The Life Underwriting and Risk Classification Subcommittee submitted additional comments to the Colorado Division of Insurance on the ACLI draft proposed quantitative testing 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 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 Life Underwriting and Risk Classification Subcommittee submitted comments to the NAIC's Special (EX) Committee on Race and Insurance Life Workstream on the July 17 Exposure of the Survey of Life Insurer Underwriting Guidelines as Applied to Justice Impacted Individuals. 

The Data Science and Analytics Committee commented to the U.S. Department of the Treasury on the Request for Information (RFI) on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector.

The Long-Term Care (LTC) Committee submitted comments to the NAIC’s Long-Term Care Actuarial (B) Working Group (LTCAWG) in response to LTCAWG's July 2 request for comments on the Minnesota approach. 

The Life Practice Council provided comments to the Life Actuarial Task Force (LATF) regarding LATF's “Reinsurance AAT Concepts" and "Reinsurance AAT Attribution Analysis" exposures. 

The Life Underwriting and Risk Classification Subcommittee commented to the Colorado Division of Insurance on the ACLI draft proposed quantitative testing 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 Retirement Practice Council’s Social Security and Retirement Policy and Design Evaluation committees sent a joint comment letter to the Senate Committee on Health, Education, Labor and Pensions regarding portable benefits for self-employed workers and other individuals in nontraditional working arrangements.

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 Health Practice Council’s Active Benefits Committee and Individual and Small Group Markets Committee responded to the U.S. Senate Committee on Health, Education, Labor and Pensions’ (HELP) request for information regarding portable benefits for self-employed workers and other individuals in nontraditional working arrangements.

The Prudential Regulation Committee submitted comments to the International Association of Insurance Supervisors (IAIS) on its public consultation on climate risk supervisory guidance – ICP guidance and supporting material.

The Academy's C1 Subcommittee provided comments to the NAIC's Risk-Based Capital Investment Risk and Evaluation (E) Working Group on the exposed interim residual tranche proposal by Everlake Life Insurance Company.

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 Prudential Regulation Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Capital Adequacy (E) Task Force on the exposure draft of Risk-Based Capital Preamble, 2024-16-CA.

The ERM/ORSA Committee submitted comments to the Actuarial Standards Board regarding the proposed revision of Actuarial Standard of Practice (ASOP) No. 7, Analysis of Life, Health, or Property/Casualty Insurance Cash Flow Risk.

The Retirement Practice Council and Pension Committee responded to a request for information (RFI) by the majority staff of the U.S. Senate Health, Education, Labor, and Pensions (HELP) Committee regarding ways to bolster the defined benefit pension system.

The Asset Adequacy and Reinsurance Issues Task Force provided comments to the Life Actuarial Task Force (LATF) regarding LATF's “AAT Reinsurance Exposure 031724” document. 

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 Variable Annuity Reserves and Capital Subcommittee sent comments to the NAIC’s Variable Annuities Capital and Reserve (E/A) Subgroup on the exposure draft of APF 2024-07 that proposes updates to the VM-21 Standard Projection Amount assumptions.

The Pension Committee submitted comments to the Actuarial Standards Board regarding the proposed revision of Actuarial Standard of Practice (ASOP) No. 12, Risk Classification (for All Practice Areas).

The Health 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 C1 Subcommittee commented on the Oliver Wyman report on Asset-Backed Securities Residual Tranches that was exposed at the NAIC Spring National Meeting to the NAIC's Risk Based Capital Investment Risk and Evaluation (E) Working Group. 

The Financial Reporting Committee and the Life GAAP Reporting Committee sent a comment letter to the Financial Accounting Standards Board (FASB) on the exposure draft of Chapter 6: Measurement, of Concepts Statement No. 8, Conceptual Framework for Financial Reporting.

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 Variable Annuity Reserve and Capital Subcommittee commented to the NAIC’s Life Actuarial (A) Task Force on the order of operations between the interest maintenance reserve (IMR) and cash surrender value (CSV) floor in the VM-21 reserve calculation.

The Prudential Regulation Committee submitted comments to the International Association of Insurance Supervisors (IAIS) on its consultation draft application paper on climate risk scenario analysis in the insurance sector.

The Annuity Reserve and Capital Subcommittee commented to the NAIC’s Valuation Manual (VM)-22 (A) Subgroup of the Life Actuarial (A) Task Force on the Nov 2023 exposure of VM-31, VM-G, and the VM-22 PBR Supplement Blank.

The Health Practice Council’s Individual and Small Group Markets Committee and Active Benefits Committee responded to the DOL’s Employee Benefits Security Administration’s proposed rule on Association Health Plan’s definition of employer.

The Economic Scenario Generator Subcommittee submitted comments to the Life Actuarial Task Force (LATF) on the Dec 12 exposure of the updated Generator of Economic Scenarios (GOES) Targeting Criteria and Evaluation Statistics.