Public Policy Comments and Letters

Comments on Proposed Accounting Standards Update Revenue Recognition

Financial Reporting Committee responses to questions posed in FASB's Revenue Recognition paper. (March 13, 2012)

Comments on Increasing Flexibility for Elections to Reduce Funding Balances

Pension Committee letter to the Internal Revenue Service and Department of the Treasury addressing elections to reduce funding balances for defined benefit pension plans. (February 16, 2012)

Actuarial Perspective on Death, Disability, and Retirement Extended Reporting Endorsement

Medical Professional Liability Insurance Committee fact sheet on the Death, Disability, and Retirement (DDR) Extended Reporting Endorsement. (February 15, 2012)

Comments to CMS on MLR Reporting Form

Medical Loss Ratio (MLR) Work Group comments to CMS on the exposure draft of the MLR annual reporting form. (February 14, 2012)

Second Health Practice Council Letter to Arizona Insurance Department

Health Practice Council and Committee on Qualifications letter to the Arizona insurance director stressing its concern that their regulatory definition of “qualified actuary” for health premium rate actuarial certifications was inappropriate and suggested corrective language. (February 10, 2012)

Letter to HHS on Essential Health Benefits Bulletin

Individual and Small Group Market Task Force comments to the HHS on the essential health benefits bulletin. (January 31, 2012)

Letter to HHS on Research Brief Addressing Actuarial Value

Health Practice Council letter to the Assistant Secretary for Planning and Evaluation (ASPE) at HHS providing comments on a research brief, Actuarial Value and Employer-Sponsored Insurance. (January 31, 2012)

Academy LVS submits comments on AG 38 Framework

The Academy Life Valuation Subcommittee submitted a comment letter to the NAIC Joint Working Group of the Life Insurance and Annuities (A) Committee and Financial Condition (E) Committee regarding their draft Framework on Actuarial Guideline 38.
(January 30, 2012)

Comments on Application of IRC Section 415(b) Limits

Pension Committee letter to the Internal Revenue Service and Department of the Treasury concerning differing interpretations in the application of IRC Section 415(b) limits and requesting guidance. (January 30, 2012)

Comments on Defining Contract Boundary for Insurance Contracts

International Accounting Standards Task Force comments on the topic of defining the contract boundary for insurance contracts. (December 21, 2011)

Comments on Proposed Rule on Systemically Important Financial Institutions

Financial Regulatory Reform Task Force comments to the FSOC on proposed rule relating to systemically important financial institutions. (December 19, 2011)

Comments to FIO on Modernizing and Improving U.S. System of Insurance Regulation

Financial Regulatory Reform Task Force comments to the FIO on how to modernize and improve the U.S. system of insurance regulation. (December 16, 2011)

Letter to NAIC Regarding Accounting for Pension Benefits and OPEBs

Pension Accounting Committee and Joint Committee on Retiree Health letter to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. (December 9, 2011)

Joint Comments to NAIC on Exposure Drafts of SSAPs No. 92 and No. 102

Pension Accounting Committee and Joint Committee on Retiree Health comment letter to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. (December 6, 2011)

Letter to Massachusetts Senate on Amendment to H.3535

Premium Review Work Group letter to the Massachusetts Senate regarding an amendment to the state budget that would require the disapproval of any health insurance rates to be supported by "sound actuarial assumptions and methods." (November 30, 2011)

Committee Letter to Arizona Insurance Department

Health Practice Council and Committee on Qualifications letter to the Arizona insurance director pointing out that their regulatory definition of “qualified actuary” for health premium actuarial certifications was inappropriate and suggested corrective language. (November 18, 2011)

PBGC Response to Pension Committee’s Inquiry

PBGC response to the Pension Committee’s Oct. 14 inquiry regarding instructions on the Schedule H (Form 5500). (November 2, 2011)

Letter to NAIC on Progress of Academy/SOA Cancer Claims Cost Tables Work Group

Cancer Claims Cost Tables Work Group letter to the NAIC’s Health Actuarial Task Force discussing the progress it has made over the past year and outlining its objectives for the coming year. (October 31, 2011)

Comment Letter on Proposed Rule Related to Reinsurance, Risk Corridors, and Risk Adjustment

Risk Sharing Work Group comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule implementing the risk-spreading mechanisms included in the Affordable Care Act (ACA) and related to reinsurance, risk corridors, and risk adjustment. (October 28, 2011)

Comments on NAIC ORSA Guidance Manual

ERM Committee comments on wording suggestions to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual recognizing the model risk for insurers. (October 28, 2011)