Public Policy Comments and Letters

Life Practice Council letter to the National Association of Insurance Commissioners (NAIC) (EX) Working Group and Life Insurance and Annuities (A) Committee on principles-based valuation and capital approach (PBA) for life insurance. (May 12, 2010)
Medical Loss Ratio Regulation Work Group letter to the chair of the NAIC's Accident and Health Working Group responding to his request for input on defining an appropriate way to maintain statistical validity within the rebate process. The Academy sent a subsequent letter to respond to a request from the NAIC for more information on statistical credibility. (May 12, 2010)
Premium Review Work Group letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup, the Accident and Health Working Group, and the Rate Review Subgroup regarding the Patient Protection and Affordability Act (PPACA) provision that establishes a review process for unreasonable rate increases. (May 8, 2010)
Pension Committee and the Multiemployer Subcommittee comments on multiemployer pension plan provisions of H.R. 4213, the American Workers, State and Business Relief Act of 2010. (May 4, 2010)
Pension Practice Council and Life Practice Council's response to a request for information from the Labor and Treasury departments regarding lifetime-income options for participants and beneficiaries in retirement plans. (May 3, 2010)
Risk Management and Solvency Committee comments to the IAIS on its Guidance Paper on Capital Adequacy for Regulatory Solvency Purposes. (April 30, 2010)
Risk Management and Solvency Committee comments to the IAIS on its Guidance Paper on Capital Adequacy for Regulatory Solvency Purposes. (April 30, 2010)
Medical Loss Ratio Regulation Work Group second letter to the chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding the medical loss ratio provisions and the potential for individual market disruption under the Patient Protection and Affordability Act. (April 28, 2010)
Medical Loss Ratio Regulation Work Group letter to the Chairs of the NAIC's Health Care Reform Solvency Impact Subgroup and the Accident and Health Working Group regarding considerations related to the Patient Protection and Affordability Act Medical Loss Ratio Provisions (2718). (April 20, 2010)
Committee on State Health Issues letter to the North Carolina Department of Insurance regarding the Department's proposal to change the definition of "qualified actuary." (April 14, 2010)
Pension Committee comments to the Actuarial Standards Board (ASB) regarding proposed revisions to ASOP No. 41, Actuarial Communications. (March 31, 2010)
Pension Committee comments to the Actuarial Standards Board (ASB) regarding proposed revisions to ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations. (March 31, 2010)
Health Practice Council letter to members of House and Senate pledging to work with regulatory authorities on the implementation of the health reform law. (March 24, 2010)
Health Practice Council letter to Congress outlining technical and policy issues that need to be addressed before the passage of health reform legislation to ensure success of the reforms. (March 8, 2010)
Regulatory Capital Requirements Task Force response to questions posed in the Consultation Paper on Regulatory Capital Requirements and Overarching Accounting and Valuation Issues for the Solvency Modernization Initiative. (March 1, 2010)
Health Practice Council letter to the White House and invitees of the Feb. 25 bipartisan health summit stressing critical actuarial aspects of health reform legislation that will need to be addressed to support the stated goals of reducing the number of uninsured, increasing the availability and affordability of coverage, and enhancing the focus on quality of care and health spending growth. (February 24, 2010)
Letter to NAIC regarding the joint Academy State LTC Task Force and SOA Valuation Committee project to develop and recommend valuation morbidity tables for long-term care insurance. (February 22, 2010)
Financial Reporting Committee comments on the recent vote by the IASB and confirmation by the FASB to not permit the recognition of revenue for incremental acquisition expenses upon the initial measurement of an insurance contract. (February 19, 2010)
Workers' Compensation Subcommittee comments on the California Commission on Health and Safety and Workers' Compensation investigation of relationships between workers' compensation and group health care. (February 12, 2010)
Life Financial Reporting Committee and Financial Reporting Committee comments on the FASB on exposure draft, Proposed ASU-Financial Services-Insurance (Topic 944): "Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts." (February 12, 2010)