Life Comments and Letters

Life Financial Soundness/Risk Management Committee presentation of NAIC's Life and Health Actuarial Task Force Amendment proposal outlining a simplified approach for determining prudent estimate mortality assumption for VM-20. (June 18, 2012)
Actuarial Guideline 43/C-3 Phase II Work Group comments to the NAIC C-3 Phase II/AG 43 Working Group regarding their current deliberations. (June 15, 2012)
Annuity Illustration Work Group comments to the NAIC Annuity Disclosure Working Group regarding the latest drafts of the NAIC Annuity Buyer’s Guides distributed on May 15, 2012. (June 15, 2012)
Life Practice Council letter to the NAIC Blanks Committee with comments on blanks proposal 2012-04. (May 14, 2012)
The Academy Life Valuation Subcommittee submitted a comment letter to the NAIC Joint Working Group of the Life Insurance and Annuities (A) Committee and Financial Condition (E) Committee regarding their draft Framework on Actuarial Guideline 38.
(January 30, 2012)
Contingent Annuity Issues Work Group analysis assisting the National Association of Insurance Commissioners in its work involving contingent annuities. (October 28, 2011)
Tax Work Group, in conjunction with the Nonforfeiture Improvement Work Group, follow-up comment letter to the Life Actuarial Task Force with suggested revisions to VM-20. (October 12, 2011)
Tax Work Group in conjunction with the Nonforfeiture Improvement Work Group comment letter to the Life Actuarial Task Force regarding issues associated with proposed language in VM-02. (October 3, 2011)
Invested Assets Working Group comments on the NAIC's Securities Valuation Office staff reports related to the rating agency working group charges. (February 24, 2011)
Annuity Illustration Work Group letter to the National Association of Fixed Annuities with comments in response to its recommendations on the Annuity Disclosure Model Regulation. (February 17, 2011)
Life, Health, and Property/Casualty RBC committees joint report in response to the NAIC's request for assistance with the Solvency Modernization (SMI) project on the NAIC's Risk-Based Capital (RBC) formulas. This report discusses the intended/expected safety levels for RBC and identifies risks that are missing from the RBC formulas. (February 2, 2011)
Life, Health, and Property/Casualty RBC committees joint report in response to the NAIC's request for assistance with the Solvency Modernization (SMI) project on the NAIC's Risk-Based Capital (RBC) formulas. The report discusses the intended/expected safety levels for RBC and identifies risks that are missing from the RBC formulas. (January 31, 2011)
Academy report to the NAIC in response to its request for assistance with the Solvency Modernization project on the NAIC's Risk-Based Capital (RBC) formula. (January 31, 2011)
Annuity Illustration Work Group comment letter regarding the Annuity Disclosure Model Act to the NAIC Annuity Disclosure Working Group. (November 11, 2010)
IAWG Comment Lettter on ACLI Proposal for Commercial Mortgages
Invested Asset Work Group letter to the NAIC Life RBC Working Group regarding the ACLI's Proposal on Risk-Based Capital for Commercial Mortgages. (November 4, 2010)
P/C Risk-Based Capital Committee response to the NAIC's request on risk-based capital issues. (October 1, 2010)
Financial Reporting Committee and Life Financial Reporting Committee comments to FASB on its Proposed Accounting Standards Update, Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities. (September 30, 2010)
Deferred Tax Asset DTA Bridge Group request for an interim report to the NAIC Capital Adequacy Task Force showing the appropriate treatment of the Deferred Tax Asset (DTA) in the Risk-Based Capital formulas for Life, Property / Casualty (P&C), and Health. (September 30, 2010)
Annuity Illustration Work Group letter to the NAIC Annuity Disclosure Working Group explaining their suggestions to the Annuity Disclosure Model Regulation and included a sample illustration. (September 30, 2010)
Risk Management and Solvency Committee comments to the IAIS on its Draft Standard on Group-wide Regulatory Requirements and Guidance on Group-wide Supervision Framework. (August 10, 2010)