Public Policy Comments and Letters

Life Capital Adequacy Committee (LCAC) comment letter to the NAIC Life Risk-Based Capital (E) Working Group regarding exposure drafts related to the XXX/AXXX reinsurance framework.
(January 29, 2015)
Rate Review Practice Note Work Group letter to CCIIO with suggested recommendations for modifications to the unified rate review template (URRT) and actuarial memorandum instructions to provide further clarification on a number of issues. (January 16, 2015)
Life Practice Council brief and FAQ supporting the adoption of the NAIC model Standard Valuation Law and Principle-Based Reserves. (January 15, 2015)
Pension Practice Council (PPC) letter to Treasury Department regarding the benefits of allowing qualified defined benefit pension plans to provide longevity annuities directly, rather than requiring them to purchase an insurance contract.  (January 14, 2015)
Pension Committee comment letter to the PBGC regarding interpretation of plan provisions governing actuarial equivalence. (January 13, 2015)
Life Illustrations Work Group letter to NAIC Life Actuarial (A) Task Force regarding principles for a sound actuarial guideline on illustrations for life insurance products. (January 8, 2015)
Life Capital Adequacy Committee, Property and Casualty Risk-Based Capital Committee, and Health Solvency Work Group comments to the National Association of Insurance Commissioners (NAIC) on operational risk issues. (January 7, 2015)
Financial Reporting Committee comments to the International Accounting Standards Board (IASB) on its treatment of participating contracts in its insurance contracts project in follow-up to a November conference call. (December 23, 2014)
Risk Sharing Work Group letter to the U.S. Department of Health and Human Services (HHS) in response to the proposed rule on benefit and payment parameters for 2016. (December 22, 2014)
Pension Committee comment letter to the IRS regarding the updated final and newly proposed regulations for hybrid retirement plans. (December 18, 2014)
Financial Regulatory Task Force comments to the Government Accountability Office (GAO) on its global capital standards report. (December 16, 2014)
Life Practice Council (LPC) comment letter to Actuarial Standards Board on exposure draft of an Actuarial Standard of Practice (ASOP) on Principle-Based Reserves for Life Products.
(December 15, 2014)
Life Products Committee (LPrC) comment letter to Actuarial Standards Board on exposure draft of an Actuarial Standard of Practice (ASOP) on Life Insurance and Annuity Pricing. (December 15, 2014)
Risk Management and Financial Reporting Council comments to the Financial Stability Board (FSB) on the consultative document: Recovery and Resolution Planning for Systemically Important Insurers: Guidance on Identification of Critical Functions and Critical Shared Services. (December 15, 2014)
Solvency Committee comments to the National Association of Insurance Commissioners on the U.S. Group Capital Methodology Concepts Discussion Paper. (December 5, 2014)
Casualty Practice Council letters to U.S. Senate and House leaders urging reauthorization of the Terrorism Risk Insurance Act (TRIA), which is set to expire on Dec. 31. (December 4, 2014)
Solvency Committee comments to members of the U.S. House of Representatives and the U.S. Senate in support of passage of the Insurance Capital Standards Clarification Act of 2014, which clarifies that the Federal Reserve has the authority to differentiate between banks and insurers in terms of capital requirements. (December 2, 2014)
Intersector Group notes to the Pension Practice Council from its October 2014 meeting with the Treasury Department and Internal Revenue Service. (November 24, 2014)
Intersector Group notes to the Pension Practice Council from its October 2014 meeting with the Pension Benefit Guaranty Corporation.  (November 24, 2014)
Financial Reporting Committee comments to the Financial Accounting Standards Board on its disclosure requirements for short duration contracts. (November 21, 2014)