Life Comments and Letters

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)
Life Products Committee letter to Massachusetts Governor Deval Patrick regarding a bill (HB 889) to allow gender pricing at the Savings Bank Life Insurance Company. (June 4, 2010)
Invested Asset Work Group letter to the Capital Adequacy Task Force regarding the proposed increase to commercial real estate mortgage risk based capital. (June 2, 2010)
Life Practice Council letter to the National Association of Insurance Commissioners (NAIC) (EX) Working Group and Life Insurance and Annuities (A) Committee on principles-based valuation and capital approach (PBA) for life insurance. (May 12, 2010)
Life Financial Reporting Committee and Financial Reporting Committee comments on the FASB on exposure draft, Proposed ASU-Financial Services-Insurance (Topic 944): "Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts." (February 12, 2010)
Response from the LRWG on New York Insurance Department’s proposed changes to the use of economic scenarios in VM-20 (December 3, 2009)
Annuity Illustration Work Group letter to the Annuity Disclosure Working Group with more suggested revisions to an ACLI proposal for a model annuity illustration. (November 6, 2009)
Annuity Illustration Work Group comment letter to the NAIC Annuity Disclosure Working Group with suggested revisions to the ACLI model proposal. (September 14, 2009)