Public Policy Comments and Letters

Health Practice Council comments urging HHS to consider implementing measures to counter the potential adverse consequences on health insurance premium rate filings in the event the Supreme Court rules for the petitioners in King v. Burwell. (February 24, 2015)
PBR Strategy Subgroup and Life Reinsurance Work Group comment letter to NAIC PBR Implementation (EX) Task Force on exposure of XXX/AXXX reinsurance supplemental proposal. (February 23, 2015)
Solvency Committee comments to the International Association of Insurance Supervisors on the Risk-based Global Insurance Capital Standard public consultation document dated Dec. 17, 2014. (February 6, 2015)
Pension Committee comment letter to the IRS regarding the use of mortality tables to calculate pension funding requirements for the years after 2015. (February 5, 2015)
Pension Committee comment letter regarding potential improvements in the operation of IRC Section 436 while still protecting the funded status of pension plans.
(February 5, 2015)
Casualty Practice Council comments on Casualty Actuarial Society’s statement of principles on P&C ratemaking exposure draft. (January 31, 2015)
Casualty Practice Council comment letter to Actuarial Standards Board on exposure draft of a proposed Actuarial Standard of Practice on Property/Casualty Ratemaking. (January 31, 2015)
Stress Testing Work Group comment letter to NAIC Stress Testing (E) Subgroup on stress testing proposal as an outline for field testing of life insurance reserves. (January 30, 2015)
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)
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)