Public Policy Comments and Letters

Health Solvency Subcommittee letter to the NAIC’s Health Risk-Based Capital (E) Working Group with comments on Proposal 2016-01-H’s individual premiums and claims footnote. (March 28, 2016)
Role of the Actuary Subgroup comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on revisions to Section VM-31 of the Valuation Manual applicable to qualified actuaries for clarification and consistency with the Standard Valuation Law. (March 25, 2016)
Joint Academy Life Experience Committee and SOA Preferred Mortality Oversight Group comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on the removal of the provisions for unisex rates as applied to reserves. (March 17, 2016)
Senior Pension Fellow Ted Goldman comments to the Senate Finance Committee on its hearing, “The Multiemployer Pension Plan System: Recent Reforms and Current Challenges.”
(March 17, 2016)
Comments to the NAIC executive committee by the Price Optimization Task Force on changes made to the proposed Price Optimization White Paper. (March 15, 2016)
Life Illustrations Work Group comments to the NAIC’s IUL Illustration (A) Subgroup on revisions to Actuarial Guideline (AG) 49. (March 14, 2016)
Role of the Actuary Subgroup comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on revisions to the Corporate Governance Guidance Appendix, Section VM-G, of the Valuation Manual applicable to qualified actuaries for clarification and consistency with the Standard Valuation Law. (March 10, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's V-22 Subgroup of the Life Actuarial Task Force on statutory regulations regarding the determination of statutory valuation interest rates. (February 23, 2016)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed accounting standards update, Fair Value Measurement (Topic 820): Disclosure Framework. (February 18, 2016)
Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC’s Actuarial Opinion (C) Working Group on the Actuarial Opinion Instructions. (February 12, 2016)
Senior Property/Casualty Fellow Jim MacGinnitie comments to the NAIC/IAIABC Joint (C) Working Group on the 2015 Workers’ Compensation Large Deductible Study draft. (February 5, 2016)
Committee on Property and Liability Financial Reporting (COPLFR)  comments to the NAIC’s Statutory Principles (E) Working Group on the proposed Clarification of Accounting Treatment for Fees Incurred for Salvage/Subrogation Recoveries. (February 3, 2016)
Life Illustrations Work Group (LIWG) comments to the NAIC’s Life Insurance and Annuities (A) Committee on the new working group formed to explore disclosures required in Model #580 and #582. (January 29, 2016)
Actuarial Guideline 43/C-3 Phase II Work Group comments to the NAIC on the variable annuities blanks proposal exposed on Nov. 19. (January 29, 2016)
Medicare Subcommittee letter to the Senate Finance Committee with comments on the Bipartisan Chronic Care Working Group’s Policy Options Document. (January 26, 2016)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Non-traditional Non-insurance Activities and Products public consultation document dated November 25, 2015. (January 25, 2016)
Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC/IAIABC Joint (C) Working Group on the 2015 Workers’ Compensation Large Deductible Study draft. (January 19, 2016)
Risk Sharing Subcommittee letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule on benefit and payment parameters for 2017. (December 20, 2015)
Intersector Group notes of its September 2015 meeting with the Treasury Department and Internal Revenue Service. 
(December 9, 2015)
Intersector Group notes of its September 2015 meeting with the Pension Benefit Guaranty Corporation (PBGC).
(December 9, 2015)