Pension Committee comments on Internal Revenue Service Notice 2013-49: Updated Static Mortality Tables for the Years 2014 and 2015. (December 16, 2013)

Rate Review Practice Note Work Group letter to the Center for Consumer Information and Insurance Oversight (CCIIO) highlighting several technical comments on the current versions of the Unified Rate Review Template and the actuarial memorandum instructions. (December 04, 2013)

Solvency Committee comments to the National Association of Insurance Commissioners on the International Association of Insurance Supervisors’ paper, Common Framework for the Supervision of Internationally Active Insurance Groups. (December 04, 2013)

Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors’ paper, Common Framework for the Supervision of Internationally Active Insurance Groups.
(November 22, 2013)

Life Practice Council comments on the Initial Report of Rector & Associates to the NAIC Principle-Based Reserving Implementation (EX) Task Force regarding assets for captive reinsurance.  
(November 15, 2013)

Health Practice Council letter to members of Congress on potential consequences of proposals that would modify ACA provisions regarding plan cancellations in the individual and small group health insurance markets.
(November 14, 2013)

State Long-Term Care Task Force comment letter to the NAIC's Long-Term Care Valuation Subgroup regarding proposed changes to the NAIC's Health Insurance Reserves Model Regulation. (November 06, 2013)

Health Practice Council letter to members of Congress on potential adverse consequences of delaying the Affordable Care Act's (ACA) individual mandate and/or extending its open enrollment period. (November 05, 2013)

Pension Committee, Joint Committee on Retiree Health, and Pension Finance Task Force letter to the Actuarial Standards Board (ASB) on coordinating Actuarial Standards of Practice (ASOPs) involving retirement benefits. (October 29, 2013)

International Accounting Standards Task Force comment letter to the Financial Accounting Standards Board on its revised exposure draft, Insurance Contracts.
(October 24, 2013)

International Accounting Standards Task Force comment letter to the International Accounting Standards Board on its revised exposure draft, Insurance Contracts. (October 24, 2013)

The Financial Regulatory Reform Task Force comments to the Financial Stability Board on its paper, “Comments on Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions.” (October 18, 2013)

Health Solvency Work Group response letter to questions raised by the NAIC's Health RBC Working Group regarding the HSWG's model that examines administrative expenses within the context of business concentration risk. (October 18, 2013)

The Financial Regulatory Reform Task Force comments to the Financial Stability Board on its paper, “Comments on Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions.” (October 18, 2013)

Life Capital Adequacy Subcommittee comment letter to the NAIC’s Life Risk-Based Capital (E) Working Group regarding double counting of the Asset Valuation Reserve in both RBC and Asset Adequacy Analysis.
(October 11, 2013)

Life Capital Adequacy Subcommittee comment letter to the NAIC’s Life-Risk Based Capital (E) Working Group on its exposure draft on  additional collateral for transactions with unauthorized reinsurers before risk-based capital (RBC) credit can be taken by the ceding company.
(October 11, 2013)

P/C Risk-Based Capital Committee comment letter to the National Association of Insurance Commissioners on the Reinsurance Association of America's discussion draft on reinsurance credit risk. (October 08, 2013)

Pension Committee comments to the Employee Benefits Security Administration (EBSA) regarding certain disclosures on the Annual Funding Notice for defined benefit plans. (October 03, 2013)

Pension Committee letter to the Pension Benefit Guaranty Corporation (PBGC) that supports the proposed regulations on premium rates, payment of premiums, and reducing regulatory burdens. (October 02, 2013)

The Enterprise Risk Management Committee comments to the Financial Stability Board on its paper, “Principles For an Effective Risk Appetite Framework.” (September 30, 2013)

AG 43/C-3 Phase II Work Group comment letter to the NAIC C-3 Phase II/AG 43 (E/A) Subgroup regarding recent amendment with modifications to current total return gross wealth ratios for Actuarial Guideline 43.  
(September 30, 2013)

Pension Committee comments to the Actuarial Standards Board on its recent modeling ASOP exposure draft that included concerns that the potential ASOP could be applied too broadly. (September 27, 2013)

Pension Finance Task Force letter to the Financial Accounting Standards Board (FASB) that provides suggestions, based on financial economics, to improve accounting for single employer pension plans, an issue that FASB may consider revisiting. (September 26, 2013)

Pension Committee comments to the Internal Revenue Service regarding the Annual Return/Report of Employee Benefit Plan (Form 5500) that focus on the electronic submission of data on Schedules SB and MB. (September 23, 2013)

Terrorism Risk Insurance Subcommittee comment letter to the Federal Insurance Office on the long-term availability and affordability of insurance for terrorism risk. (September 16, 2013)

MLR Work Group comments to CMS that reiterate previous comments on the proposed rule implementing medical loss ratio (MLR) requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (September 06, 2013)

Health and Pension Practice Council letter to the Actuarial Standards Board on coordinating Actuarial Standards of Practice (ASOP) affecting pension and retiree group benefits. (August 30, 2013)

Joint Committee on Retiree Health comments to the Actuarial Standards Board on revisions to a second exposure draft of ASOP No. 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Program Periodic Costs or Prefunding Contributions. (August 30, 2013)

Nonforfeiture Modernization Work Group update to the Life Actuarial Task Force regarding nonforfeiture treatment of certain fixed deferred annuities under the proposed gross premium nonforfeiture method approach.

(August 22, 2013)

Aggregate Margin Task Force proposal to replace individual margin in VM-20 with aggregate margin approach.

(August 22, 2013)