Public Policy Comments and Letters

Intersector Group notes of its September 2015 meeting with the Pension Benefit Guaranty Corporation (PBGC).
(December 9, 2015)
Life Illustrations Work Group comments to LATF’s IUL Illustration (A) Subgroup on the draft revision to Actuarial Guideline (AG) 49. (December 1, 2015)
Price Optimization Task Force comments to the NAIC’s Property/Casualty Committee on the Price Optimization White Paper after its adoption by the Casualty Actuarial and Statistical Task Force (CASTF). (November 21, 2015)
ERM/ORSA Committee comments to the International Actuarial Association (IAA) on its white paper "Actuarial Aspects of ERM for Insurance Companies." (November 20, 2015)
Individual Disability Tables Work Group (IDTWG) presented updated incidence modifiers report for use in active life reserve calculations for employer-sponsored disability income policies along with a corresponding memo memo to the chair of the Health Actuarial Task Force. (November 18, 2015)
Deposit Fund Subgroup comments to the Life Actuarial Task Force on rules for separate accounts that fund guaranteed minimum benefits under group contracts related to the synthetic GIC model regulation. (November 16, 2015)
P/C Risk-Based Capital Committee comments to the NAIC’s Capital Adequacy Task Force on the ongoing examination of the bond risk factors used in the P/C risk-based capital (RBC) formula. (November 10, 2015)
Medicare Supplemental Work Group responses to questions regarding the work group’s recommendations on modifications to the Medicare supplement refund formula.
(November 10, 2015)
Health Solvency Subcommittee updated on the evaluation of asset risk in the health risk-based capital (HRBC) formula.
(November 9, 2015)
Pension Practice Council comments to the Treasury Department and the Internal Revenue Service regarding final regulations concerning Qualified Longevity Annuity Contracts (QLACs) and their advantages. (November 6, 2015)
Financial Reporting and Solvency Committee comment letter to the NAIC's Emerging Accounting Issues (E) Working Group on the “ACA Risk Corridors Collectability” exposure draft. (October 30, 2015)
Solvency Committee comments to the National Association of Insurance Commissioners on the Group Capital Calculation Recommendation exposure draft. (October 27, 2015)
Life Reserves Work Group amendment proposal to the NAIC regarding the removal of references to the “seriatim reserve” in the Valuation Manual. (October 21, 2015)
Life Reserves Work Group amendment proposal to the NAIC regarding the definition and clarification of the term “modeled reserve” in the VM-20. (October 21, 2015)
Price Optimization Task Force comments to the NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on its Price Optimization White Paper that was exposed on Oct. 13. (October 21, 2015)
Nonforfeiture Modernization Work Group comments related to cancellation benefits on contingent deferred annuities (CDAs) to the NAIC CDA (A) Working Group (CDAWG). (October 20, 2015)
AG 43/C-3 Phase II Work Group comments on the "Variable Annuities Framework for Change" to the NAIC’s Variable Annuities Issues (E) Working Group. (October 16, 2015)
Active Benefits Subcommittee letter to the IRS regarding Notice 2015-52 on the excise tax for high-cost employer-sponsored health coverage under the Affordable Care Act (ACA). (October 1, 2015)
Principle-Based Reserves Strategy Subgroup comments to Reinsurance Task Force on XXX/AXXX Credit for Reinsurance Model Regulation Draft. (September 30, 2015)
Life Illustrations Work Group (LIWG) comments to the Life Insurance and Annuities (A) Committee regarding illustration issues that could be reviewed by the proposed Illustration Review (A) Working Group. (September 30, 2015)