Public Policy Comments and Letters

Letter on Implementation of MAP-21 Pension Provisions

Pension Committee letter to Department of Treasury officials regarding the implementation of MAP-21 pension provisions. Attached to the letter is an outline of topics discussed by several Pension Committee members at a meeting with Treasury on July 23. (August 2, 2012)

Letter to Sen. Hatch on State, Local Government Defined Benefit Pension Plans

Pension Practice Council letter to Sen. Orrin Hatch responding to a January 10, 2012 report entitled “State and Local Government Defined Benefit Pension Plans: The Pension Debt Crisis that Threatens America.” (July 31, 2012)

Comments on Proposed Assessment Methodology for Global Systemically Important Insurers

Financial Regulatory Reform Task Force comments to the IAIS on its proposed method to identify insurers whose distress or disorderly failure would cause significant disruption to the global financial system and economic activity. (July 31, 2012)

Comments on ComFrame Draft for Supervision of Internationally Active Insurance Groups

Solvency Committee comments to the NAIC and IAA on the IAIS ComFrame paper concerning the relationship beween IAIGs and supervisors and the framework for supervisors to address group-wide activities and risks. (July 27, 2012)

LPC Comment Letters to NAIC on Valuation Manual

Comment letters to both the NAIC Life Actuarial Task Force and the Life and Annuities (A) Committee from the Academy's Life Practice Council and Life Financial Reporting/Risk Management Committee regarding the need for changes to the valuation manual as well as a formal updating and review process. (July 16, 2012)

Comments to ASB on ASOP 6 Exposure Draft

Joint Committee on Retiree Health comments on the ASB's exposure draft of ASOP 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Plan Costs or Contributions. (July 14, 2012)

Letter to SMI RBC Subgroup on CAS Working Party Activity

P/C Risk-Based Capital Committee letter to Solvency Modernization Initiative RBC Subgroup concerning CAS Working Party research on potential improvements to the NAIC's P/C RBC framework. (July 10, 2012)

Comments on Impact of Stop-Loss Insurance Under ACA

Stop-Loss Work Group comments to the Employee Benefits Security Administration regarding stop-loss insurance and the Affordable Care Act (ACA). (July 2, 2012)

Pension Committee Letter to SOA on Scale BB

Pension Committee letter to the SOA regarding a new set of mortality tables and projection scales for the valuation of uninsured pension plans. (June 30, 2012)

Comment Letter on Comprehensive Flood Reform Bill

Flood Insurance Subcommittee comment letter to Congressional leaders concerning H.R. 4348, a bill to reform the National Flood Insurance Program and reauthorize it for five years. (June 28, 2012)

Comment Letter to NAIC Valuation of Securities Task Force

Invested Asset Work Group comments to the NAIC Valuation of Securities (E) Task Force related to modification of the methodology for assigning classifications to investments and changing how classification decisions are implemented. (June 20, 2012)

VM-20 Amendment Proposal on Mortality

Life Financial Soundness/Risk Management Committee presentation of NAIC's Life and Health Actuarial Task Force Amendment proposal outlining a simplified approach for determining prudent estimate mortality assumption for VM-20. (June 18, 2012)

C-3 Phase II/AG43 Comment Letter

Actuarial Guideline 43/C-3 Phase II Work Group comments to the NAIC C-3 Phase II/AG 43 Working Group regarding their current deliberations. (June 15, 2012)

NAIC Annuity Buyer's Guides Comment Letter

Annuity Illustration Work Group comments to the NAIC Annuity Disclosure Working Group regarding the latest drafts of the NAIC Annuity Buyer’s Guides distributed on May 15, 2012. (June 15, 2012)

Comment Letter to CMS on Medicaid Payment Rate Change

Medicaid Work Group comments to CMS on a proposed rule regarding payments for Medicaid primary care services. (June 12, 2012)

Comment Letter to IRS on Minimum Value

Actuarial Value Subgroup comments to the IRS on Notice 2012-31, Minimum Value of an Employer Sponsored Health Plan, addressing how to account for non-core benefits and non-standard plan features as well as other considerations related to the treatment of health savings account (HSA) contributions. (June 11, 2012)

Comments to ASB on ASOP 4 Exposure Draft

Joint Committee on Retiree Health comments on the ASB's exposure draft for ASOP 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions, requesting clarification on the implications for retiree group benefits. (May 31, 2012)

Comments to ASB on ASOP 27 Exposure Draft

Joint Committee on Retiree Health comments on the ASB's exposure draft for ASOP 27, Selection of Economic Assumptions for Measuring Pension Obligations, regarding the implications for retiree group benefits. (May 31, 2012)

Letter on Proposed Revision to ASOP No. 27

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. (May 31, 2012)

Letter on Proposed Revision to ASOP No. 4

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)