Public Policy Comments and Letters

Letter to IPSASB on Exposure Draft 31, Employee Benefits

Public Plans Task Force letter to the International Public Sector Accounting Standards Board (IPSASB) regarding Exposure Draft (ED) 31, Employee Benefits. (February 28, 2007)

Comment Letter to House and Senate on Restricting Insurers' Use of Genetic Information

Health Practice Council comment letter to members of the House and Senate on the actuarial implications of restricting insurers' use of genetic information. (February 16, 2007)

Comments on IAIS paper 'Common Structure for the Assessment of Insurer Solvency'

Risk Management and Solvency Committee comments on a 2007 version of an IAIS paper regarding a common structure for insurer solvency assessment. (January 5, 2007)

Comments on One-Role-per-User Rule for Medicare RDS Website

Health Practice Council comments that urge CMS to reconsider the one-role-per-user rule for actuaries for Part D attestations and to investigate alternatives that would not prevent actuaries from fulfilling their actuarial obligations. (December 19, 2006)

Updated Draft Actuarial Guidelines on Reserve Documentation and Disclosure

Life Reserves Work Group update on draft actuarial guidelines on reserve documentation and disclosure. (December 1, 2006)

Updated Actuarial Guideline PBR-VAL from LRWG

Updated Actuarial Guideline PBR-VAL from the Life Reserves Work Group presented to the National Association of Insurance Commissioners’ Life and Health Actuarial Task Force. (December 1, 2006)

Draft Model Regulation on Life Reserving Update

Life Reserves Work Group update of draft model regulation on principle-based life reserving. (December 1, 2006)

Summary of Changes in AG DIS, AG PBR-VAL and Life Reserving

Life Reserves Work Group summary of changes made in all three documents: AG DIS, AG PBR-VAL, and draft model regulation on principle-based life reserving. (December 1, 2006)

Comment Letter to State Regulators on Florida Travel Underwriting

Life Products Committee comment letter to state insurance regulators on Florida travel underwriting rule. (December 1, 2006)

Comments on ACLI's Proposed Long-Term Care Experience Form

Subgroup on Long-Term Care Experience Forms comments to the NAIC regarding American Council of Life Insurers (ACLI) Proposed Recommendation to Report Non-Exempt LTC accelerated-type products. (November 17, 2006)

Comments to IRS and Treasury on Substitute Mortality Tables

Pension Committee discussion paper to the Internal Revenue Service (IRS) and Department of the Treasury regarding the use of substitute mortality tables. (November 6, 2006)

Comments on IAIS Paper on Common Structure for Insurer Solvency Assessment

Risk Management and Solvency Committee comments to the IAIS on its paper "Common Structure for the Assessment of Insurer Solvency." (November 1, 2006)

LPC Paper for Testimony at NAIC Hearing on Considering Travel Destination in Life Underwriting

Life Products Council paper supporting a move to a principles-based system to the NAIC's Life Insurance and Annuities Committee regarding the travel underwriting issue. (September 9, 2006)

Letter to DOL on Proposed Addition of Asset-Related Question to Form 5500

Pension Committee letter to the Department of Labor (DOL) expressing objections to the proposed addition of an asset information question to Form 5500 Schedule B. (September 4, 2006)

Letter to Congress on Nonadmitted and Reinsurance Reform Act of 2006 (H.R. 5637)

Risk Management and Financial Reporting Council letter to congressional leaders on the legislative definition of a qualified risk manager under Nonadmitted and Reinsurance Reform Act of 2006 (H.R. 5637). (September 1, 2006)

Updated Draft Actuarial Guidelines to NAIC Life and Health Actuarial Task Force

Life Reserve Work Group updated draft actuarial guidelines on reserve documentation and disclosure (AG DIS), on life valuation assumptions (AG PBR-VAL), updated draft model regulation on principle-based life reserving, and summary of changes to the NAIC's Life and Health Actuarial Task Force. (September 1, 2006)

PBRGWG Presentation on Draft Model Regulation on Principle-Based Peer Review

Principle-Based Review and Governance Work Group draft model regulations to the NAIC's Life and Health Actuarial Task Force regarding principles-based valuation review opinions. (September 1, 2006)

Report on Short-Term Changes Needed in Standard Nonforfeiture Law

Life Products Committee report to the NAIC's Life and Health Actuarial Task Force on short term changes needed to the standard nonforfeiture laws. (September 1, 2006)

Report on Principle-Based Reserves for Non-Variable Annuities

Annuity Reserve Work Group report to the NAIC's Life and Health Actuarial Task Force regarding principle-based reserves for non-variable annuities. (September 1, 2006)

Letter to IRS on Requests for Technical Guidance on Circular 230

Pension Practice Council letter to the Internal Revenue Service (IRS) requesting technical guidance on regulatory issues related to IRS Circular 230. (August 29, 2006)