Public Policy Comments and Letters

Intersector Group notes of its March 2016 meeting with the Treasury Department and Internal Revenue Service.  (June 7, 2016)
Intersector Group notes of its March 2016 meeting with the Pension Benefit Guaranty Corporation (PBGC). (June 7, 2016)
Solvency Committee comments to the NAIC's Operational Risk (E) Subgroup on its "Operational Risk 2016 Factors" exposure document. (June 6, 2016)
The Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on combined revisions regarding VM-G of the Valuation Manual. (June 3, 2016)
Casualty Practice Council and P/C Extreme Events Committee letter to U.S. Senate Banking, Housing and Urban Affairs Committee on HR 2901, The Flood Insurance Market Parity and Modernization Act, concerning an expanded role for private insurers in the flood insurance marketplace. (May 25, 2016)
Solvency Committee comments to the NAIC's Investment Risk-Based Capital (E) Working Group on its "Way Forward" exposure document. (May 19, 2016)
Life Reserves Work Group (LRWG) comments to the NAIC's Life Actuarial Task Force (LATF) on the Minnesota Department of Commerce Amendment Proposal Form (APF) on post-level term profit assumptions. (May 18, 2016)
Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on recommendations made in amendment proposal forms regarding VM-G of the Valuation Manual. (May 6, 2016)
LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (April 28, 2016)
Pension Committee comments to the Internal Revenue Service regarding the proposed regulations for nondiscrimination relief for closed defined benefit plans.
(April 28, 2016)
Pension Practice Council comments to the Department of Defense regarding the use of personal discount rates to calculate lump-sum payments from military pensions as required in the National Defense Authorization Act for Fiscal Year 2016.
(April 27, 2016)
Casualty Practice Council and P/C Extreme Events Committee letter to U.S. House of Representatives on HR 2901, The Flood Insurance Market Parity and Modernization Act, concerning an expanded role for private insurers in the flood insurance marketplace. (April 26, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 Subgroup of the Life Actuarial Task Force (LATF) on questions and answers in response to statutory regulations regarding the determination of statutory valuation interest rates. (April 25, 2016)
Life Reserves Work Group (LRWG) comments to the NAIC’s Life Actuarial Task Force (LATF) on currently exposed amendment proposal forms on net premium reserves. (April 25, 2016)
Life Reserves Work Group (LRWG) comments to the NAIC’s Life Actuarial Task Force (LATF) on currently exposed amendment proposal forms on term and universal life insurance with secondary guarantees. (April 25, 2016)
Pension Accounting Committee comments to the Financial Accounting Standards Board on its exposure draft on changes to the disclosure requirements for defined benefit plans.
(April 25, 2016)
Risk Sharing Subcommittee letter to the Centers for Medicare & Medicaid Services (CMS) with comments on its recent discussion paper, HHS-Operated Risk Adjustment Methodology. The letter includes comments on partial year enrollment, use of pharmacy data, use of concurrent versus prospective model, high-risk enrollee pooling, recalibration of the model, and the transfer formula.  (April 22, 2016)
Casualty Practice Council comments on the Actuarial Standards Board's (ASB) second exposure draft of the proposed actuarial standards of practice for Property/Casualty Ratemaking. (April 21, 2016)
Health Care Receivables Factors Work Group recommendation on credit risk factors for health care receivables to the NAIC’s Health Risk Based Capital (E) Work Group. (April 15, 2016)
Premium Review Work Group letter to CCIIO with comments on the 2017 unified rate review template (URRT). (March 30, 2016)