Public Policy Comments and Letters

Life and Health Valuation Law Manual Task Force comment letter to Life Actuarial (A) Task Force on recommendations to changes for the 2019 Life and Health Valuation Law Manual.  (August 16, 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)
Notes from the Multiemployer Plans Committee meeting on Feb. 23, 2018 with officials of the Treasury and Labor departments, and Pension Benefit Guaranty Corporation to discuss applications by multiemployer pension plans in critical and declining status to suspend benefits or partition liabilities. This meeting supplements the first meeting between these parties on this topic, which was held on Feb. 22, 2017. (July 31, 2018)
Pension Committee, Public Plans Committee and Multiemployer Plans Committee comment letter to ASB on exposure drafts of proposed revisions to ASOPs 4, 24, and 35. (July 31, 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)
C1 Work Group comment letter on alternative C1 bond factors for different levels of statutory reserve offset.  (July 17, 2018)
Macroprudential Task Force comment letter on scope considerations for liquidity stress test and design elements. (July 16, 2018)
AG43/C3 Phase II Work Group comment letter to NAIC on proposed policyholder behavior assumptions.  (July 16, 2018)
AG43/C3 Phase II Work Group comment letter to NAIC on May 31 expossure of Variable Annuities Issues Working Group Framework.  (July 13, 2018)
Lifetime Income Risk Joint Task Force letter to Congress on the Lifetime Income Disclosure Act.  (July 6, 2018)
AG43/C3 Phase II Work Group comment letter to NAIC on assumption governance.  (July 5, 2018)
Annuity Illustration Work Group comment letter to NAIC on proposed changes to the Annuity Disclosure Model Regulation #245.  (July 2, 2018)
Life Illustrations Work Group comment letter to California Department of Insurance regarding Assembly Bill 2634. (July 2, 2018)
Life Reserves Work Group revised APF on the aggregation of mortality segments in VM-20. (June 27, 2018)
C1 Work Group comment letter to NAIC Valuation of Securities Task Force on their proposal to add instructions for fund investments to the Purposes and Procedures Manual.  (June 25, 2018)
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)