RMFRC Comments and Letters

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)
Financial Regulatory Reform Task Force letter to Congress urging the inclusion of an Office of the Chief Actuary in the Office of Financial Research as Congress was in conference reconciling bills H.R.4173 and S.3217. (June 9, 2010)
Risk Management and Solvency Committee comments to the IAIS on its Guidance Paper on Capital Adequacy for Regulatory Solvency Purposes. (April 30, 2010)
Risk Management and Solvency Committee comments to the IAIS on its Guidance Paper on Capital Adequacy for Regulatory Solvency Purposes. (April 30, 2010)
Regulatory Capital Requirements Task Force response to questions posed in the Consultation Paper on Regulatory Capital Requirements and Overarching Accounting and Valuation Issues for the Solvency Modernization Initiative. (March 1, 2010)
Financial Reporting Committee comments on the recent vote by the IASB and confirmation by the FASB to not permit the recognition of revenue for incremental acquisition expenses upon the initial measurement of an insurance contract. (February 19, 2010)
Life Financial Reporting Committee and Financial Reporting Committee comments on the FASB on exposure draft, Proposed ASU-Financial Services-Insurance (Topic 944): "Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts." (February 12, 2010)
ERM Subcommittee comments on the Basel Committee on Banking Supervision's consultation document, "Recognizing the Risk-Mitigating Impact of Insurance in Operational Risk Modelling." (January 29, 2010)
Risk Management and Solvency Committee comments to the NAIC on its draft paper, United States Insurance Financial Solvency Framework. (December 17, 2009)
Financial Regulatory Reform Task Force comments on H.R. 2609, the Insurance Information Act, and H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009, that recommends including an explicit provision in the legislation to include important professional expertise by creating an Office of the Actuary. (November 24, 2009)