Public Policy Comments and Letters

Pension Committee comments to the Actuarial Standards Board (ASB) regarding proposed revisions to ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations. (March 31, 2010)
Health Practice Council letter to members of House and Senate pledging to work with regulatory authorities on the implementation of the health reform law. (March 24, 2010)
Health Practice Council letter to Congress outlining technical and policy issues that need to be addressed before the passage of health reform legislation to ensure success of the reforms. (March 8, 2010)
Regulatory Capital Requirements Task Force response to questions posed in the Consultation Paper on Regulatory Capital Requirements and Overarching Accounting and Valuation Issues for the Solvency Modernization Initiative. (March 1, 2010)
Health Practice Council letter to the White House and invitees of the Feb. 25 bipartisan health summit stressing critical actuarial aspects of health reform legislation that will need to be addressed to support the stated goals of reducing the number of uninsured, increasing the availability and affordability of coverage, and enhancing the focus on quality of care and health spending growth. (February 24, 2010)
Letter to NAIC regarding the joint Academy State LTC Task Force and SOA Valuation Committee project to develop and recommend valuation morbidity tables for long-term care insurance. (February 22, 2010)
Financial Reporting Committee comments on the recent vote by the IASB and confirmation by the FASB to not permit the recognition of revenue for incremental acquisition expenses upon the initial measurement of an insurance contract. (February 19, 2010)
Workers' Compensation Subcommittee comments on the California Commission on Health and Safety and Workers' Compensation investigation of relationships between workers' compensation and group health care. (February 12, 2010)
Life Financial Reporting Committee and Financial Reporting Committee comments on the FASB on exposure draft, Proposed ASU-Financial Services-Insurance (Topic 944): "Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts." (February 12, 2010)
Medicare Supplement Work Group additional comments to NAIC on the draft revisions to the Medicare Supplement Compliance Manual, clarifying the use of the pooling approach used in the manual and how it may interact with loss ratio standards. (February 2, 2010)
ERM Subcommittee comments on the Basel Committee on Banking Supervision's consultation document, "Recognizing the Risk-Mitigating Impact of Insurance in Operational Risk Modelling." (January 29, 2010)
Pension Committee comments to the Pension Benefit Guaranty Corporation (PBGC) on proposed regulations concerning reportable events under ERISA Section 4043 and the purchase of irrevocable commitments prior to initiating a standard plan termination under ERISA Section 4041. (January 22, 2010)
Medical Professional Liability Subcommittee letter to Congress discussing concerns with the inclusion of a provision that would repeal the McCarran-Ferguson Act, an antitrust exemption for health and medical professional liability insurance, within the House's Affordable Health Care for America Act. Additionally, the Academy provided comments to the House on the legislation focusing on the risks insured under a variety of types of property/casualty insurance policies. (January 21, 2010)
Health Practice Council letter to House Speaker Nancy Pelosi and Senate Majority Leader Harry Reid highlighting some of the key differences on actuarial issues between the House's Affordable Health Care for America Act (HR 3962) and the Senate's Patient Protection and Affordable Care Act. (January 14, 2010)
Risk Management and Solvency Committee comments to the NAIC on its draft paper, United States Insurance Financial Solvency Framework. (December 17, 2009)
Pension Committee comments to the Department of Labor regarding the electronic display of certain information contained in the annual Form 5500 filing for single employer defined benefit plans. (December 9, 2009)
Response from the LRWG on New York Insurance Department’s proposed changes to the use of economic scenarios in VM-20 (December 3, 2009)
Financial Regulatory Reform Task Force comments on H.R. 2609, the Insurance Information Act, and H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009, that recommends including an explicit provision in the legislation to include important professional expertise by creating an Office of the Actuary. (November 24, 2009)
Health Practice Council letter to Sens. Harry Reid and Mitch McConnell that outlines key isuses that need to be considered when evaluating whether the Senate's health care reform bill will lead to a viable health insurance system and discusses whether the Patient Protection and Affordable Care Act addresses the outlined issues. (November 20, 2009)
Pension Committee letter to Rep. Earl Pomeroy regarding H.R. 2748, Retirement Security Needs Lifetime Pay Act of 2009. (November 18, 2009)