Life Comments and Letters

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)
The Financial Reporting Committee, Pension Accounting Committee, Casualty Committee on Property and Liability Financial Reporting, Health Financial Reporting and Solvency Committee, and Life Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) “The Auditor's Use of the Work of Specialists” consultation paper. (July 15, 2015)
Deposit Fund Subgroup letter to NAIC Life Actuarial (A) Task Force recommending edits to model regulation 695 concerning synthetic guaranteed investment contracts (GICs). (June 15, 2015)
Nonforfeiture Modernization Work Group comment letter to NAIC Life Actuarial (A) Task Force on exposed edits to the standard nonforfeiture law for annuities regarding requirements for contingent deferred annuities (CDA). (May 13, 2015)
Deposit Fund Subgroup comment letter to NAIC Life Actuarial (A) Task Force on exposed edits to the model regulation for synthetic guaranteed investment contracts (GIC). (April 22, 2015)
Life Illustrations Work Group comment letter to NAIC Life Actuarial (A) Task Force on proposed actuarial guideline for indexed universal life illustrations. (April 14, 2015)
Nonforfeiture Modernization Work Group update to the NAIC Life Actuarial (A) Task Force at the NAIC Spring 2015 National Meeting. (March 27, 2015)
Life Capital Adequacy Committee (LCAC) comment letter to the NAIC Life Risk-Based Capital (E) Working Group regarding the latest exposure drafts related to the XXX/AXXX reinsurance framework. (March 20, 2015)