U.S. Qualification Standards Request for Comments:
What are seven questions of particular interest?

We are particularly interested in the following questions:
  1. Are there portions of the QS that have prevented otherwise qualified actuaries from practicing in certain areas?  If so, how can the QS be modified to allow those actuaries to practice in certain areas while maintaining proper qualification standards?
  2. Are there existing, new, or emerging practice areas that require new specific qualification standards to ensure that actuaries practicing in those areas are qualified to do so?  If so, what are these areas and what particular standards should be added to any contemplated specific qualifications?
  3. In the current QS, is it clear as to what qualifies as organized, other, professionalism and business activities?  If not, what changes do you suggest that would clarify these categories of the QS?
  4. Should there be a yearly cap on professionalism CEs?  Currently there is a minimum number of professionalism CEs but no maximum.  If capped, what maximum amount do you recommend?
  5. Currently, the QS only apply to actuaries issuing Statements of Actuarial Opinion in the United States, so actuaries providing Actuarial Services without a Statement of Actuarial Opinion are not required to comply with the QS.  Should the QS be expanded to include all Actuarial Services as defined in the Code of Professional Conduct? 
  6. Section 3.1.1 addresses additional basic and continuing educations requirements for actuaries providing NAIC statements of actuarial opinion.  Sections (Life), (Property Casualty) and (Health) each list specific topics for actuaries who issue NAIC opinions as shown in the table below. With regard to these specific qualification standards, should the topics be updated?  If so, what topics do you recommend adding, deleting or changing?
Life and A&H Property and Casualty Health
Policy forms and coverages Policy forms and coverages, underwriting, and marketing Principles of insurance and
Dividends and reinsurance Principles of ratemaking Principles of ratemaking
Investments and valuations of assets and the relationship
between cash flows from assets and related liabilities
Statutory insurance accounting and expense analysis Statutory insurance accounting and expense analysis
Statutory insurance
Premium, loss, and expense reserves Premium, loss, expense, and contingency reserves
Valuation of liabilities Reinsurance Social insurance
Valuation and nonforfeiture laws.    
  1. Are the carryover provisions of the QS understandable or do they need to be clarified?  If so, what is confusing to you and what suggestions do you have in clarifying the requirements?  In addition, should the maximum carryover be reduced so that an actuary will always need to earn some CEs in a given calendar year?  Currently an actuary could carry over a full year’s CE from the prior year resulting in no additional CEs for the current calendar year.  For both of these questions, please address whether your comments apply to general carryover requirements or to specific, organized, professionalism or business requirements.