Life Comments and Letters

SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on the VM-22 Maximum Valuation Interest Rates for Income Annuities draft report. (March 14, 2017)
SVL Interest Rate Modernization Work Group comments on a revised weighting methodology proposal to the NAIC's VM-22 (A) Subgroup. (February 17, 2017)
AG 43/C-3 Phase II Work Group comments to the NAIC’s Variable Annuities Issues (E) Working Group on version 1 of the draft specifications for the second quantitative impact study. (February 3, 2017)
Standard Valuation Law Interest Rate Modernization Work Group comments to the NAIC’s Life Actuarial Task Force (LATF) on its “VM-22: Maximum Valuation Interest Rates for Income Annuities” exposure draft. (January 25, 2017)
Non-Guaranteed Elements Work Group comments to the New York state Department of Financial Services on Proposed 11 NYCRR 48 (Insurance Regulation 210) on life insurance and annuity non-guaranteed elements. (January 17, 2017)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on proposed operational risk factors and growth charge for the life risk-based capital (RBC) formula. Appendix attached. (December 19, 2016)
AG 43/C-3 Phase II Work Group comments to the Variable Annuities Issues (E) Working Group on the exposed proposal to revise Actuarial Guideline 43 (AG 43) and C-3 Phase II. (November 14, 2016)
Work Group Comments on Valuation Rate Buckets for Proposed VM-22 for Income Annuities Draft
SVL Interest Rate Modernization Work Group comments on valuation rate buckets to the NAIC's VM-22 (A) Subgroup on its exposure draft on the VM-22 maximum valuation interest rates for income annuities. (November 2, 2016)
Work Group Comments on Proposed VM-22 Maximum Valuation Interest Rates for Income Annuities Draft
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on its exposure draft on the VM-22 maximum valuation interest rates for income annuities. (November 2, 2016)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on proposed operational risk factors and growth charge for the life risk-based capital (RBC) formula. (October 31, 2016)
C1 Work Group comments to the NAIC's Investment Risk Based Capital Working Group on proposed RBC factors for fixed income securities for the NAIC’s life RBC formula. (October 17, 2016)
Tax Work Group comments to the NAIC's Statutory Accounting Principles (E) Working Group in response to the Issue Paper No. 15X concerning the implementation of principle-based reserving (PBR). (October 6, 2016)
C1 Work Group comments to the NAIC's Investment Risk Based Capital Working Group in response to the “Proposal for Life Bond Granularity and Related Issues” dated Sept. 6, 2016. (October 5, 2016)
Life Illustrations Work Group comments to the Actuarial Standards Board (ASB) on revisions to ASOP No. 24 Revision–Compliance with the NAIC Life Insurance Illustrations Model Regulation. (September 29, 2016)
Stress Testing Work Group comments to the NAIC's Stress Testing (E) Subgroup on providing assistance to help meet its charge. (September 28, 2016)
Nonforfeiture Modernization Work Group comments to the NAIC's Life Actuarial Task Force (LATF) with regard to potentially updating standard nonforfeiture laws. (September 28, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on Non-Jumbo and Jumbo Sample Calculations on valuation interest rates. (September 21, 2016)
Life Products Committee comments to the Actuarial Standards Board (ASB) on the proposed Actuarial Standard of Practice (ASOP) that applies to the pricing of life insurance and annuity products. (August 24, 2016)
Lifetime Income Risk Joint Task Force comment letter to the Department of Labor concerning proposals for increasing retiree income options, with a focus on additional safe harbors that encourage delivering lifetime income.
(August 19, 2016)
Life Illustrations Work Group comments to the NAIC's IUL Illustrations (A) Subgroup regarding the extension of Actuarial Guideline 49 (AG 49) to all inforce life insurance illustrations. (August 1, 2016)