Public Policy Comments and Letters

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)
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)