Public Policy Comments and Letters

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)
Annuity Illustration Work Group letter to the Annuity Disclosure Working Group with more suggested revisions to an ACLI proposal for a model annuity illustration. (November 6, 2009)
Health Practice Council letter to Speaker Nancy Pelosi and Republican Leader John Boehner providing an actuarial perspective on health insurance market reforms, outlining three criteria to ensure that the current markets remain viable, and offering comments on how certain provisions of the House’s Affordable Health Care for America Act (HR 3962) conform with those criteria. (November 6, 2009)
Medical Professional Liability Insurance Subcommittee letter to House Speaker Nancy Pelosi regarding "The Affordable Health Care for America Act" and its possible effects on medical professional liability insurance. (November 5, 2009)
Medical Professional Liability Insurance Subcommittee tort-reform fact sheet, which is the second in a series of fact sheets published by the subcommittee designed for actuaries as well as the general public. (October 1, 2009)
Financial Reporting Committee comments to the IASB on its Exposure Draft, Fair Value Measurement. (October 1, 2009)
Financial Reporting Committee white paper and notes on the use of discount rates in accounting present value estimates. (September 15, 2009)
Annuity Illustration Work Group comment letter to the NAIC Annuity Disclosure Working Group with suggested revisions to the ACLI model proposal. (September 14, 2009)
Life Financial Reporting Committee and Financial Reporting Committee comments to the IASB on its "Exposure Draft, Financial Instruments: Classification and Measurement." (September 14, 2009)
Academy letter to Rep. Anthony Weiner concerning his comments about Social Security's annual cost-of-living adjustments (COLAs). (September 4, 2009)