Public Policy Comments and Letters

Exchanges Work Group letter to HHS in response to its request for comments on the exchange-related provisions in ACA. (October 4, 2010)
ERM Committee response to the NAIC on its consultation paper on Own Risk and Solvency Assessment (ORSA) for the Solvency Modernization Initiative. (October 4, 2010)
Joint Committee on Retiree Health and the Pension Accounting Committee joint comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions). (October 4, 2010)
P/C Risk-Based Capital Committee response to the NAIC's request on risk-based capital issues. (October 1, 2010)
Deferred Tax Asset DTA Bridge Group request for an interim report to the NAIC Capital Adequacy Task Force showing the appropriate treatment of the Deferred Tax Asset (DTA) in the Risk-Based Capital formulas for Life, Property / Casualty (P&C), and Health. (September 30, 2010)
Annuity Illustration Work Group letter to the NAIC Annuity Disclosure Working Group explaining their suggestions to the Annuity Disclosure Model Regulation and included a sample illustration. (September 30, 2010)
Financial Reporting Committee and Life Financial Reporting Committee comments to FASB on its Proposed Accounting Standards Update, Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities. (September 30, 2010)
Casualty Practice Council request for research assistance from the Casualty Actuarial Society in conjunction with its efforts to aid the National Association of Insurance Commissioners with its RBC SMI project. (September 30, 2010)
Risk Sharing Work Group letter to HHS regarding the ACA reinsurance provision that references the Academy. The letter includes initial input on potential approaches for identifying high-risk individuals and determining reinsurance payments. (September 22, 2010)
Pension Practice Council response to the Governmental Accounting Standards Board (GASB)'s "Preliminary Views on Pension Accounting and Financial Reporting by Employers." (September 17, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on first-dollar coverage of preventive services. (September 17, 2010)
Pension Accounting Committee comments to the International Accounting Standards Board (IASB) regarding  proposed amendments to IAS 19. (September 3, 2010)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on ACA provisions that eliminate lifetime limits, restrict annual limits, eliminate preexisting condition exclusions, and prohibit rescissions. (August 27, 2010)
Medical Loss Ratio Regulation Work Group letter to HHS with input on credibility issues for the purpose of calculating rebates under the new MLR requirements. (August 20, 2010)
Grandfathering Provisions Work Group letter to HHS in response to an interim final rule on the ACA provision related to the status of health insurance coverage as a grandfathered plan. (August 16, 2010)
Risk Management and Solvency Committee comments to the IAIS on its Draft Standard on Group-wide Regulatory Requirements and Guidance on Group-wide Supervision Framework. (August 10, 2010)
Financial Reporting Committee and Risk Management and Solvency Committee comments on the June 2010 Primary Considerations to the NAIC Statutory Accounting and Financial Reporting (EX) Subgroup. (August 4, 2010)
Terrorism Risk Insurance Subgroup comments to the President's Working Group on Financial Markets in response to its Federal Register request for an analysis of terrorism risk insurance. (August 2, 2010)
Premium Review Work Group letter regarding Massachusetts Senate Bill 2447, which includes a provision that would limit rate increases to medical CPI. (July 27, 2010)
Premium Review Work Group comment letter on the NAIC's exposure draft of a rate-filing disclosure form that is intended to facilitate the reporting of unreasonable rate increases to HHS. (July 14, 2010)