Public Policy Comments and Letters

Pension Finance Task Force comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)
Joint Committee on Retiree Health comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. (May 31, 2012)
Joint Committee on Retiree Health comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)
Actuarial Value Subgroup letter to CCIIO offering comments on the Actuarial Value and Cost-Sharing Reduction bulletin, specifically addressing the proposed actuarial value calculator. This letter supplements comments submitted April 2 on the cost-sharing inputs for the calculator. (May 16, 2012)
Health Practice Financial Reporting Committee comments to the ASB on revisions to ASOPs 22 and 28. (May 15, 2012)
Life Practice Council letter to the NAIC Blanks Committee with comments on blanks proposal 2012-04. (May 14, 2012)
Pension Committee comments to the Internal Revenue Service on proposed regulations for partial annuity distribution options under defined benefit pension plans. (May 3, 2012)
Pension Committee comment letter to the Internal Revenue Service responding to proposed regulations for longevity annuity contracts. (May 3, 2012)
Medical Loss Ratio Subgroup letter to CMS offering comments on the revised annual reporting form, specifically on the definition of premiums, contract reserves, and the definition of pre-tax underwriting gain/(loss). (May 2, 2012)
Pension Practice Council letter to members of the House-Senate Conference Committee commenting on the pension funding stabilization provisions included in S. 1813 as passed by the Senate. (May 2, 2012)
Comments by Committee on Property and Liability Financial (COPLFR) to the NAIC's Blanks Working Group on its proposed 2012 Actuarial Opinion Instructions. (May 1, 2012)
Financial Regulatory Reform Task Force comments to the Federal Reserve on its proposed rule establishing additional prudential standards to apply to non-bank financial service companies identified by the Financial Stability Oversight Council as companies that could pose systemic risk. (April 30, 2012)
Federal Long-Term Care (LTC) Task Force letter to NCOIL in response to a request for information on strategies to reduce costs related to LTC coverage. (April 27, 2012)
Health Practice Council and the Committee on Qualifications letter to all state insurance commissioners and chairs of each state house and senate insurance committee regarding the appropriate definition of "Qualified Actuary" as it relates to the Affordable Care Act's rate review provision. (April 20, 2012)
Risk Management and Financial Reporting Council letter to the Department of Treasury urging that actuarial science be one of the specific considerations for members of the proposed Financial Research Advisory Committee that will support the work of the Office of Financial Research. (April 13, 2012)
Natural Catastrophe Subcommittee of the Extreme Events Committee comments to the National Conference of Insurance Legislators concerning natural catastrophe insurance reform options. (April 13, 2012)
Health Practice Council comment letter to the Center for Consumer Information and Insurance Oversight (CCIIO) providing responses to questions raised during a meeting with representatives of CCIIO on the structure of a proposed actuarial value calculator (for purposes of the ACA). (April 2, 2012)
Pension Accounting Committee and Public Plans Subcommittee joint comment letter to the Governmental Accounting Standards Board responding to GASB’s Preliminary Views on Economic Condition Reporting: Financial Projections. (April 2, 2012)
Health Practice Council comment letter to House leadership on legislation (HR 5) that would include a provision to repeal the Independent Payment Advisory Board, which was created under the ACA to provide recommendations to reduce growth in Medicare expenditures if spending exceeds a certain growth rate. (March 21, 2012)
Medical Professional Liability Committee letter to the leadership of the U.S. House of Representatives concerning H.R. 5, which would reform the medical professional liability system and repeal the Independent Payment Advisory Board. (March 21, 2012)