Public Policy Comments and Letters

Catastrophe Risk Subcommittee of the P/C Risk-Based Capital (RBC) Committee comments to the NAIC’s Catastrophe Risk Subgroup on the proposal to revise the calculation of catastrophe risks R6 and R7 for the 2015 reporting year. (June 12, 2015)
Intersector Group notes of its April 2015 meeting with the Treasury Department and Internal Revenue Service.  (June 2, 2015)
Intersector Group notes of its April 2015 meeting with the Pension Benefit Guaranty Corporation (PBGC). (June 2, 2015)
Pension Committee comments to the Actuarial Standards Board (ASB) on its exposure draft, “Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.” (June 1, 2015)
Public Plans Subcommittee comments to the Actuarial Standards Board (ASB) on its exposure draft, “Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.” (May 29, 2015)
RBC Catastrophe Risk Subcommittee comments to NAIC’s Catastrophe Risk (E) Subgroup on revised Form PR026 for the 2015 reporting year. (May 22, 2015)
Health Solvency Work Group comment letter to the NAIC's Investment Risk-Based Capital Working Group on the evaluation of asset risk factors for the health risk-based capital formula. (May 20, 2015)
Nonforfeiture Modernization Work Group comment letter to NAIC Life Actuarial (A) Task Force on exposed edits to the standard nonforfeiture law for annuities regarding requirements for contingent deferred annuities (CDA). (May 13, 2015)
Risk Management and Financial Reporting Council comments to the International Association of Insurance Supervisors (IAIS) on Insurance Core Principle (ICP) 8: Risk Management and Internal Controls. (May 12, 2015)
Risk Sharing Work Group letter to CCIIO on the methodology proposed to evaluate the sufficiency of EDGE server data. (May 8, 2015)
ERM/ORSA Committee comments to the International Association of Insurance Supervisors (IAIS) on its draft issues paper Conduct of Business Risk and its Management. (May 1, 2015)
Financial Reporting Committee comments on the Financial Accounting Standards Board's (FASB) proposed accounting standards update-Derivatives and Hedging (Topic 815): Disclosures about Hybrid Financial Instruments with Bifurcated Embedded Derivatives. (April 30, 2015)
Risk Management and Financial Reporting Council and Financial Reporting Committee comments to the Federal Insurance Office (FIO) on U.S. GAAP loss recognition testing and Insurance Core Principle (ICP) 14 current estimates. (April 27, 2015)
Deposit Fund Subgroup comment letter to NAIC Life Actuarial (A) Task Force on exposed edits to the model regulation for synthetic guaranteed investment contracts (GIC). (April 22, 2015)
Price Optimization Task Force comments to NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on its Price Optimization White Paper. (April 15, 2015)
Life Illustrations Work Group comment letter to NAIC Life Actuarial (A) Task Force on proposed actuarial guideline for indexed universal life illustrations. (April 14, 2015)
Casualty Practice Council comments to NAIC’s Casualty Actuarial and Statistical Task Force on the CPC’s process for approving member actuaries to sign P/C NAIC opinions. (April 9, 2015)
Pension Practice Council and Multiemployer Subcommittee comment letter to the IRS and Treasury regarding the Request for Information on Suspensions of Benefits under the Multiemployer Pension Reform Act of 2014 (MPRA).  (April 7, 2015)
Pension Practice Council and Multiemployer Subcommittee comment letter to the Pension Benefit Guarantee Corporation regarding the Request for Information on Partitions and Facilitated Mergers under the Multiemployer Pension Reform Act of 2014 (MPRA). (April 6, 2015)
Risk Sharing Work Group letter to CMS with comments on the 2014 medical loss ratio (MLR) annual reporting form. (March 31, 2015)