Public Policy Comments and Letters

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)
Financial Regulatory Task Force comments to the Federal Reserve Board (Fed) on its proposed rule on Capital Requirements for Supervised Institutions Significantly Engaged in Insurance Activities.
(September 16, 2016)
Pension Committee comments to U.S. Senate Special Committee on Aging Chairman Susan Collins on efforts to encourage open multiple employer plans.
(September 1, 2016)
Life Products Committee comments to the Actuarial Standards Board (ASB) on the proposed Actuarial Standard of Practice (ASOP) that applies to the pricing of life insurance and annuity products. (August 24, 2016)
Lifetime Income Risk Joint Task Force comment letter to the Department of Labor concerning proposals for increasing retiree income options, with a focus on additional safe harbors that encourage delivering lifetime income.
(August 19, 2016)
ERM/ORSA Committee comments to the NAIC’s National Treatment and Coordination (E) Working Group on its “Draft Form A Review Best Practices” exposure document. (August 17, 2016)
Financial Regulatory Task Force comments to the Federal Reserve Board (Fed) on its proposed rule on Enhanced Prudential Standards for Systemically Important Insurance Companies. (August 17, 2016)
Multiemployer Subcommittee comment letter on the Pension Benefit Guaranty Corporation’s (PBGC) proposed rule on mergers and transfers between multiemployer plans.
(August 5, 2016)
Life Illustrations Work Group comments to the NAIC's IUL Illustrations (A) Subgroup regarding the extension of Actuarial Guideline 49 (AG 49) to all inforce life insurance illustrations. (August 1, 2016)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on how operational risk, including a prospective growth charge, might be better reflected in the Life Risk-Based Capital Formula. (July 27, 2016)
Financial Reporting Committee (FRC) and Committee on Property and Liability Financial Reporting (COPLFR) comments to the SEC on its concept release on the modernization of certain disclosure requirements in Regulation S-K. (July 21, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 Subgroup of the Life Actuarial Task Force (LATF) in a question-and-answer format on the determination of statutory valuation interest rates. (July 15, 2016)
Pension Committee comment letter on the decision by the Internal Revenue Service (IRS) to limit the pension actuaries’ potential to interact with IRS actuaries and other experienced employee-benefits personnel.
(July 15, 2016)
Comment letter from the Committee on Property and Liability Financial Reporting (COPLFR) to the NAIC noting inconsistencies in the instructions for certification of loss reserves for international insurers. (July 7, 2016)
Life Reserves Work Group (LRWG) comments to the NAIC's Life Actuarial Task Force (LATF) on the exposed NAIC staff Amendment Proposal Form (APF) on VM-20 product aggregation. (July 5, 2016)
Life Practice Council comments to the NAIC's Life Actuarial Task Force (LATF) on the qualified actuaries’ responsibilities to the interests of the company versus the commissioner. (June 30, 2016)
Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on on the Consolidated ACLI and Academy Amendment Proposal Form. (June 22, 2016)
Pension Committee comment letter to the Pension Benefit Guarantee Corporation (PBGC) expressing appreciation for proposed regulations providing a reduction or partial waiver of the penalty due upon the late payment of premiums to the single employer and multiemployer insurance programs.
(June 22, 2016)
Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on Section 4 of the Valuation Manual-G. (June 10, 2016)