Public Policy Comments and Letters

Intersector Group notes of its May 2017 meeting with the Pension Benefit Guaranty Corporation.
(August 3, 2017)
Intersector Group notes of its May 2017 meeting with the Treasury Department and Internal Revenue Service. (August 3, 2017)
Comment letter submitted jointly by the P/C RBC Committee and the Health Solvency Subcommittee regarding changes to corporate bond factors being considered by the NAIC’s Investment Risk-Based Capital Working Group. (July 25, 2017)
Health Practice Council letter to the U.S. Senate on potential adverse consequences of legislation to eliminate the Affordable Care Act’s (ACA) individual mandate. (July 25, 2017)
C1 Work Group comments to the NAIC's Investment Risk-Based Capital Working Group (IRBC) on their recent proposal on RBC requirements for real estate. (July 24, 2017)
COPLFR's comment letter to the NAIC's Title Insurance Financial Reporting Working Group regarding proposed changes to reporting of reserves in the title statement of actuarial opinion (July 14, 2017)
Financial Regulatory Task Force comments to the U.S. House Financial Services Committee on H.R. 3110, Financial Stability Oversight Council Insurance Member Continuity Act. (July 14, 2017)
Accelerated Underwriting Project Oversight Group (reporting to the Academy's Life Experience Committee and SoA's Preferred Mortality Oversight Group) comments to NAIC's Life Actuarial Task Force (LATF) discussing future experience study data elements. (July 14, 2017)
VM-31 Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on an amendment to eliminate the summary of methods and assumptions that covers multiple product groups in the executive summary.  (July 10, 2017)
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)