Life Comments and Letters

Life Capital Adequacy Subcommittee comment letter to the NAIC’s Life-Risk Based Capital (E) Working Group on its exposure draft on  additional collateral for transactions with unauthorized reinsurers before risk-based capital (RBC) credit can be taken by the ceding company.
(October 11, 2013)
AG 43/C-3 Phase II Work Group comment letter to the NAIC C-3 Phase II/AG 43 (E/A) Subgroup regarding recent amendment with modifications to current total return gross wealth ratios for Actuarial Guideline 43.  
(September 30, 2013)

Aggregate Margin Task Force proposal to replace individual margin in VM-20 with aggregate margin approach.

(August 22, 2013)

Annuity Reserve Work Group report to the Life Actuarial Task Force on potential reserve methodology for non-variable annuities in VM-22.

(August 22, 2013)

Nonforfeiture Modernization Work Group update to the Life Actuarial Task Force regarding nonforfeiture treatment of certain fixed deferred annuities under the proposed gross premium nonforfeiture method approach.

(August 22, 2013)
Proposal by the Actuarial Guideline 33 Non-Elective Task Force to the NAIC Life Actuarial Task Force regarding reserves for non-elective incidence under Actuarial Guideline 33.   (August 22, 2013)
Comment letter from the C1 Work Group to the NAIC Investment Risk-Based Capital Working Group on Illinois’ common stock proposal for C1 Risk-based Capital.  
(July 24, 2013)
PBR Strategy Subgroup comment letter to the NAIC Principle-Based Reserving Implementation (EX) Task Force on the May 9 drafts of the PBR legislative and educational briefs.  
(June 11, 2013)
The Solvency Committee submitted comments to the NAIC on its revised version of a draft white paper on the Solvency Modernization Initiative and insurance regulation. (June 6, 2013)
PBR Strategy Subgroup comment letter to the NAIC Principle-Based Reserving Implementation (EX) Task Force regarding the potential impact of PBR in its draft legislative brief.  
(May 6, 2013)
Life Practice Council comment letter to the NAIC Principle-Based Reserving Implementation (EX) Task Force praising additional language in the April 3 NAIC PBR Draft Implementation Plan and offering assistance with evaluating and updating the PBR methodology.   
(May 6, 2013)
PBR Strategy Subgroup comment letter to the NAIC Principle-Based Reserves (EX) Task Force on its legislative brief outlining the ramifications of the Standard Valuation Law for state legislatures.  
(April 22, 2013)
Casualty, Health, Life, and Professionalism Council comments to the NAIC’s Joint Qualified Actuary (A/B/C) Subgroup in response to its request for comments to a list of nine questions in anticipation of the Subgroup’s meeting at the NAIC Spring National Meeting on April 5, 2013. (March 27, 2013)
Separate Account Products Work Group (SAWG) comments on the December 20, 2012 document, “Review of Non-Variable, Insulated Products/Product Characteristics with Proposed Recommendations” exposed on January 9 by the NAIC Separate Account Risk (E) Working Group. (March 25, 2013)
Annuity Illustration Work Group comments to the Iowa Insurance Division on its March 18 draft memorandum: Annuity Illustrations; 191 Iowa Administrative Code rules 15.61-.69, based upon the new NAIC Annuity Disclosure Model Regulation.
(March 22, 2013)
C1 Work Group request for data from the NAIC Capital Markets Bureau for use to assist the NAIC's Investment Risk-Based Capital Working Group with developing the risk-based capital requirements for corporate bonds.  (March 18, 2013)
Contingent Annuity Work Group comments on the NAIC Contingent Deferred Annuity (A) Working Group's February 13 draft recommendation to the Life Insurance and Annuities (A) Committee. (February 20, 2013)
C1 Work Group comments on the NAIC Securities Valuation Office Staff Recalibration Project.  (February 12, 2013)
Councils' letter to NAIC's Joint Qualified Actuary (A/B/C) Subgroup on the subgroup's two new charges related to defining a "qualified actuary" and recommending a process to address "unprofessional" actuarial work. (February 11, 2013)
Deposit Fund Subgroup proposal for reserving synthetic GICs based upon the Subgroup's report presented to the Life Actuarial Task Force on November 28, 2012. (February 8, 2013)