Public Policy Comments and Letters

VM-22 drafting subgroup of the Annuity Reserve Work Group (ARWG) comments to LATF’s VM-22 subgroup on sections of VM-22 that cover all non-variable annuities and deposit funds. (September 29, 2015)
Solvency Committee written testimony for the U.S. House Financial Services Subcommittee on Housing and Insurance's hearing on "The Impact of Domestic Regulatory Standards on the U.S. Insurance Market." (September 29, 2015)
C1 Work Group (C1WG) comments on the ACLI’S proposed Life Insurer C-1 Asset Risk-Based Capital Requirement – Real Estate that was exposed by the NAIC Investment Risk-Based Capital Working Group. (September 29, 2015)
Pension Committee comments to the Pension Benefit Guaranty Corporation (PBGC) regarding the proposed changes to the §4010 reporting requirements.
(September 25, 2015)
Premium Review Work Group letter to CCIIO with suggested changes to the unified rate review template (URRT) and rating methodology. (September 22, 2015)
Life Practice Council comments to the NAIC’s Principle-Based Reserving Implementation (EX) Task Force on its “Substantially Similar Terms and Provisions” to Determine the Valuation Manual Operative Date exposure draft. (September 17, 2015)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposal to limit unlocking the assumptions and discount rates for long-duration insurance contracts to only the fourth quarter. (September 16, 2015)
Reinsurance Committee comments to the National Association of Insurance Commissioners (NAIC) on the draft Certified Reinsurers and Passporting Public Document. (September 11, 2015)
Price Optimization Task Force comments to the NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on its Price Optimization White Paper, which was exposed at the NAIC’s summer national meeting. (September 10, 2015)
Auto Insurance Committee comments to the Federal Insurance Office on monitoring the affordability of auto insurance. (August 31, 2015)
Multiemployer Subcommittee comments to the IRS and Treasury on proposed regulations on suspensions of benefits under the Multiemployer Pension Reform Act of 2014.
(August 19, 2015)
Solvency Committee comments to the National Association of Insurance Commissioners (NAIC) on the Discussion Draft on Approaches to a Group Capital Calculation dated July 23, 2015. (August 7, 2015)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Higher Loss Absorbency Capacity for Global Systemically Important Insurers (G-SIIs) public consultation document dated June 25, 2015. (August 6, 2015)
Price Optimization Task Force comments to NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on the recommendations section of its “Price Optimization White Paper.” (July 31, 2015)
Terrorism Risk Insurance Subcommittee comments to NAIC’s Blanks Working Group on its terrorism risk insurance supplement and instructions draft. (July 30, 2015)
The Casualty Practice Council, Health Practice Council, Life Practice Council, and Risk Management and Financial Reporting Council comments to the National Association of Insurance Commissioners (NAIC) on its Financial Condition (E) Committee questionnaire that examines the reasons for single-state solutions to help regulators develop a process for creating a uniform framework for state-based regulation. (July 27, 2015)
Medicaid Subcommittee comment letter to Centers for Medicare and Medicaid Services (CMS) on proposed rules about Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid managed care, CHIP delivered in managed care, Medicaid and CHIP comprehensive quality strategies, and revisions related to third party liability. (July 27, 2015)
Amendment Proposals on New CSO Tables in Valuation Manual
Joint American Academy of Actuaries Life Experience Committee and Society of Actuaries Preferred Mortality Oversight Group amendment proposals to the Life Actuarial Task Force on VM-02 Section 5A, VM-20 Sections 3 and 6, VM-M Section 1.H, and VM-A to the Valuation Manual regarding adoption of new CSO tables. (July 23, 2015)
Individual Disability Tables Work Group comments on the “The Individual Disability Valuation Standard Report” of the Joint American Academy of Actuaries/Society of Actuaries Individual Disability Tables Work Group. (July 22, 2015)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on issues raised during the May 21, 2015 educational session related to retrospective unlocking in long-duration contracts. (July 22, 2015)