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Public Policy Comments and Letters
Printer-friendly versionSolvency Committee's comments to the International Association of Insurance Supervisor (IAIS) on its concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. These comments further address the methods of operating group-wide supervision of internationally active insurance groups. (August 25, 2011)
Medicare Supplement Work Group letter to the NAIC's Medicare Supplement Refund Formula Subgroup with a proposed charge to have the work group review the Medicare Supplement Refund Formula for potential changes that may need to be addressed. (August 24, 2011)
Letter following up Public Interest Committee congressional testimony to House Ways and Means Subcommittee on Social Security. (August 15, 2011)
Solvency Committee comments to the NAIC on its ComFrame Concept Paper Draft US Responses and supports the position that the modules should be outcome-oriented rather than prescriptive. (August 15, 2011)
Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisor (IAIS) concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. The committee addressed questions presented in the paper relating to Own Risk & Solvency Assessment (ORSA), corporate governance, and Enterprise Risk Management. (July 27, 2011)
Property/Casualty RBC Committee update in response to the NAIC's request for assistance with the Solvency Modernization project on the NAIC's Risk-Based Capital formulas. This update discusses the Committee's progress toward providing recommendations for improving the correlation/covariance methodologies used in the P/C RBC formula. (July 21, 2011)
Flood Insurance Subcommittee letter to the U.S. Senate Banking, Housing & Urban Affairs Committee concerning the actuarial implications of S. 1091, "The Consumer Option for an Alternative System to Allocate Losses (COASTAL) Act." The bill would reauthorize the NFIP for an additional five years and would create a system for allocating losses between wind and water for "slab claims," in which no physical structure remains. (July 11, 2011)
Pension Committee comment letter to the Joint Board for Enrollment of Actuaries regarding final regulations and continuing education requirements for enrolled actuaries. (June 29, 2011)
Premium Review Work Group comments to CMS in response to the revised preliminary justification and consumer disclosure forms for purposes of rate review disclosure and reporting requirements. (June 28, 2011)
Financial Regulatory Reform Task Force letter to the Department of the Treasury outlining the metrics intended to aid in identifying systemic risk in the insurance sector. (June 24, 2011)
Pension Practice Council and Public Plans Subcommittee comment letter to the Securities and Exchange Commission requesting that public pension plans be excluded from the definition of "investment strategies" and that enrolled actuaries and members of the five U.S.-based actuarial organizations be excluded from the definition of "municipal advisors" to the extent they are providing actuarial services that are governed by the Actuarial Standards of Practice and the Code of Professional Conduct. (June 22, 2011)
Pension Committee letter to the Internal Revenue Service with concerns about the implications of the proposed modifications to Circular 230 and registration requirements for PTINs and the application of these rules to various reporting requirements for retirement plan professionals. (June 14, 2011)
Health Care Quality Work Group comments to CMS in response to proposed regulations on accountable care organizations and the Medicare Shared Savings Program under the Affordable Care Act. (June 6, 2011)
Pension Committee letter to the Internal Revenue Service and Department of the Treasury with comments and recommendations for future guidance on merger and spinoff issues related to the measurement of assets and liabilities for pension funding purposes and funding ratios. (June 1, 2011)
Pension Committee comments to the IRS and Treasury regarding the potential implications of expected regulatory guidance on the definition of "plan-related expenses expected to be paid from plan assets" under Internal Revenue Code (IRC) Section 430(b). (May 24, 2011)
Pension Committee comments to the Actuarial Standards Board regarding a proposed revision of ASOP No. 27, "Selection of Economic Assumptions for Measuring Pension Obligations." (May 12, 2011)
Flood Insurance Subcommittee comment letter to the leadership of the House Financial Services Committee on H.R. 1309, a bill to reform the National Flood Insurance Program. (May 4, 2011)
Premium Review Work Group comments to CMS in response to a notice on rate increase disclosure and review reporting requirements. (May 2, 2011)
Reinsurance Subcommittee letter to the IASB on its Insurance Contracts Exposure Draft regarding recognition of gains and losses on reinsurance ceded for long duration contracts. (April 11, 2011)
Exchanges Work Group comments to the National Assocation of Insurance Commissioners (NAIC) Exchanges (B) Subgroup regarding its white paper on adverse selection and exchanges created through the Affordable Care Act. (April 5, 2011)
