Public Policy Comments and Letters

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)
Benefits and Eligibility Work Group letter to HHS in response to an interim final rule on the PPACA provision that extends dependent coverage to age 26. (July 12, 2010)
Pension Committee comments to the Cost Accounting Standards Board on the proposed rulemaking for harmonization of CAS Nos. 412 and 413 with the Pension Protection Act of 2006. (July 9, 2010)
Pension Committee letter to the Department of the Treasury and the Internal Revenue Service (IRS) with suggestions for the 2011 schedules SB and MB instructions and forms. (July 7, 2010)
Financial Reporting Committee and Life Financial Reporting Committee comments to the IASB concerning its report, "Exposure Draft Financial Instruments: Amortised Cost and Impairment." (June 30, 2010)
Property and Casualty Risk-Based Capital Committee update to the National Association of Insurance Commissioners (NAIC)'s Property & Casualty Risk-Based Capital Working Group regarding the RBC Committee's prior March 2010 update of the property/casualty RBC underwriting factors. (June 22, 2010)
Health Solvency Work Group comment letter to the chair of the NAIC's Capital Adequacy Task Force regarding the evaluation of the current health risk-based capital covariance formula calculation for potential changes to the calculation or methodology. (June 11, 2010)
Financial Regulatory Reform Task Force letter to Congress urging the inclusion of an Office of the Chief Actuary in the Office of Financial Research as Congress was in conference reconciling bills H.R.4173 and S.3217. (June 9, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Accident and Health Working Group offering input on the potential inclusion of a change in contract reserves in the numerator of the MLR rebate calculation. (June 7, 2010)
Life Products Committee letter to Massachusetts Governor Deval Patrick regarding a bill (HB 889) to allow gender pricing at the Savings Bank Life Insurance Company. (June 4, 2010)
Joint Committee on Retiree Health letter to the Department of Health and Human Services in response to an interim final rule on the PPACA provision that creates a temporary reinsurance program for early retirees. (June 3, 2010)
Invested Asset Work Group letter to the Capital Adequacy Task Force regarding the proposed increase to commercial real estate mortgage risk based capital. (June 2, 2010)
Medical Loss Ratio Regulation Work Group letter to the NAIC responding to a request for more information on defining statistical credibility within the MLR rebate process as provided in a previous letter. (May 20, 2010)
Property and Casualty Risk-Based Capital follow-up comments to the National Association of Insurance Commissioners (NAIC)'s Property Risk-Based Capital Working Group regarding the Committee's March 2010 update of the property/casualty RBC underwriting factors. (May 18, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Health Care Reform Solvency Impact Subgroup on an exposure draft of a new proposed financial reporting exhibit the Supplemental Health Care Exhibit. (May 17, 2010)
Medical Loss Ratio Regulation Work Group letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that requires medical loss ratio reporting and rebates. (May 14, 2010)
Premium Review Work Group letter to the Department of Health and Human Services in response to its request for comments on the PPACA provision that establishes a review process for unreasonable rate increases. (May 14, 2010)