RMFRC Comments and Letters

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)
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)
Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisors' (IAIS) Memo on a proposed approach for a global insurance capital standard. (June 6, 2014)
Solvency Committee comments to members of the U.S. House of Representatives supporting passage of the Insurance Capital Standards Clarification Act of 2014 (S.2270/H.R.4510), which clarifies that the Fed has the authority to differentiate between banks and insurers in terms of capital requirements. (June 5, 2014)
Risk Management and Financial Reporting Council comments to NCOIL's International Issues Task Force with recommendations on three international priorities that NCOIL should address in 2014. (June 2, 2014)
ORSA Subgroup comments to the NAIC's Risk-Focused Surveillance Working Group on draft ORSA guidance that will be included in the Financial Analysis Handbook and the Financial Condition Examiners Handbook. (May 16, 2014)
ORSA Subgroup comments to the NAIC on its Guidance Manual for the Own Risk and Solvency Assessment (ORSA), noting that revisions made in the March 2014 draft provides clarity for those developing ORSA reports. (March 5, 2014)
Financial Reporting Committee letter to the Financial Accounting Standards Board on proposed wording to clarify the methodology used in determining the "top down" discount rate. (February 12, 2014)
ERM Committee comments to the Financial Stability Board on its proposal, Guidance on Supervisory Interaction with Financial Institutions on Risk Culture.
(January 30, 2014)
Solvency Committee comments to the National Association of Insurance Commissioners on the International Association of Insurance Supervisors’ proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (January 28, 2014)