Pension Committee letter to the Internal Revenue Service and Department of the Treasury concerning differing interpretations in the application of IRC Section 415(b) limits and requesting guidance. (January 30, 2012)

The Academy Life Valuation Subcommittee submitted a comment letter to the NAIC Joint Working Group of the Life Insurance and Annuities (A) Committee and Financial Condition (E) Committee regarding their draft Framework on Actuarial Guideline 38.
(January 30, 2012)

International Accounting Standards Task Force comments on the topic of defining the contract boundary for insurance contracts. (December 21, 2011)

Financial Regulatory Reform Task Force comments to the FSOC on proposed rule relating to systemically important financial institutions. (December 19, 2011)

Financial Regulatory Reform Task Force comments to the FIO on how to modernize and improve the U.S. system of insurance regulation. (December 16, 2011)

Pension Accounting Committee and Joint Committee on Retiree Health letter to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. (December 09, 2011)

Pension Accounting Committee and Joint Committee on Retiree Health comment letter to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. (December 06, 2011)

Premium Review Work Group letter to the Massachusetts Senate regarding an amendment to the state budget that would require the disapproval of any health insurance rates to be supported by "sound actuarial assumptions and methods." (November 30, 2011)

Health Practice Council and Committee on Qualifications letter to the Arizona insurance director pointing out that their regulatory definition of “qualified actuary” for health premium actuarial certifications was inappropriate and suggested corrective language. (November 18, 2011)

PBGC response to the Pension Committee’s Oct. 14 inquiry regarding instructions on the Schedule H (Form 5500). (November 02, 2011)

Cancer Claims Cost Tables Work Group letter to the NAIC’s Health Actuarial Task Force discussing the progress it has made over the past year and outlining its objectives for the coming year. (October 31, 2011)

ERM Committee comments on wording suggestions to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual recognizing the model risk for insurers. (October 28, 2011)

Risk Sharing Work Group comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule implementing the risk-spreading mechanisms included in the Affordable Care Act (ACA) and related to reinsurance, risk corridors, and risk adjustment. (October 28, 2011)

Contingent Annuity Issues Work Group analysis assisting the National Association of Insurance Commissioners in its work involving contingent annuities. (October 28, 2011)

Financial Reporting Committee and International Accounting Standards Task Force response to the International Accounting Standards Board (IASB) on its Agenda Consultation 2011 paper. (October 27, 2011)

Multiemployer Plans Subcommittee letter to the Pension Benefit Guaranty Corporation (PBGC) with proposed modifications to the multiemployer pension plan provisions of the Pension Protection Act (PPA). (October 26, 2011)

DTA Bridge Group letter to the NAIC relating to the SSAP No. 101 - Income Taxes, A Replacement of SSAP No. 10R and SSAP No. 10 recently adopted by the NAIC’s Statutory Accounting Principles Working Group. (October 25, 2011)

Pension Committee letter to the IRS and Department of Labor concerning a possible error in the instructions for Form 5500, Schedule H on the reporting of premium payments made to the PBGC from qualified DB plan assets.  (October 17, 2011)

Pension Practice Council comments to the Governmental Accounting Standards Board (GASB) to two exposure drafts on pension accounting and financial reporting by employers. (October 14, 2011)

Joint work group of the SOA Long-Term Section Council and the Academy’s Federal Long-Term Care Task Force letter to HHS Secretary Sebelius regarding the department’s extension of the Genetic Information Nondiscrimination Act (GINA) to long-term care insurance in proposed regulations. (October 13, 2011)

Pension Committee comment letter to the Actuarial Standards Board regarding the discussion draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (October 12, 2011)

Tax Work Group, in conjunction with the Nonforfeiture Improvement Work Group, follow-up comment letter to the Life Actuarial Task Force with suggested revisions to VM-20. (October 12, 2011)

Casualty Practice Council comments to the NAIC’s Casualty Actuarial & Statistical Task Force on its proposed 2012 Actuarial Opinion Instructions. (October 10, 2011)

Exchanges Work Group comments to CMS in response to proposed regulations establishing health insurance exchanges and qualified health plans under the ACA.  (October 06, 2011)

Medicare Supplement Work Group letter to the NAIC Medigap PPACA Subgroup offering comments on the subgroup’s new discussion paper, Medicare Supplement Insurance First Dollar Coverage and Cost-Shares.

(October 04, 2011)

Tax Work Group in conjunction with the Nonforfeiture Improvement Work Group comment letter to the Life Actuarial Task Force regarding issues associated with proposed language in VM-02. (October 03, 2011)

Financial Reporting Committee letter to the Public Company Accounting Oversight Board (PCAOB) on the issues surrounding the auditor’s report based on recent investor feedback. The committee’s comments included a recommendation to increase disclosure and provide more detail to the auditor's reporting model. (September 30, 2011)

Pension Committee comment letter to the Pension Benefit Guaranty Corporation regarding the calculation of unfunded vested benefits for at risk pension plans. (September 22, 2011)

Social Security Committee letter urging the president, congressional leaders, and the Joint Select Committee on Deficit Reduction to improve the long-term solvency and sustainability of Social Security.

(September 22, 2011)

Medicare Steering Committee comment letter to the members of the new Joint Select Committee on Deficit Reduction urging action to improve the long-term solvency and sustainability of the Medicare program. (August 31, 2011)