Public Policy Comments and Letters

Health Practice Council comments to the U.S. House and Senate on the potential inclusion of individual mandate repeal in The Tax Cuts and Jobs Act. (December 12, 2017)
Life Practice Council comment letter to NAIC Financial Condition (E) Committee raising concerns over the process by which the NAIC is developing changes to the statutory framework for variable annuities (VAs), including both C-3 Phase II for risk-based capital (RBC) and Actuarial Guideline (AG) 43 reserve requirements. (November 28, 2017)
Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2019 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, special enrollment periods, essential health benefits, minimum essential coverage, and medical loss ratios.
(November 27, 2017)
Health Practice Council comments to the U.S. Senate on a proposal in the Tax Cuts and Jobs Act to eliminate the ACA's individual mandate. (November 21, 2017)
Multiemployer Plans Committee comments to the Pension Benefit Guaranty Corporation (PBGC) on modifications to the instructions for the 2017 Schedule MB (Multiemployer Defined Benefit Plan Actuarial Information) of the Form 5500.
(November 20, 2017)
Casualty Practice Council letter to the U. S. House of Representatives on pending flood insurance legislation. (November 8, 2017)
Health Practice Council comments on the October 12 executive order. (November 7, 2017)
Life Reinsurance Work Group comment letter to the NAIC’s Life Actuarial (A) Task Force on yearly renewable term reinsurance premiums under Section 20 of the Valuation Manual.  (November 7, 2017)
The Life Products Committee comment letter to the Actuarial Standards Board regarding a proposed actuarial standard of practice (ASOP) on pricing of life insurance and annuity products. 
(October 31, 2017)
Pension Committee comments to the AICPA Employee Benefit Expert Panel on the current ASC 960 reporting standards for defined benefit pension plans. (October 27, 2017)
Pension Practice Council comment letter to Missouri State Employees’ Retirement System Board on the newly-adopted Terminated-Vested Member Buyout Program.
(October 23, 2017)
Non-Guaranteed Elements Work Group comment letter on the NAIC’s Life Insurance Buyer’s Guide (A) Working Group discussion draft. (October 19, 2017)
Non-Guaranteed Elements Work Group comment letter on the NAIC’s Life Insurance Buyer’s Guide (A) Working Group discussion draft. (October 19, 2017)
Committee on Property and Liability Financial Reporting comment letter to NAIC's Actuarial Opinion Working Group on the impact of life insurance Valuation Manual changes on P/C insurers' Statements of Actuarial Opinion that include accident and health (A&H) and long-term care (LTC) lines of business. (October 18, 2017)
The Life Reinsurance Work Group comments to the NAIC's Statutory Accounting Principles (E) Working Group on exposure draft 2017-28 relating to “Reinsurance Risk Transfer”. (October 13, 2017)
The C1 Work Group comments to the NAIC’s Investment Risk-Based Capital (E) Working Group on capital requirements for bonds. (October 10, 2017)
The Committee on Property and Liability Financial Reporting’s comment letter to the NAIC’s Statutory Accounting Working Group, questioning the proposed new definition of reinsurance risk transfer in SSAP No. 62R: Property and Casualty Reinsurance. (October 4, 2017)
Health Practice Council comments on the Graham-Cassidy-Heller-Johnson Proposal (GCHJ), legislation that would make revisions to the individual health insurance market and approaches to federal Medicaid funding. (September 22, 2017)
Health Practice Council letter to the U.S. Senate HELP Committee on stabilizing the individual health insurance market. (September 12, 2017)
PBR Governance Work Group’s VM-31 Review Subgroup Comment Letter to the NAIC’s Life Actuarial (A) Task Force on the exposed VM-31 Amendment Proposal Form.
(September 12, 2017)