Public Policy Comments and Letters

AG33 Non-Elective Task Force letter to NAIC Life Actuarial Task Force on Actuarial Guideline XXXIII. (August 15, 2014)
Principle-Based Reserves Strategy Subgroup comment letter to NAIC Life Actuarial Task Force on the Net Premium Reserve component of the Rector report. (August 12, 2014)
Solvency Committee comments to the National Association of Insurance Commissioners on the International Association of Insurance Supervisors' revised proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (August 4, 2014)
Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors' revised proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (August 4, 2014)
Pension Practice Council letter to Congressional leaders on concerns about proposals to raise revenues by changing private sector pension law to offset unrelated spending increases. (July 25, 2014)
Pension Finance Task Force letter to Congressional leaders on concerns about proposals to raise revenues by changing private sector pension law to offset unrelated spending increases. (July 25, 2014)
ORSA Subgroup comments to the NAIC's Risk-Focused Surveillance Working Group on the second exposure draft of ORSA guidance, which will be included in the Financial Analysis Handbook and the Financial Condition Examiners Handbook. (July 22, 2014)
Casualty Practice Council comments to U.S. House leaders on the TRIA Reform Act of 2014 in support of reauthorizing the terrorism risk insurance program and maintaining a government backstop for a peril that is difficult to fully insure in the private market. (July 16, 2014)
Pension Committee comment letter to National Conference of Insurance Legislators on proposed Pension De-Risking Model Act. (July 11, 2014)
Casualty Practice Council comments to Senate leaders on the Terrorism Risk Insurance Reauthorization Act of 2014 in support of reauthorizing the terrorism risk insurance program and maintaining a government backstop for a peril that is difficult to fully insure in the private market. (July 10, 2014)
Committee on Property and Liability Financial Reporting comment letter to the NAIC's Casualty Actuarial and Statistical Task Force on proposed changes to IRIS ratios 11, 12, and 13, which would add adjusting and other expenses to the basis for calculating these ratios. (July 10, 2014)
Medicaid Work Group request to the Centers for Medicare and Medicaid Services for specific guidance on the Affordable Care Act's Health Insurance Providers fee and how it affects the Medicaid program. (July 7, 2014)
Financial Reporting Committee letter to the Financial Accounting Standards Board on its insurance contracts project, encouraging convergence for long-duration contracts but also highlighting issues that may need to be addressed if targeted improvements instead of the building block approach are pursued. (June 30, 2014)
Financial Reporting Committee letter to the Financial Accounting Standards Board on its insurance contracts project, encouraging convergence for long-duration contracts but also highlighting issues that may need to be addressed if targeted improvements instead of the building block approach are pursued. (June 30, 2014)
Tax Work Group comment letter to NAIC Health Actuarial Task Force on tax implications of 2013 Individual Disability Income Valuation Tables. (June 26, 2014)
Life Practice Council comment letter to the NAIC Principle-based Reserving Implementation (EX) Task Force on June 4 exposure of the Rector Report.
(June 25, 2014)
Casualty Practice Council comments on Casualty Actuarial Society’s Statement of Principles on P&C Ratemaking revised draft. (June 20, 2014)
Health Practice Financial Reporting Committee comments to the NAIC on new accounting proposals for the risk-sharing programs of the Affordable Care Act. (June 20, 2014)
Stress Testing Work Group comments on NAIC Life Risk-Based Capital Working Group stress testing proposal.
(June 18, 2014)
C-3 Work Group report on recommended approach for updating regulatory Risk-Based Capital requirements for interest rate risk for fixed annuities and single premium life insurance (C-3 Phase I).
(June 12, 2014)