Public Policy Comments and Letters

Committee comments on proposed legislation to add a long-term care benefit to the Medicare program, evaluating in terms of financing, benefits, and coordination with other programs. (June 15, 2018)
Life Reserves Work Group revised APF 2018-17 in response to comments recieved on the original version of the APF.  (June 11, 2018)
Life Operational Risk Work Group comment letter to NAIC on prospective operational risk growth charge for Life RBC Formula.
(June 6, 2018)
RBC Tax Reform Work Group comment letter to NAIC on the rounding of C-2 life insurance RBC factors and life RBC charges for certain health insurance coverages.  (June 4, 2018)
Life Products Committee comment letter to NAIC on exposed Actuarial Guideline, Application of Section 6 of the Standard Nonforfeiture Law for Individual Deferred Annuities Model 805.  (May 29, 2018)
Financial Reporting Committee comments to the Actuarial Standards Board for consideration on the International Actuarial Association's International Standard of Actuarial Practice 4—IFRS 17 Insurance Contracts exposure draft. 
(May 25, 2018)
Financial Regulatory Task Force comments to the U.S. House of Representatives on S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act. (May 21, 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)
AG43/C3P2 Work Group comment letter to NAIC on Recommendation #9. (May 11, 2018)
Life Illustrations Work Group comment letter to NAIC Life Insurance Illustration Issues Working Group on draft changes to Model #582. (April 30, 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)
RBC Tax Reform Work Group follow-up letter to NAIC Life Risk-Based Capital Working Group on additional comments regarding impact of changes to corporate tax rate on risk-based capital calculation.  (April 24, 2018)
PBR Model Governance Work Group amendment proposal form to NAIC on universal life with secondary guarantees net premium reserve lapse rate.  (April 23, 2018)
Committee comments on a proposed rule that would lengthen the maximum period of short-term, limited-duration (STLD) insurance through amending the definition of STLD. (April 6, 2018)
Non-Guaranteed Elements Work Group comment letter on the NAIC March 19 draft life insurance buyer's guide.  (April 4, 2018)
Life Experience Committee presentation to NAIC on analysis and comparison of reserves for Guaranteed Issue (GI) plans.  (March 22, 2018)
Financial Reporting Committee questions for consideration by the IFRS Transition Resource Group on IFRS 17 Insurance Contracts. (March 22, 2018)
Life Experience Committee letter to NAIC responding to ACLI comment on accelerated underwriting data elements.  (March 20, 2018)
Workers’ Compensation Committee discussion of comparisons between states of workers’ comp rates. (March 16, 2018)
RBC Tax Reform Work Group comment letter to NAIC on changes to Life Risk-Based Capiutal calculations as a result of tax reform.  (March 16, 2018)