Public Policy Comments and Letters

Life Illustrations Work Group comments to the NAIC’s IUL Illustration (A) Subgroup on revisions to Actuarial Guideline (AG) 49. (March 14, 2016)
Role of the Actuary Subgroup comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on revisions to the Corporate Governance Guidance Appendix, Section VM-G, of the Valuation Manual applicable to qualified actuaries for clarification and consistency with the Standard Valuation Law. (March 10, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's V-22 Subgroup of the Life Actuarial Task Force on statutory regulations regarding the determination of statutory valuation interest rates. (February 23, 2016)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed accounting standards update, Fair Value Measurement (Topic 820): Disclosure Framework. (February 18, 2016)
Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC’s Actuarial Opinion (C) Working Group on the Actuarial Opinion Instructions. (February 12, 2016)
Senior Property/Casualty Fellow Jim MacGinnitie comments to the NAIC/IAIABC Joint (C) Working Group on the 2015 Workers’ Compensation Large Deductible Study draft. (February 5, 2016)
Committee on Property and Liability Financial Reporting (COPLFR)  comments to the NAIC’s Statutory Principles (E) Working Group on the proposed Clarification of Accounting Treatment for Fees Incurred for Salvage/Subrogation Recoveries. (February 3, 2016)
Life Illustrations Work Group (LIWG) comments to the NAIC’s Life Insurance and Annuities (A) Committee on the new working group formed to explore disclosures required in Model #580 and #582. (January 29, 2016)
Actuarial Guideline 43/C-3 Phase II Work Group comments to the NAIC on the variable annuities blanks proposal exposed on Nov. 19. (January 29, 2016)
Medicare Subcommittee letter to the Senate Finance Committee with comments on the Bipartisan Chronic Care Working Group’s Policy Options Document. (January 26, 2016)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Non-traditional Non-insurance Activities and Products public consultation document dated November 25, 2015. (January 25, 2016)
Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC/IAIABC Joint (C) Working Group on the 2015 Workers’ Compensation Large Deductible Study draft. (January 19, 2016)
Risk Sharing Subcommittee letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule on benefit and payment parameters for 2017. (December 20, 2015)
Intersector Group notes of its September 2015 meeting with the Treasury Department and Internal Revenue Service. 
(December 9, 2015)
Intersector Group notes of its September 2015 meeting with the Pension Benefit Guaranty Corporation (PBGC).
(December 9, 2015)
Life Illustrations Work Group comments to LATF’s IUL Illustration (A) Subgroup on the draft revision to Actuarial Guideline (AG) 49. (December 1, 2015)
Price Optimization Task Force comments to the NAIC’s Property/Casualty Committee on the Price Optimization White Paper after its adoption by the Casualty Actuarial and Statistical Task Force (CASTF). (November 21, 2015)
ERM/ORSA Committee comments to the International Actuarial Association (IAA) on its white paper "Actuarial Aspects of ERM for Insurance Companies." (November 20, 2015)
Individual Disability Tables Work Group (IDTWG) presented updated incidence modifiers report for use in active life reserve calculations for employer-sponsored disability income policies along with a corresponding memo memo to the chair of the Health Actuarial Task Force. (November 18, 2015)
Deposit Fund Subgroup comments to the Life Actuarial Task Force on rules for separate accounts that fund guaranteed minimum benefits under group contracts related to the synthetic GIC model regulation. (November 16, 2015)