Public Policy Comments and Letters

Long-Term Care Reserve Work Group letter to NAIC that illustrates the anticipated impact of various hypothetical changes in the mortality, voluntary lapse, interest and morbidity valuation assumptions on net renewal valuation premiums and contract reserves by policy duration. (September 10, 2003)
Long-Term Care Risk-Based Capital Work Group letter to the Deputy Insurance Commissioner of Pennsylvania responding to concerns regarding total asset adequacy as it relates to the Long-Term Care RBC Work Group's interim report. (September 8, 2003)
Health Practice Financial Reporting Committee letter addressing general principles that should be considered in the development of and addressed by premium deficiency reserves and gross premium valuations. (September 3, 2003)
Health Practice Council letter on the general risk sharing approaches available, summarizes the risk-sharing provisions in the Senate and House bills, and provides specific comments on the risk-sharing approaches in the Senate and House bills. (July 30, 2003)
Health Liquidity Work Group status update to the NAIC on a set of potential ratios to be used to test for health organization liquidity. The ratios would be used in a “safe harbor” test. (June 30, 2003)
Annuity Nonforfeiture Implementation Work Group comments to the NAIC regarding the implementation of a new model nonforfeiture law for deferred annuities. (June 25, 2003)
Long-Term Care RBC Work Group interim report on the Managed Care Organization Risk Based Capital formulas for Long Term Care (LTC) insurance products and described the source of data, methodology, analysis, and recommendations. (June 22, 2003)
Illustrations Work Group comments to the NAIC on mortality assumptions used in life insurance. (June 1, 2003)
Health Practice Council comments on legislation that was introduced in both the House and Senate to regulate the use of genetic information, particularly with respect to health insurance. (May 22, 2003)
Retiree Health Insurance Work Group letter to the Governmental Accounting Standards Board (GASB) about the actuarial measurement of retiree health benefits. (May 20, 2003)
Workers' Compensation Subcommittee comments in response to a Federal Register request by the Treasury Department for comments on implementation of Title I of the Terrorism Risk Insurance Act of 2002 and the related April 15, 2003 Interim Final Rule. (May 16, 2003)
Life Financial Reporting Committee comments on an AICPA proposed statement of opinion for deferred acquisition costs on internal replacements. (May 15, 2003)
Health Plan Work Group comments on the Small Business Health Fairness Act of 2003 (H.R. 660 and S. 545), which would amend ERISA to establish a new “Part 8—Rules Governing Association Health Plans. (April 28, 2003)
LTC Reserve Work Group outline of the proposed near-term and long-term objectives as they relate to the NAIC's request for the Academy to review the reserve methodology for LTC insurance. (March 7, 2003)
Academy comments to the SEC on proposed Sarbanes-Oxley Act auditor independence rules. (January 6, 2003)
Health Liquidity Work Group status update to the NAIC on a set of potential ratios to be used to test for health organization liquidity. The ratios would be used in a “safe harbor” test. (December 31, 2002)
Health Practice Council and Pension Practice Council letter to GASB discussing concerns actuaries have about two aspects of the proposed standard, including the use of a common premium concept to determine whether an employer is subject to the accounting and reporting aspects of this standard, and, the use of an alternative (non-actuarial) approach that could be used by small employers. (December 13, 2002)
Academy commments to the SEC on proposed Sarbanes-Oxley Act disclosure rules. (November 26, 2002)
Committee on Property and Liability Financial Reporting letter to Casualty Actuarial Society on Statement of Principles Regarding Property and Casualty Loss and Loss Adjustment Expense Reserves. (November 12, 2002)
Life Financial Reporting Committee comment on draft of the proposed statement of position, "Accounting and Reporting by Insurance Enterprises for Certain Nontraditional Long-Duration Contracts and for Separate Accounts." (October 30, 2002)