Public Policy Comments and Letters

Risk Management and Financial Reporting Council letter to the FDIC regarding a New York Times article in which the FDIC agreed to guarantee billions of dollars in risky loans assuming that those loans represent zero default risk. (April 14, 2009)
Risk Management and Financial Reporting Council response to a New York Times article in which the FDIC agreed to guarantee billions of dollars in risky loans assuming that those loans represent zero default risk. (April 8, 2009)
Financial Reporting Committee response to the joint IASB/FASB Financial Crisis Advisory Group (FCAG) in which FCAG sought input from constituents to discussion questions surrounding accounting and reporting matters related to the financial crisis. (April 1, 2009)
Financial Reporting Committee comments to the Securities and Exchange Commission on the "Roadmap for the Potential Use of Financial Statements Prepared in Accordance with International Financial Reporting Standards by US Issuers." (March 4, 2009)
Financial Reporting Committee comments to the International Accounting Standards Board regarding its revenue recognition project. (February 4, 2009)
Risk Management and Solvency Committee comments to the NAIC on its draft memorandum, Windows and Walls Approach for Regulation of United States Based Insurers Operating within Corporate Groups. (January 29, 2009)
Medicare Steering Committee and Health Care Quality Work Group comments to the Senate Finance Committee on the draft legislation "Medicare Hospital Quality Improvement Act of 2008", which would link Medicare hospital payments to performance on certain quality measures. (December 15, 2008)
Medicare Part D RBC Subgroup letter to the Centers for Medicare and Medicaid Services for financial data related to Medicare Part D, which will be used to update a report on Medicare Part D RBC risk factors. (October 6, 2008)
Life Financial Soundness/Risk Management Committee comments on company generated scenarios. (August 31, 2008)
Health RBC Trend Test Work Group report to the NAIC on evaluating the effectiveness of three proposed trend tests. (August 26, 2008)
Risk Management and Financial Reporting Council letter to the Senate seeking clarification on the role of the actuary in the Insurance Information Act of 2008. (July 29, 2008)
Risk Management and Financial Reporting Council letter to the House seeking clarification on the role of the actuary in the Insurance Information Act of 2008. (July 29, 2008)
Reinsurance Work Group comments to the NAIC on risk transfer rules. (July 15, 2008)
Risk Margin Task Force comments to the IAA on its second exposure draft, "Measurement of Liabilities for Insurance Contracts: Current Estimates and Risk Margins." (May 28, 2008)
Extreme Events Committee’s Natural Catastrophe Subcommittee comments on a proposed NCOIL resolution about a state-federal system for catastrophe funding. (May 1, 2008)
Life Tax Steering Group comments on an IRS notice to life insurers about potential federal income tax issues concerning proposed principle-based reserving and proposed Actuarial Guideline VA-CARVM. (May 1, 2008)
Pension Committee comments to the Internal Revenue Service (IRS) regarding proposed regulations for some hybrid defined benefit (DB) pension plans. (March 3, 2008)
Pension Committee comments to the Internal Revenue Service (IRS) on proposed regulations for measuring pension assets and liabilities. (March 3, 2008)
First in a series of fact sheets produced by the Medical Malpractice Insurance Subcommittee that discusses different types of medical professional liability insurance policies. (March 1, 2008)
Financial Reporting Committee comments on the proposed International Standard on Auditing (ISA) 620, "Using the Work of an Auditor’s Expert." (February 22, 2008)