The Committee on Property and Liability Financial Reporting, submitted a comment letter to the Actuarial Standards Board (ASB) on the second exposure draft of ASOP no. 36, Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves.

The Life Practice Council and Casualty Practice Council submitted comments to the Colorado Division of Insurance on its draft regulation, Concerning Quantitative Testing of External Consumer Data and Information Sources, Algorithms, and Predictive Models Used for Life Insurance Underwriting for Unfairly Discriminatory Outcomes. The comments reiterated support for Colorado’s initiative to prevent unfairly discriminatory practices in insurance and shared actuarial perspectives related to the design of the data testing requirement.   

P/C Committee on Equity and Fairness Chairperson Lauren Cavanaugh and Vice Chairperson Susan Kent presented at the Colorado Division of Insurance’s stakeholder meeting on Unfair Discrimination in Insurance Practices, focusing on private passenger auto insurance. They cited key points, illustrative examples, and the committee’s February issue brief, Approaches to Identify and/or Mitigate Bias in Property and Casualty Insurance.

The P/C Extreme Events and Property Lines Committee submitted a comment letter to the California Department of Insurance for the Department's upcoming public workshop on Catastrophe Modeling and Insurance. 

The Committee on Property Liability and Financial Reporting (COPLFR) submitted a comment letter to the Internal Revenue Service (IRS) on an exposure on Micro-Captive Listed Transactions and Micro-Captive Transactions of Interest. 

The Casualty Practice Council submitted a comment letter to the Actuarial Standards Board (ASB) on the second exposure draft of ASOP No. 29, Expense Provisions in Property/Casualty Insurance Ratemaking.

The Committee on Property Liability and Financial Reporting (COPLFR) submitted a comment letter to the National Association of Insurance Commissioners (NAIC) Casualty Actuarial and Statistical (C) Task Force proposing a modification to the Annual Statement blank that would eliminate the distinction between “short-tailed” and “long-tailed” lines of business in Schedule P.

The Committee on Property Liability and Financial Reporting (COPLFR) and the Health Practice Council’s Committee on Financial Reporting and Solvency submitted a comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed exposure to add instructions for the appointed actuary and qualified actuary contacts to the Jurat electronic only section in order to address any actuarial questions.

The Life Practice Council, Health Practice Council, and Casualty Practice Council submitted a joint comment letter to the Colorado Division of Insurance on its recent exposure of a draft regulation on Governance and Risk Management Framework Requirements for Life Insurance Carriers’ Use of External Consumer Data and Information Sources, Algorithms, and Predictive Models: the first exposed implementation regulation for Colorado Revised Statute (C.R.S.) § 10-3-1104.9, signed into law on July 6, 2021.

The Life Practice Council and the Casualty Practice Council submitted a joint comment letter to the National Association of Insurance Commissioner’s Big Data and Artificial Intelligence (H) Working Group on its Artificial Intelligence/Machine Learning Model and Data Regulatory Questions Exposure.

The P/C Committee on Equity and Fairness sent a comment letter to the District of Columbia Department of Insurance, Securities and Banking (DISB) on the DISB’s request for comment on its draft data call to support their study of unintentional bias in automobile insurance.

Committee on Cyber Risk comments to the U.S. Department of the Treasury and Federal Insurance Office (FIO) request for comment (RFC) on cyber insurance and catastrophic cyber incidents in order to inform a joint assessment being conducted by the Department of the Treasury's Federal Insurance Office (FIO) and the Department of Homeland Security's Cybersecurity and Infrastructure Security Agency (CISA). 

Comment letter from the Casualty Practice Council, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP 41, Actuarial Communications.

Comment letter from the Casualty Practice Council, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP 20, Discounting of Property/Casualty Unpaid Claim Estimates.

Comment letter from the Committee on Property and Liability Financial Reporting, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP 36, Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves.

The Casualty Practice Council submitted written comments to the Washington, D.C. Department of Insurance, Securities and Banking's (DISB) Request for Comments on evaluating unintentional bias in private passenger automobile insurance. The letter expanded on the Academy's previous comments to the DISB on recommended actuarial considerations for determining unintentional bias in auto insurance. 

The Casualty Practice Council submitted written comments following the Washington, D.C. Department of Insurance, Securities and Banking (DISB) on their hearing, "Initiative to Evaluate Unintentional Bias in Private Passenger Automobile Insurance." The letter expanded on the Academy's verbal presentation on the recommended actuarial considerations for determining unintentional bias in auto insurance. 

Comment Letter to the Senate Banking, Housing and Urban Affairs on NFIP

Comment letter from the Casualty Practice Council, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP No. 29, Expense Provisions.

Extreme Events Committee comments to the House Financial Services Subcommittee on Housing, Community Development, and Insurance on the committee's proposed reauthorization and reforms of the National Flood Insurance Program, in advance of the congressional hearing.