The P&C Committee on Equity and Fairness submitted comments to the Colorado Division of Insurance (DOI) on the exposed template of the DOI’s upcoming data call on private passenger auto insurance as part of the implementation of CO SB21-169 – Protecting Consumers from Unfair Discrimination in Insurance Practices.

Vice presidents of the Academy’s Casualty Practice Council, Health Practice Council, Life Practice Council, and Risk Management and Financial Reporting Council provided comments to the NAIC’s newly established Risk-Based Capital (RBC) Model Governance (EX) Task Force on the task force’s 2025 goals and proposed charges.

The Casualty Practice Council submitted comments to the Actuarial Standards Board (ASB) on the exposure draft of Actuarial Standard of Practice (ASOP) No. 30, Profit Margins and Contingency Provisions in Property/Casualty Risk Transfer and Risk Retention.

The Extreme Events and Property Lines Committee submitted comments to the Federal Emergency Management Agency on their RFI on the redesign effort of the National Flood Insurance Program’s Community Rating System.

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 recently released draft market conduct study, Evaluating Unintentional Bias in Private Passenger Automobile Insurance.

The Casualty Practice Council submitted comments on the exposure draft of Actuarial Standard of Practice (ASOP) No. 7, Analysis of Life, Health, or Property/Casualty Insurance Cash Flow Risk.

The Casualty Practice Council submitted comments on the exposure draft of Actuarial Standard of Practice (ASOP) No. 12, Risk Classification (for All Practice Areas).

The P/C Extreme Events and Property Lines Committee submitted a comment letter to the California Department of Insurance in advance of the department’s public workshop on its draft regulation that would modify state law to allow for catastrophe modeling to be used for wildfire, terrorism, and flood lines of homeowners and commercial insurance lines.

The Academy’s Health, Life, and Casualty practice councils submitted comments on New York State Department of Financial Services’ proposed insurance circular letter on the use of Artificial Intelligence Systems (AIS) and External Consumer Data and Information Sources (ECDIS) in insurance underwriting and pricing. The councils support efforts to curb underwriting and pricing methods that “reflect systemic biases and can reinforce and exacerbate inequality.”

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.