Public Policy Comments and Letters

Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisors' (IAIS) Memo on a proposed approach for a global insurance capital standard. (June 6, 2014)
Separate Account Product Work Group comment letter to the NAIC Separate Account Risk Working Group on its revised recommendations for separate accounts exposed May 7, 2014.
(June 5, 2014)
Solvency Committee comments to members of the U.S. House of Representatives supporting passage of the Insurance Capital Standards Clarification Act of 2014 (S.2270/H.R.4510), which clarifies that the Fed has the authority to differentiate between banks and insurers in terms of capital requirements. (June 5, 2014)
Risk Management and Financial Reporting Council comments to NCOIL's International Issues Task Force with recommendations on three international priorities that NCOIL should address in 2014. (June 2, 2014)
Reinsurance Work Group comment letter to the NAIC Emerging Actuarial Issues Working Group on the exposed Reinsurance Ceded Interpretation Question.
(June 2, 2014)
Pension Committee comments to the Society of Actuaries’ Retirement Plans Experience Committee on the RP-2014 and MP-2014 exposure drafts. (May 29, 2014)
Life Illustrations Work Group comment letter to the Life Actuarial Task Force on ACLI proposal for an Actuarial Guideline for Indexed Universal Life Illustrations.
(May 23, 2014)
ORSA Subgroup comments to the NAIC's Risk-Focused Surveillance Working Group on draft ORSA guidance that will be included in the Financial Analysis Handbook and the Financial Condition Examiners Handbook. (May 16, 2014)
Life Practice Council comment letter to the Life Actuarial Task Force on ACLI’s proposed small company exemption to VM-20.
(May 15, 2014)
P/C Risk-Based Capital Committee comment letter to the National Association of Insurance Commissioners on the Reinsurance Association of America's updated proposal on credit risk factors. (May 12, 2014)
AG 43/C-3 Phase II Work Group comment letter to NAIC on ACLI proposals for modification of reserve and capital requirements for contingent deferred annuities. (May 8, 2014)
Intersector Group notes to the Pension Practice Council from its March 2014 meeting with the Treasury Department and Internal Revenue Service. (May 1, 2014)
Intersector Group notes to the Pension Practice Council from its March 2014 meeting with the Pension Benefit Guaranty Corporation. (May 1, 2014)
Principle-based Reserve Strategy Subgroup (PBRSS) comment letter to the NAIC suggesting topics to be discussed at a potential interim meeting of the PBR Implementation (EX) Task Force.
(April 23, 2014)
Risk Sharing Work Group letter to CCIIO with comments on a proposed rule related to exchanges and market reforms for 2015, specifically addressing ACA risk-sharing mechanisms. (April 21, 2014)
Pension Practice Council letter to congressional leaders on proposals to raise revenue from the private sector pension system to offset unrelated spending increases. (April 17, 2014)
Pension Finance Task Force letter on proposals to extend the pension funding rules enacted under MAP-21. (April 17, 2014)
Life Capital Adequacy Subgroup comments on the NAIC Operational Risk Subgroup’s March 20 exposure of a revised proposal that suggests a new “C-5” factor in the NAIC Life Risk-Based Capital formula to provide for operational risk.
(April 15, 2014)
Principle-based Reserves Strategy Subgroup comments clarifying the suggestion to eliminate the net premium reserve (NPR) component of VM-20 in previous comments on Feb. 17 Report of Rector & Associates to the Principle-Based Reserving Implementation (EX) Task Force.
(April 11, 2014)
Letter to congressional leaders regarding the sunset of certain multiemployer provisions in the Pension Protection Act of 2006 that will expire at the end of 2014. (March 31, 2014)