Public Policy Comments and Letters

Risk Management and Financial Reporting Council and Financial Reporting Committee comments on the Treasury Department's proposed review of the U.S. financial regulatory structure. (November 19, 2007)
International Financial Reporting Standards Task Force comments to the IASB on its discussion paper, "Preliminary Views on Insurance Contracts." (November 16, 2007)
International Financial Reporting Standards Task Force response to FASB on its Invitation to Comment on FASB Agenda Proposal, "Accounting for Insurance Contracts by Insurers and Policyholders." (November 16, 2007)
Pension Committee letter to Internal Revenue Service (IRS) commenting on proposed benefit restrictions for defined benefit (DB) pension plans under Internal Revenue Code Sections 430(f) and 436. (November 5, 2007)
Pension Practice Council and Pension Committee letter to the House Ways and Means Committee requesting technical corrections to clarify aspects of the Pension Protection Act. (November 5, 2007)
Financial Reporting Committee comments to the SEC on a proposal to eliminate a requirement for reconciling IFRS financial statements with U.S. GAAP. (October 9, 2007)
Terrorism Risk Insurance Subgroup comments to Senate Banking Committee about extending the federal terrorism insurance program. (October 1, 2007)
Terrorism Risk Insurance Subgroup comment letter to Congress on proposed legislation extending the federal terrorism insurance program. (September 19, 2007)
Pension Committee letter to Joint Board for the Enrollment of Actuaries (JBEA) requesting the JBEA provide a summary of key mistakes or problems it has found in audits of enrolled actuaries CE filings. (September 3, 2007)
Cost Accounting Standards Task Force response to the Cost Accounting Standards Board (CASB) regarding a survey on harmonizing two cost accounting standards with provisions of the Pension Protection Act. (September 3, 2007)
Pension Committee letter to the Department of the Treasury requesting that Treasury reconsider its method for applying an anti-backloading rule (the four-thirds rule) to cash balance plans. (September 3, 2007)
Risk Management and Solvency Committee comments to the IAIS on three papers: Capital Requirements, Enterprise Risk Management for Capital and Solvency Purposes, and the Use of Internal Models by Insurers. (August 23, 2007)
Workers' Compensation Subcommittee comments on a New York state workers' compensation bill that would, among other provisions, prohibit data sharing. (August 22, 2007)
Comments from Life, Health, and Casualty Practice Councils on life and health insurance principles proposed by the NAIC's Principle-based Reserving (EX) Working Group. (August 17, 2007)
Workers’ Compensation Subcommittee comments to the International Association of Industrial Accident Boards and Commissions on proposed self-insured workers' comp loss reporting forms. (August 1, 2007)
Life Products Committee comments to the NAIC on travel-related life insurance provisions in a draft model trade law. (July 31, 2007)
Nonforfeiture Improvement Work Group follow-up questions on responses to LHATF questionnaire. (June 30, 2007)
Joint Committee on Retiree Health letter to Texas officials about misinterpretations of the committee's 2006 comments on accounting standards for OPEBs. (June 15, 2007)
Medicare Part D RBC Subgroup revision proposals to the NAIC life and health RBC instructions for Medicare Part D to address a potential unintended consequence related to the Authorized Control Level (ACL) RBC results. (June 3, 2007)
Risk Margin Task Force comments to IAA on draft "Measurement of Liabilities for Insurance Contracts: Current Estimates and Risk Margins." (May 25, 2007)