RMFRC Comments and Letters

Solvency Committee comments to the International Association of Insurance Supervisors on the Risk-based Global Insurance Capital Standard public consultation document dated Dec. 17, 2014. (February 6, 2015)
Financial Reporting Committee comments to the International Accounting Standards Board (IASB) on its treatment of participating contracts in its insurance contracts project in follow-up to a November conference call. (December 23, 2014)
Financial Regulatory Task Force comments to the Government Accountability Office (GAO) on its global capital standards report. (December 16, 2014)
Risk Management and Financial Reporting Council comments to the Financial Stability Board (FSB) on the consultative document: Recovery and Resolution Planning for Systemically Important Insurers: Guidance on Identification of Critical Functions and Critical Shared Services. (December 15, 2014)
Solvency Committee comments to the National Association of Insurance Commissioners on the U.S. Group Capital Methodology Concepts Discussion Paper. (December 5, 2014)
Solvency Committee comments to members of the U.S. House of Representatives and the U.S. Senate in support of passage of the Insurance Capital Standards Clarification Act of 2014, which clarifies that the Federal Reserve has the authority to differentiate between banks and insurers in terms of capital requirements. (December 2, 2014)
Financial Reporting Committee comments to the Financial Accounting Standards Board on its disclosure requirements for short duration contracts. (November 21, 2014)
Reinsurance Committee comments to the International Accounting Standards Board on the Insurance Contracts Project's reinsurance and ceding commissions proposal. (November 20, 2014)
Reinsurance Committee comments to the National Association of Insurance Commissioners on the Uniform Application Checklist for Certified Reinsurers exposure draft. (November 11, 2014)
Financial Regulatory Task Force comment letter to the Financial Stability and Oversight Council on the importance of actuaries in financial and insurance systems, and its perspective on updates to actuarial standards and guidance. (November 3, 2014)
Financial Reporting Committee comments to the Public Company Accounting Oversight Board on the draft Auditing Accounting Estimates and Fair Value Measurements staff consultation paper. (October 31, 2014)
Financial Reporting Committee comments to the International Accounting Standards Board (IASB) and Financial Accounting Standards Board (FASB) on the IASB's Accounting for Dynamic Risk Management: a Portfolio Revaluation Approach to Macro Hedging discussion paper. (October 17, 2014)
Solvency Committee comments to the National Conference of Insurance Legislators on the key priorities and principles that should be considered when developing insurance group solvency and capital standards. (October 10, 2014)
Solvency Committee comments to the National Association of Insurance Commissioners on the key priorities and principles that should be considered when developing insurance group solvency and capital standards. (September 18, 2014)
Reinsurance Committee comments to the NAIC's Reinsurance (E) Task Force on the exposure draft, Securities Listed by the Securities Valuation Office, that specifically address the security provided for the purpose of collateralizing reinsurance obligations. (September 5, 2014)
Financial Reporting Committee letter to the International Accounting Standards Board on the treatment of participating contracts within the IFRS Foundation's insurance contracts project that includes discussions on book-yield and effective-yield approaches. (September 2, 2014)
Solvency Committee comments to the National Association of Insurance Commissioners on the International Association of Insurance Supervisors' revised proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (August 4, 2014)
Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors' revised proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (August 4, 2014)
ORSA Subgroup comments to the NAIC's Risk-Focused Surveillance Working Group on the second exposure draft of ORSA guidance, which will be included in the Financial Analysis Handbook and the Financial Condition Examiners Handbook. (July 22, 2014)
Financial Reporting Committee letter to the Financial Accounting Standards Board on its insurance contracts project, encouraging convergence for long-duration contracts but also highlighting issues that may need to be addressed if targeted improvements instead of the building block approach are pursued. (June 30, 2014)