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 24, 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 19, 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 19, 2018)

C1 Work Group comment letter on alternative C1 bond factors for different levels of statutory reserve offset.  (July 16, 2018)

AG43/C3 Phase II Work Group comment letter to NAIC on proposed policyholder behavior assumptions.  (July 15, 2018)

Macroprudential Task Force comment letter on scope considerations for liquidity stress test and design elements. (July 15, 2018)

AG43/C3 Phase II Work Group comment letter to NAIC on May 31 expossure of Variable Annuities Issues Working Group Framework.  (July 12, 2018)

Lifetime Income Risk Joint Task Force letter to Congress on the Lifetime Income Disclosure Act.  (July 05, 2018)

AG43/C3 Phase II Work Group comment letter to NAIC on assumption governance.  (July 04, 2018)

Annuity Illustration Work Group comment letter to NAIC on proposed changes to the Annuity Disclosure Model Regulation #245.  (July 01, 2018)

Life Illustrations Work Group comment letter to California Department of Insurance regarding Assembly Bill 2634. (July 01, 2018)

Life Reserves Work Group revised APF on the aggregation of mortality segments in VM-20. (June 26, 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 24, 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 14, 2018)

Life Reserves Work Group revised APF 2018-17 in response to comments recieved on the original version of the APF.  (June 10, 2018)

Life Operational Risk Work Group comment letter to NAIC on prospective operational risk growth charge for Life RBC Formula.
(June 05, 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 03, 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 28, 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 24, 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 20, 2018)

Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force exposure draft containing potential changes to the P/C Statement of Actuarial Opinion Instructions to address the CASTF’s “Attestation” charge. (May 10, 2018)

AG43/C3P2 Work Group comment letter to NAIC on Recommendation #9. (May 10, 2018)

Life Illustrations Work Group comment letter to NAIC Life Insurance Illustration Issues Working Group on draft changes to Model #582. (April 29, 2018)

Comment letter from  Senior Casualty Fellow Kevin Ryan to the International Association of Insurance Supervisors on climate change risks to the insurance sector. (April 26, 2018)

RBC Tax Reform Work Group follow-up letter to NAIC Life Risk-Based Capital Working Group on additional comments regarding impact of changes to corporate tax rate on risk-based capital calculation.  (April 23, 2018)

PBR Model Governance Work Group amendment proposal form to NAIC on universal life with secondary guarantees net premium reserve lapse rate.  (April 22, 2018)

Committee comments on a proposed rule that would lengthen the maximum period of short-term, limited-duration (STLD) insurance through amending the definition of STLD. (April 05, 2018)

Non-Guaranteed Elements Work Group comment letter on the NAIC March 19 draft life insurance buyer's guide.  (April 03, 2018)

Financial Reporting Committee questions for consideration by the IFRS Transition Resource Group on IFRS 17 Insurance Contracts. (March 22, 2018)

Life Experience Committee presentation to NAIC on analysis and comparison of reserves for Guaranteed Issue (GI) plans.  (March 22, 2018)