RMFRC Comments and Letters

Financial Regulatory Reform Task Force comments to the IAIS on its proposed policy measures that would be applied to insurers whose failure would cause major disruption to the global financial system. (December 14, 2012)
International Accounting Standards Task Force comments to the International Accounting Standards Board on its working drafts, feedback on the premium-allocation approach decisions, feedback on the Non-Insurance Components and on measuring earned premium under the building block approach. (October 9, 2012)
Pension Accounting Committee comments to the Financial Accounting Standards Board (FASB) regarding its proposed Accounting Standards Update: Financial Instruments (Topic 825) – Disclosures about Liquidity Risk and Interest Rate Risk. (October 1, 2012)
Casualty, Life, Health, Professionalism, and Financial Reporting Council comments to the NAIC's Corporate Governance Working Group on its Proposed Responses to a Comparative Analysis of Existing U.S. Corporate Governance Requirements. (September 28, 2012)
Financial Reporting Committee comments to the Financial Accounting Standards Board on its exposure draft regarding liquidity risk and interest rate risk disclosures and how the proposed amendments would affect insurance companies. (September 26, 2012)
Reinsurance Committee comments to the Federal Insurance Office on topics relating to reinsurance, including: the purpose of reinsurance, the effect of domestic and international regulation on reinsurance in the U.S., and the coordination of reinsurance supervision nationally and internationally. (August 27, 2012)
Solvency Committee comments to the IAIS on its Common Framework (ComFrame) paper concerning the relationship between IAIGs and supervisors, and the framework for supervisors to address group-wide activities and risks. (August 16, 2012)
Financial Regulatory Reform Task Force comments to the IAIS on its proposed method to identify insurers whose distress or disorderly failure would cause significant disruption to the global financial system and economic activity. (July 31, 2012)
Solvency Committee comments to the NAIC and IAA on the IAIS ComFrame paper concerning the relationship beween IAIGs and supervisors and the framework for supervisors to address group-wide activities and risks. (July 27, 2012)
Financial Regulatory Reform Task Force comments to the Federal Reserve on its proposed rule establishing additional prudential standards to apply to non-bank financial service companies identified by the Financial Stability Oversight Council as companies that could pose systemic risk. (April 30, 2012)
Risk Management and Financial Reporting Council letter to the Department of Treasury urging that actuarial science be one of the specific considerations for members of the proposed Financial Research Advisory Committee that will support the work of the Office of Financial Research. (April 13, 2012)
Financial Reporting Committee responses to questions posed in FASB's Revenue Recognition paper. (March 13, 2012)
International Accounting Standards Task Force comments on the topic of defining the contract boundary for insurance contracts. (December 21, 2011)
Financial Regulatory Reform Task Force comments to the FSOC on proposed rule relating to systemically important financial institutions. (December 19, 2011)
Financial Regulatory Reform Task Force comments to the FIO on how to modernize and improve the U.S. system of insurance regulation. (December 16, 2011)
ERM Committee comments on wording suggestions to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual recognizing the model risk for insurers. (October 28, 2011)
Financial Reporting Committee and International Accounting Standards Task Force response to the International Accounting Standards Board (IASB) on its Agenda Consultation 2011 paper. (October 27, 2011)
DTA Bridge Group letter to the NAIC relating to the SSAP No. 101 - Income Taxes, A Replacement of SSAP No. 10R and SSAP No. 10 recently adopted by the NAIC’s Statutory Accounting Principles Working Group. (October 25, 2011)
Financial Reporting Committee letter to the Public Company Accounting Oversight Board (PCAOB) on the issues surrounding the auditor’s report based on recent investor feedback. The committee’s comments included a recommendation to increase disclosure and provide more detail to the auditor's reporting model. (September 30, 2011)
ERM Committee comments to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual supporting its view that the manual offers ORSA guidance which focuses on the most fundamental components of a strong ERM framework. (August 25, 2011)