Public Policy Comments and Letters

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)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on the VM-22 Maximum Valuation Interest Rates for Income Annuities draft report. (March 14, 2017)
Pension Committee comments to the U.S. Treasury Department requesting guidance from the IRS and Treasury to resolve uncertainties that exist as to how variable annuity plans should be valued for minimum funding and Internal Revenue Code (IRC) §417(e) purposes.
(March 9, 2017)
Individual and Small Group Markets Committee comments to the U.S. House Committee on Education and the Workforce on  H.R. 1101, the Small Business Health Fairness Act, related to association health plans.
(March 8, 2017)
Individual and Small Group Markets Committee letter to the Centers for Medicare & Medicaid Services regarding the proposed rule for market stabilization. (March 7, 2017)
Financial Reporting Committee comments to the International Actuarial Association (IAA) on the exposure draft of its “Risk Adjustments for Financial Reporting of Insurance Contracts under International Financial Reporting Standards No. X” monograph. (February 28, 2017)
Multiemployer Pension Plans Subcommittee comments to the Pension Benefit Guaranty Corporation (PBGC) on alternative two-pool withdrawal liability methods. (February 24, 2017)
Pension Committee comment letter to the IRS on proposed regulations to the minimum present value requirements for defined benefit (DB) plan distributions. (February 24, 2017)
SVL Interest Rate Modernization Work Group comments on a revised weighting methodology proposal to the NAIC's VM-22 (A) Subgroup. (February 17, 2017)
AG 43/C-3 Phase II Work Group comments to the NAIC’s Variable Annuities Issues (E) Working Group on version 1 of the draft specifications for the second quantitative impact study. (February 3, 2017)
ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers exposure draft. (January 31, 2017)
Health Financial Reporting and Solvency Committee comments to the Long-Term Care Valuation (B) Subgroup on asset treatment for stand-alone LTC asset adequacy analysis. (January 26, 2017)
Standard Valuation Law Interest Rate Modernization Work Group comments to the NAIC’s Life Actuarial Task Force (LATF) on its “VM-22: Maximum Valuation Interest Rates for Income Annuities” exposure draft. (January 25, 2017)
Non-Guaranteed Elements Work Group comments to the New York state Department of Financial Services on Proposed 11 NYCRR 48 (Insurance Regulation 210) on life insurance and annuity non-guaranteed elements. (January 17, 2017)
LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (January 6, 2017)
Joint Property and Casualty Risk-Based Capital Committee and Health Solvency Subcommittee letter to the NAIC's Operational Risk Subgroup on proposed changes to the operational risk factor in risk-based capital (RBC) formulas for property/casualty and health. (December 19, 2016)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on proposed operational risk factors and growth charge for the life risk-based capital (RBC) formula. Appendix attached. (December 19, 2016)
GASB 74 Implementation Work Group comments on the GASB 74 implementation guide exposure draft that addresses financial reporting for postemployment benefit plans other than pension plans. (December 19, 2016)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed accounting standards update, Targeted Improvements to the Accounting for Long-Duration Contracts. (December 14, 2016)
Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of repealing provisions of the Affordable Care Act (ACA) without having a replacement approach in place, and the challenges faced by eliminating the reimbursements to insurers for cost-sharing reduction subsidies.
(December 7, 2016)