Public Policy Comments and Letters

P/C Risk-Based Capital Committee comments to the NAIC’s Capital Adequacy Task Force on the ongoing examination of the bond risk factors used in the P/C risk-based capital (RBC) formula. (November 10, 2015)
Medicare Supplemental Work Group responses to questions regarding the work group’s recommendations on modifications to the Medicare supplement refund formula.
(November 10, 2015)
Health Solvency Subcommittee updated on the evaluation of asset risk in the health risk-based capital (HRBC) formula.
(November 9, 2015)
Pension Practice Council comments to the Treasury Department and the Internal Revenue Service regarding final regulations concerning Qualified Longevity Annuity Contracts (QLACs) and their advantages. (November 6, 2015)
Financial Reporting and Solvency Committee comment letter to the NAIC's Emerging Accounting Issues (E) Working Group on the “ACA Risk Corridors Collectability” exposure draft. (October 30, 2015)
Solvency Committee comments to the National Association of Insurance Commissioners on the Group Capital Calculation Recommendation exposure draft. (October 27, 2015)
Life Reserves Work Group amendment proposal to the NAIC regarding the removal of references to the “seriatim reserve” in the Valuation Manual. (October 21, 2015)
Life Reserves Work Group amendment proposal to the NAIC regarding the definition and clarification of the term “modeled reserve” in the VM-20. (October 21, 2015)
Price Optimization Task Force comments to the NAIC’s Casualty Actuarial and Statistical Task Force (CASTF) on its Price Optimization White Paper that was exposed on Oct. 13. (October 21, 2015)
Nonforfeiture Modernization Work Group comments related to cancellation benefits on contingent deferred annuities (CDAs) to the NAIC CDA (A) Working Group (CDAWG). (October 20, 2015)
AG 43/C-3 Phase II Work Group comments on the "Variable Annuities Framework for Change" to the NAIC’s Variable Annuities Issues (E) Working Group. (October 16, 2015)
Active Benefits Subcommittee letter to the IRS regarding Notice 2015-52 on the excise tax for high-cost employer-sponsored health coverage under the Affordable Care Act (ACA). (October 1, 2015)
Principle-Based Reserves Strategy Subgroup comments to Reinsurance Task Force on XXX/AXXX Credit for Reinsurance Model Regulation Draft. (September 30, 2015)
Life Illustrations Work Group (LIWG) comments to the Life Insurance and Annuities (A) Committee regarding illustration issues that could be reviewed by the proposed Illustration Review (A) Working Group. (September 30, 2015)
VM-22 drafting subgroup of the Annuity Reserve Work Group (ARWG) comments to LATF’s VM-22 subgroup on sections of VM-22 that cover all non-variable annuities and deposit funds. (September 29, 2015)
Solvency Committee written testimony for the U.S. House Financial Services Subcommittee on Housing and Insurance's hearing on "The Impact of Domestic Regulatory Standards on the U.S. Insurance Market." (September 29, 2015)
C1 Work Group (C1WG) comments on the ACLI’S proposed Life Insurer C-1 Asset Risk-Based Capital Requirement – Real Estate that was exposed by the NAIC Investment Risk-Based Capital Working Group. (September 29, 2015)
Pension Committee comments to the Pension Benefit Guaranty Corporation (PBGC) regarding the proposed changes to the §4010 reporting requirements.
(September 25, 2015)
Premium Review Work Group letter to CCIIO with suggested changes to the unified rate review template (URRT) and rating methodology. (September 22, 2015)
Life Practice Council comments to the NAIC’s Principle-Based Reserving Implementation (EX) Task Force on its “Substantially Similar Terms and Provisions” to Determine the Valuation Manual Operative Date exposure draft. (September 17, 2015)