Life Comments and Letters

Stress Testing Work Group comments on NAIC Life Risk-Based Capital Working Group stress testing proposal.
(June 18, 2014)
C-3 Work Group report on recommended approach for updating regulatory Risk-Based Capital requirements for interest rate risk for fixed annuities and single premium life insurance (C-3 Phase I).
(June 12, 2014)
Separate Account Product Work Group comment letter to the NAIC Separate Account Risk Working Group on its revised recommendations for separate accounts exposed May 7, 2014.
(June 5, 2014)
Reinsurance Work Group comment letter to the NAIC Emerging Actuarial Issues Working Group on the exposed Reinsurance Ceded Interpretation Question.
(June 2, 2014)
Life Illustrations Work Group comment letter to the Life Actuarial Task Force on ACLI proposal for an Actuarial Guideline for Indexed Universal Life Illustrations.
(May 23, 2014)
Life Practice Council comment letter to the Life Actuarial Task Force on ACLI’s proposed small company exemption to VM-20.
(May 15, 2014)
AG 43/C-3 Phase II Work Group comment letter to NAIC on ACLI proposals for modification of reserve and capital requirements for contingent deferred annuities. (May 8, 2014)
Principle-based Reserve Strategy Subgroup (PBRSS) comment letter to the NAIC suggesting topics to be discussed at a potential interim meeting of the PBR Implementation (EX) Task Force.
(April 23, 2014)
Life Capital Adequacy Subgroup comments on the NAIC Operational Risk Subgroup’s March 20 exposure of a revised proposal that suggests a new “C-5” factor in the NAIC Life Risk-Based Capital formula to provide for operational risk.
(April 15, 2014)
Principle-based Reserves Strategy Subgroup comments clarifying the suggestion to eliminate the net premium reserve (NPR) component of VM-20 in previous comments on Feb. 17 Report of Rector & Associates to the Principle-Based Reserving Implementation (EX) Task Force.
(April 11, 2014)
Principle-Based Reserve Strategy Subgroup comments on the exposed Feb. 17, 2014, Report of Rector & Associates, Inc. to the Principle-Based Reserving Implementation (EX) Task Force.
(March 21, 2014)
Contingent Annuity Issues Work Group responses to questions from the NAIC regarding the reserving and capital requirements for contingent annuities.
(March 21, 2014)
Life Reserves Work Group revised amendment proposal regarding treatment of due premiums in VM-20 reserve calculation.
(February 5, 2014)
Academy comments to NAIC’s Joint Qualified Actuary (A/B/C) Subgroup on definitions of “qualified actuary” as prescribed by the NAIC.  (February 3, 2014)
Letter from Academy RBC work groups to the NAIC SMI RBC Subgroup regarding the NAIC’s Dec. 9 Operational Risk Proposal. (January 30, 2014)
Life Practice Council comments on proposed “actuarial standard” in Report of Rector & Associates to the NAIC Principle-Based Reserving Implementation (EX) Task Force. 
(January 15, 2014)
Separate Account Products Work Group comments on the Potential Actions/Recommendations (Document 2) exposed for comment on Nov. 18, 2013, by the NAIC Separate Account Risk (E) Working Group.
(January 10, 2014)
In a Jan. 6 letter to the National Association of Insurance Commissioners’ (NAIC) Joint Qualified Actuary subgroup, American Academy of Actuaries President Tom Terry provides comments on a uniform definition of “qualified actuary” for life, health, and property/casualty appointed actuaries signing prescribed NAIC Statements of Actuarial Opinion. (January 6, 2014)
Life Practice Council comments on the Initial Report of Rector & Associates to the NAIC Principle-Based Reserving Implementation (EX) Task Force regarding assets for captive reinsurance.  
(November 15, 2013)
Life Capital Adequacy Subcommittee comment letter to the NAIC’s Life Risk-Based Capital (E) Working Group regarding double counting of the Asset Valuation Reserve in both RBC and Asset Adequacy Analysis.
(October 11, 2013)