RMFRC Comments and Letters

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)
Financial Reporting Committee comments to the IASB on its Exposure Draft, Fair Value Measurement. (October 1, 2009)
Financial Reporting Committee white paper and notes on the use of discount rates in accounting present value estimates. (September 15, 2009)
Life Financial Reporting Committee and Financial Reporting Committee comments to the IASB on its "Exposure Draft, Financial Instruments: Classification and Measurement." (September 14, 2009)
Financial Reporting Committee comments to the IASB on its Discussion Paper, Credit Risk in Liability Measurement. (September 1, 2009)
Solvency Committee comments to the National Conference of Insurance Legislators (NCOIL) on its credit default insurance model legislation. (July 9, 2009)
Financial Reporting Committee comments to the International Association of Insurance Supervisors (IAIS) on the Draft Issues Paper on the Roles of and Relationship Between the Actuary and the External Auditor in the Preparation and Audit of Financial Reports. (May 15, 2009)
Financial Reporting Committee comments to the FASB on its Discussion Paper, "Preliminary Views on Financial Statement Presentation." (April 14, 2009)
Risk Management and Financial Reporting Council letter to the FDIC regarding a New York Times article in which the FDIC agreed to guarantee billions of dollars in risky loans assuming that those loans represent zero default risk. (April 14, 2009)
Risk Management and Financial Reporting Council response to a New York Times article in which the FDIC agreed to guarantee billions of dollars in risky loans assuming that those loans represent zero default risk. (April 8, 2009)
Financial Reporting Committee response to the joint IASB/FASB Financial Crisis Advisory Group (FCAG) in which FCAG sought input from constituents to discussion questions surrounding accounting and reporting matters related to the financial crisis. (April 1, 2009)
Financial Reporting Committee comments to the Securities and Exchange Commission on the "Roadmap for the Potential Use of Financial Statements Prepared in Accordance with International Financial Reporting Standards by US Issuers." (March 4, 2009)