RMFRC Comments and Letters

Solvency Committee's comments to the International Association of Insurance Supervisor (IAIS) on its concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. These comments further address the methods of operating group-wide supervision of internationally active insurance groups. (August 25, 2011)
Solvency Committee comments to the NAIC on its ComFrame Concept Paper Draft US Responses and supports the position that the modules should be outcome-oriented rather than prescriptive. (August 15, 2011)
Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisor (IAIS) concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. The committee addressed questions presented in the paper relating to Own Risk & Solvency Assessment (ORSA), corporate governance, and Enterprise Risk Management. (July 27, 2011)
Financial Regulatory Reform Task Force letter to the Department of the Treasury outlining the metrics intended to aid in identifying systemic risk in the insurance sector. (June 24, 2011)
Reinsurance Subcommittee letter to the IASB on its Insurance Contracts Exposure Draft regarding recognition of gains and losses on reinsurance ceded for long duration contracts. (April 11, 2011)
Solvency Committee comments to the IAA and additional comments to the NAIC on the IAIS paper, ICP 14: "Valuation for Solvency Purposes." (March 24, 2011)
Solvency Committee comments on the IAIS paper, ICP14: 'Valuation for Solvency Purposes.' (March 24, 2011)
ERM Committee comments to the NAIC on its U.S. Own Risk and Solvency Assessment (ORSA) Proposal. (March 18, 2011)
Financial Regulatory Reform Task Force comments to the Financial Stability Oversight Council on its proposed rule, "Authority to Require Supervision and Regulation of Certain Non-Bank Financial Companies." (February 25, 2011)
Solvency Committee comments to the IAIS on the Financial Stability Board's (FSB) Principles for Reducing Reliance on Credit Rating Agencies (CRA) Ratings document. (February 3, 2011)
ERM Committee comments to the IAIS on its draft paper ICP7: "Corporate Governance." (December 31, 2010)
IFRS Task Force comments to the IASB on its Insurance Contracts Exposure Draft and comments to the FASB on its accompanying discussion paper. (November 30, 2010)
Solvency Committee and ERM Subcommittee comments to NAIC on its Group Capital Assessment Options Paper. (October 11, 2010)
Financial Reporting Committee comments to FASB on its Proposed Accounting Standards Update, Health Care Entities (Topic 954) - "Accounting for Legal Costs Associated with Medical Malpractice and Similar Claims." (October 8, 2010)
ERM Committee response to the NAIC on its consultation paper on Own Risk and Solvency Assessment (ORSA) for the Solvency Modernization Initiative. (October 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)
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)
Financial Reporting Committee and Risk Management and Solvency Committee comments on the June 2010 Primary Considerations to the NAIC Statutory Accounting and Financial Reporting (EX) Subgroup. (August 4, 2010)
Financial Reporting Committee and Life Financial Reporting Committee comments to the IASB concerning its report, "Exposure Draft Financial Instruments: Amortised Cost and Impairment." (June 30, 2010)