Public Policy Comments and Letters

Committee on Property and Liability Financial Reporting comment letter to NAIC's Actuarial Opinion Working Group on the impact of life insurance Valuation Manual changes on P/C insurers' Statements of Actuarial Opinion that include accident and health (A&H) and long-term care (LTC) lines of business. (October 18, 2017)
The Life Reinsurance Work Group comments to the NAIC's Statutory Accounting Principles (E) Working Group on exposure draft 2017-28 relating to “Reinsurance Risk Transfer”. (October 13, 2017)
The C1 Work Group comments to the NAIC’s Investment Risk-Based Capital (E) Working Group on capital requirements for bonds. (October 10, 2017)
The Committee on Property and Liability Financial Reporting’s comment letter to the NAIC’s Statutory Accounting Working Group, questioning the proposed new definition of reinsurance risk transfer in SSAP No. 62R: Property and Casualty Reinsurance. (October 4, 2017)
Health Practice Council comments on the Graham-Cassidy-Heller-Johnson Proposal (GCHJ), legislation that would make revisions to the individual health insurance market and approaches to federal Medicaid funding. (September 22, 2017)
Health Practice Council letter to the U.S. Senate HELP Committee on stabilizing the individual health insurance market. (September 12, 2017)
Financial Regulatory Task Force comments to the  U.S. Senate Committee on Banking, Housing, and Urban Affairs  on S. 1463, Financial Stability Oversight Council Insurance Member Continuity Act.
(August 31, 2017)
Financial Regulatory Task Force comments to the  U.S. Senate Committee on Banking, Housing, and Urban Affairs  on S. 1360, International Insurance Capital Standards Accountability Act of 2017. (August 31, 2017)
Academy letter to U.S. Congress on the importance of an actuarial perspective on tax reform proposals and discussions. (August 31, 2017)
Casualty Practice Council comment letter to members of the U.S. House of Representatives urging reauthorization and revision of the National Flood Insurance Program. (August 30, 2017)
Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) proposed amendments to auditor’s use of the work of specialists. (August 29, 2017)
Life Reserves Work Group (LRWG) comment letter to the National Association of Insurance Commissioners’ Life Actuarial Task Force exposed VM-20 Amendment Proposal Form (APF) on term insurance riders, labeled VM Maintenance Agenda Item 2017-40. (August 28, 2017)
Casualty Practice Council comment letter to the U.S. Senate Committee on Banking, Housing, and Urban Affairs urging reauthorization and revision of the National Flood Insurance Program. (August 23, 2017)
Pension Committee comment letter to the ERISA Advisory Council on the Annual Funding Notice Under ERISA Section 101(f). (August 16, 2017)
Life Experience Committee amendment proposal form to the NAIC's Life Actuarial Task Force to implement guaranteed issue mortality tables under current formula requirements. (August 4, 2017)
Life Experience Committee amendment proposal form to the NAIC's LIfe Actuarial Task Force to implement guaranteed issue mortality tables under principle-based reserve requirements. (August 4, 2017)
Intersector Group notes of its May 2017 meeting with the Pension Benefit Guaranty Corporation.
(August 3, 2017)
Intersector Group notes of its May 2017 meeting with the Treasury Department and Internal Revenue Service. (August 3, 2017)
Comment letter submitted jointly by the P/C RBC Committee and the Health Solvency Subcommittee regarding changes to corporate bond factors being considered by the NAIC’s Investment Risk-Based Capital Working Group. (July 25, 2017)
Health Practice Council letter to the U.S. Senate on potential adverse consequences of legislation to eliminate the Affordable Care Act’s (ACA) individual mandate. (July 25, 2017)