Public Policy Comments and Letters

Pension Committee letter to Joint Board for the Enrollment of Actuaries (JBEA) requesting the JBEA provide a summary of key mistakes or problems it has found in audits of enrolled actuaries CE filings. (September 3, 2007)
Cost Accounting Standards Task Force response to the Cost Accounting Standards Board (CASB) regarding a survey on harmonizing two cost accounting standards with provisions of the Pension Protection Act. (September 3, 2007)
Pension Committee letter to the Department of the Treasury requesting that Treasury reconsider its method for applying an anti-backloading rule (the four-thirds rule) to cash balance plans. (September 3, 2007)
Risk Management and Solvency Committee comments to the IAIS on three papers: Capital Requirements, Enterprise Risk Management for Capital and Solvency Purposes, and the Use of Internal Models by Insurers. (August 23, 2007)
Workers' Compensation Subcommittee comments on a New York state workers' compensation bill that would, among other provisions, prohibit data sharing. (August 22, 2007)
Comments from Life, Health, and Casualty Practice Councils on life and health insurance principles proposed by the NAIC's Principle-based Reserving (EX) Working Group. (August 17, 2007)
Workers’ Compensation Subcommittee comments to the International Association of Industrial Accident Boards and Commissions on proposed self-insured workers' comp loss reporting forms. (August 1, 2007)
Life Products Committee comments to the NAIC on travel-related life insurance provisions in a draft model trade law. (July 31, 2007)
Nonforfeiture Improvement Work Group follow-up questions on responses to LHATF questionnaire. (June 30, 2007)
Joint Committee on Retiree Health letter to Texas officials about misinterpretations of the committee's 2006 comments on accounting standards for OPEBs. (June 15, 2007)
Medicare Part D RBC Subgroup revision proposals to the NAIC life and health RBC instructions for Medicare Part D to address a potential unintended consequence related to the Authorized Control Level (ACL) RBC results. (June 3, 2007)
Risk Margin Task Force comments to IAA on draft "Measurement of Liabilities for Insurance Contracts: Current Estimates and Risk Margins." (May 25, 2007)
Pension Committee comments to the Department of Energy (DOE) on the issues faced by the DOE and its contractors in managing the costs of pension and medical benefits. (May 10, 2007)
Medicare Part D RBC Subgroup comment letter to NAIC's Health Risk Based Capital Working Group on a possible update of proposed risk factors previously developed by the Academy's Medicare Part D subgroup. (May 3, 2007)
Health Practice Financial Reporting Committee letter to Julia T. Philips, the Chair of the NAIC's Health Risk-Based Capital (RBC) Working Group, that comments on a proposal made by Blue Cross Blue Shield of Florida regarding the treatment in the NAIC RBC formulas of medical insurance products for which active life reserves are held. The letter provided initial thoughts on the matter and seeks further input from the NAIC in light of these thoughts. (May 3, 2007)
Health Practice Financial Reporting Committee comments to the NAIC on a proposal to include a trend test in the health RBC formula. (May 3, 2007)
Social Security Committee comments to the Federal Accounting Standards Advisory Board (FASAB) regarding a preliminary views document on accounting for social insurance. (April 16, 2007)
Financial Reporting Committee and Actuarial Standards Board joint response to FASB on its request for comments on valuation guidance in financial reporting. (April 13, 2007)
Life Financial Reporting Committee comment letter to FASB on accounting for life insurance contracts acquired in a business combination. (April 2, 2007)
Workers’ Compensation Subcommittee comments to NCOIL about a proposed model law concerning professional employer organizations and workers' comp insurance. (March 30, 2007)