Casualty Comments and Letters

Letter from Academy Past President Mary D. Miller to NAIC with comments on CASTF’s draft 3-year experience proposal. (November 8, 2018)
Committee on Property and Liability Financial Reporting letter offering comments on the California Department of Insurance’s proposed changes to reporting requirements for large deductibles in workers’ compensation plans. (August 10, 2018)
Academy Past President Mary D. Miller on Friday submitted a comment letter from the Academy to the NAIC regarding the Casualty Actuarial and Statistical Task Force’s exposure draft related to the three-year experience requirement to sign statutory statements. In those comments Miller shared the Academy’s view that the exposure draft describes an approach that will neither clarify nor improve the current requirement. (August 10, 2018)
Letter from Past Academy President Mary D. Miller with comments from the Academy to the National Association of Insurance Commissioners raising several concerns over a revised attestation proposal released for exposure on June 25 by the NAIC’s Casualty Actuarial and Statistical Task Force (CASTF). (July 25, 2018)
Letter from Past Academy President Mary D. Miller with extensive comments from the Academy to the NAIC responding to an exposure draft that the Casualty Actuarial and Statistical Task Force (CASTF) issued on a CAS/SOA proposal regarding CASTF’s “Continued Competence” charge. This is a significant proposal that would affect many actuaries. Comments are due by Monday, July 23. Those interested may wish to consider filing their own comments.
(July 20, 2018)
Extreme Events & Property Lines Committee questions for regulators on private flood insurance, focusing on regulatory issues for consideration as flood insurance coverage moves from a federal program to private coverage, for NAIC review. (July 20, 2018)
Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force exposure draft containing potential changes to the P/C Statement of Actuarial Opinion Instructions to address the CASTF’s “Attestation” charge. (May 11, 2018)
Comment letter from  Senior Casualty Fellow Kevin Ryan to the International Association of Insurance Supervisors on climate change risks to the insurance sector. (April 27, 2018)
Workers’ Compensation Committee discussion of comparisons between states of workers’ comp rates. (March 16, 2018)
Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force’s (CASTF) exposure draft on the appointed actuary’s public attestation and supporting confidential documentation. (March 7, 2018)
Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force’s (CASTF) request for comments on the three-year experience period—seeking proposals. (March 7, 2018)
COPLFR letter to the NAIC's Casualty Actuarial and Statistical Task Force, with survey findings regarding reports for currency conversion and intercompany quotashare pooling. (February 15, 2018)
Casualty Practice Council letter to the U. S. House of Representatives on pending flood insurance legislation. (November 8, 2017)
Committee on Property and Liability Financial Reporting comment letter to NAIC's Actuarial Opinion Working Group on the impact of life insurance Valuation Manual changes on P/C insurers' Statements of Actuarial Opinion that include accident and health (A&H) and long-term care (LTC) lines of business. (October 18, 2017)
The Committee on Property and Liability Financial Reporting’s comment letter to the NAIC’s Statutory Accounting Working Group, questioning the proposed new definition of reinsurance risk transfer in SSAP No. 62R: Property and Casualty Reinsurance. (October 4, 2017)
Casualty Practice Council comment letter to members of the U.S. House of Representatives urging reauthorization and revision of the National Flood Insurance Program. (August 30, 2017)
Casualty Practice Council comment letter to the U.S. Senate Committee on Banking, Housing, and Urban Affairs urging reauthorization and revision of the National Flood Insurance Program. (August 23, 2017)
Comment letter submitted jointly by the P/C RBC Committee and the Health Solvency Subcommittee regarding changes to corporate bond factors being considered by the NAIC’s Investment Risk-Based Capital Working Group. (July 25, 2017)
COPLFR's comment letter to the NAIC's Title Insurance Financial Reporting Working Group regarding proposed changes to reporting of reserves in the title statement of actuarial opinion (July 14, 2017)
Casualty Practice Council comments on the ASB's third exposure of the proposed Actuarial Standards of Practice (ASOP), Estimating Future Costs for Prospective Property/Casualty Risk Transfer and Risk Funding. (April 27, 2017)