Life Comments and Letters

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)
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)
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)
Life Illustrations Work Group comments to LATF’s IUL Illustration (A) Subgroup on the draft revision to Actuarial Guideline (AG) 49. (December 1, 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)
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)
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)
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)
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)
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)
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)
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)
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)
Lifetime Income Risk Task Force comments to the Department of Labor regarding the proposed regulations defining fiduciaries and conflict of interest.
(July 20, 2015)