Public Policy Comments and Letters

Health Financial Reporting and Solvency Committee comments to NAIC Statutory Accounting Principles Working Group in Form A Maintence Maintenance Agenda Submission Form. (July 7, 2017)
Indivdiual and Small Group Markets Committee and Medicaid Subcommittee comments on the Better Care Reconciliation Act (BCRA) of 2017, the proposed legislation to repeal and replace provisions in the Affordable Care Act. (June 30, 2017)
Non-Guaranteed Elements Work Group comments to the New York Department of Financial Services on re-proposed 11NYCRR 48 (insurance regulation 210) on life insurance and annuity non-guaranteed elements. (June 22, 2017)
C1 Work Group comments to the NAIC with revised recommendations on corporate bond risk-based capital (RBC) factors based on changes to the representative portfolio. (June 8, 2017)
Medicare Subcommittee comments to House Ways and Means Health Subcommittee on preserving and strengthening the Medicare program.
(June 1, 2017)
PBR Governance Work Group comments to the Actuarial Standards Board (ASB) on the exposure draft for a new ASOP, Principle-Based Reserves for Life Products. (May 31, 2017)
Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on the group capital calculation and the proposed adjustments for comparability and consistency. (May 26, 2017)
Operational Risk Work Group comments to the NAIC on the implementation of the Life Risk-Based Capital operational risk factor.  (May 25, 2017)
Health Practice Council comments to Senate Finance Committee on improving the individual health insurance market and changing the approach to Medicaid funding.
(May 23, 2017)
Financial Regulatory Task Force comments to U.S. House leadership on H.R. 10, the Financial CHOICE Act of 2017, noting that if Congress chooses to establish an Office of the Independent Insurance Advocate, that office should include an Office of the Actuary. (May 19, 2017)
Pension Committee comment letter to the IRS and Treasury on the projection of benefits under cash balance plans with variable interest credits. (May 12, 2017)
Life Reserves Work Group amendment proposal form to the National Association of Insurance Commissioners Life Actuarial Task Force regarding the VM-20 wording on modeling of policy loans and separate account assets. (May 12, 2017)
Stop-Loss Work Group comments to the NAIC’s Capital Adequacy (E) Task Force concerning calibration of risk factors in the Stop-Loss Factors Report. (May 9, 2017)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the revised Insurance Core Principles (ICPs) and ComFrame material integrated with ICPs’ public consultation package dated March 3, 2017. (May 8, 2017)
Pension Committee comment letter to the Actuarial Standards Board (ASB) on the proposed Actuarial Standard of Practice (ASOP), Setting Assumptions.
(May 2, 2017)
Life Reserves Work Group comments on the National Association of Insurance Commissioners' (NAIC) Life Actuarial Task Force exposed amendment proposal form related to additional definitions under VM-20. (May 2, 2017)
Life Reserves Work Group comments on the National Association of Insurance Commissioners' (NAIC) Life Actuarial Task Force exposed amendment proposal form related to VM-20 Section 2G on model segmentation and the proposed alternative guidance note.
(May 2, 2017)
Casualty Practice Council comments on the ASB's third exposure of the proposed Actuarial Standards of Practice (ASOP), Estimating Future Costs for Prospective Property/Casualty Risk Transfer and Risk Funding. (April 27, 2017)
ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Setting Assumptions exposure draft. (April 27, 2017)
Premium Review Subgroup comments to the Center for Consumer Information and Insurance Oversight on the final 2018 unified rate review template (URRT) instructions. (April 27, 2017)