Public Policy Comments and Letters

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)
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)