RMFRC Comments and Letters

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)
Academy President Tom Terry’s letter to the Federal Insurance Office urging it to include actuaries on the expanded Federal Advisory Committee on Insurance. (January 28, 2014)
Financial Reporting Committee comments to the Financial Accounting Standards Board and International Accounting Standards Board regarding their joint project on classification and measurement of financial instruments.

(January 16, 2014)
Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors’ proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs).
(January 16, 2014)
Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors’ paper, Common Framework for the Supervision of Internationally Active Insurance Groups.
(November 22, 2013)
International Accounting Standards Task Force comment letter to the International Accounting Standards Board on its revised exposure draft, Insurance Contracts. (October 24, 2013)
International Accounting Standards Task Force comment letter to the Financial Accounting Standards Board on its revised exposure draft, Insurance Contracts.
(October 24, 2013)
The Financial Regulatory Reform Task Force comments to the Financial Stability Board on its paper, “Comments on Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions.” (October 18, 2013)
The Financial Regulatory Reform Task Force comments to the Financial Stability Board on its paper, “Comments on Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions.” (October 18, 2013)
The Enterprise Risk Management Committee comments to the Financial Stability Board on its paper, “Principles For an Effective Risk Appetite Framework.” (September 30, 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)
International Accounting Standards Task Force papers on issues related to the Insurance Contracts project discussed at a November 2012 meeting with FASB staff. (March 5, 2013)