Life Comments and Letters

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)
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)