 2, 2017)
Life Reserves Work Group comments on the National Association of Insurance Commissioners' (NAIC) Life Actuarial Task Force exposed amendment proposal form related to additional definitions under VM-20. (May 2, 2017)
Life Reserves Work Group comments on the National Association of Insurance Commissioners' (NAIC) Life Actuarial Task Force exposed amendment proposal form related to VM-20 Section 2G on model segmentation and the proposed alternative guidance note.
(May 2, 2017)
Casualty Practice Council comments on the ASB's third exposure of the proposed Actuarial Standards of Practice (ASOP), Estimating Future Costs for Prospective Property/Casualty Risk Transfer and Risk Funding. (April 27, 2017)
ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Setting Assumptions exposure draft. (April 27, 2017)
Premium Review Subgroup comments to the Center for Consumer Information and Insurance Oversight on the final 2018 unified rate review template (URRT) instructions. (April 27, 2017)
Pension Practice Council letter to Congressional leaders on pension-related revenue offsets. (April 18, 2017)
Workers' Compensation Committee comment letter to California's Offfice of Self-Insured Plans regarding guidance on actuarial reports on self-insured workers' compensation plans. (March 30, 2017)
Pension Committee comment letter to the IRS on the proposed update to mortality tables for determining the present value for defined benefit pension plans. (March 30, 2017)
Notes from the Multiemployer Plans Subcommittee meeting on Feb. 22 with officials of the Treasury and Labor departments, and Pension Benefit Guaranty Corporation to discuss applications by multiemployer pension plans in critical and declining status to suspend benefits or partition liabilities. (March 23, 2017)
Indivdiual and Small Group Markets Committee and Medicaid Subcommittee comments on H.R. 1628, the American Health Care Act, the proposed legislation to repeal and replace provisions in the Affordable Care Act. (March 22, 2017)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on a draft report on operational life risk-based capital. (March 17, 2017)