Public Policy Comments and Letters

Work Group Comments on Valuation Rate Buckets for Proposed VM-22 for Income Annuities Draft
SVL Interest Rate Modernization Work Group comments on valuation rate buckets to the NAIC's VM-22 (A) Subgroup on its exposure draft on the VM-22 maximum valuation interest rates for income annuities. (November 2, 2016)
Work Group Comments on Proposed VM-22 Maximum Valuation Interest Rates for Income Annuities Draft
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on its exposure draft on the VM-22 maximum valuation interest rates for income annuities. (November 2, 2016)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on proposed operational risk factors and growth charge for the life risk-based capital (RBC) formula. (October 31, 2016)
Pension Committee, Multiemployer Plans Subcommittee, and Public Plans Subcommittee comments to the Actuarial Standards Board (ASB) on a draft actuarial standard of practice (ASOP) on risk assessment and disclosure. (October 31, 2016)
Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on its NAIC Staff Memo - Inventory Method Items with Questions exposure draft.
(October 24, 2016)
Pension Committee (PC) comments to the Actuarial Standards Board (ASB) on the third exposure draft of a proposed actuarial standard of practice (ASOP) on modeling. (October 21, 2016)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Risk-based Global Insurance Capital Standard Version 1.0 public consultation document dated July 19, 2016. (October 19, 2016)
C1 Work Group comments to the NAIC's Investment Risk Based Capital Working Group on proposed RBC factors for fixed income securities for the NAIC’s life RBC formula. (October 17, 2016)
Casualty Practice Council (CPC)  and Committee on Property and Liability Financial Reporting (COPFLR) letter to the Actuarial Standards Board commenting on the third exposure draft for the proposed Actuarial Standard of Practice (ASOP) on modeling. (October 14, 2016)
Tax Work Group comments to the NAIC's Statutory Accounting Principles (E) Working Group in response to the Issue Paper No. 15X concerning the implementation of principle-based reserving (PBR). (October 6, 2016)
Intersector Group notes of its September 2016 meeting with the Treasury Department and Internal Revenue Service. (October 6, 2016)
Intersector Group notes of its September 2016 meeting with the Pension Benefit Guaranty Corporation (PBGC). (October 6, 2016)
Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2018 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, market reforms, and rate review provisions. (October 6, 2016)
C1 Work Group comments to the NAIC's Investment Risk Based Capital Working Group in response to the “Proposal for Life Bond Granularity and Related Issues” dated Sept. 6, 2016. (October 5, 2016)
Life Illustrations Work Group comments to the Actuarial Standards Board (ASB) on revisions to ASOP No. 24 Revision–Compliance with the NAIC Life Insurance Illustrations Model Regulation. (September 29, 2016)
Stress Testing Work Group comments to the NAIC's Stress Testing (E) Subgroup on providing assistance to help meet its charge. (September 28, 2016)
Nonforfeiture Modernization Work Group comments to the NAIC's Life Actuarial Task Force (LATF) with regard to potentially updating standard nonforfeiture laws. (September 28, 2016)
Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of legislation to weaken the Affordable Care Act’s (ACA) individual mandate. (September 22, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on Non-Jumbo and Jumbo Sample Calculations on valuation interest rates. (September 21, 2016)
Intersector Group meeting notes excerpt regarding Form 5500 clarifications from its September 2016 meeting with the Treasury Department and Internal Revenue Service. (September 19, 2016)