Public Policy Comments and Letters

Subgroup on Long-Term Care Experience Forms comments to the NAIC regarding American Council of Life Insurers (ACLI) Proposed Recommendation to Report Non-Exempt LTC accelerated-type products. (November 17, 2006)
Pension Committee discussion paper to the Internal Revenue Service (IRS) and Department of the Treasury regarding the use of substitute mortality tables. (November 6, 2006)
Risk Management and Solvency Committee comments to the IAIS on its paper "Common Structure for the Assessment of Insurer Solvency." (November 1, 2006)
Life Products Council paper supporting a move to a principles-based system to the NAIC's Life Insurance and Annuities Committee regarding the travel underwriting issue. (September 9, 2006)
Pension Committee letter to the Department of Labor (DOL) expressing objections to the proposed addition of an asset information question to Form 5500 Schedule B. (September 4, 2006)
Life Reserve Work Group updated draft actuarial guidelines on reserve documentation and disclosure (AG DIS), on life valuation assumptions (AG PBR-VAL), updated draft model regulation on principle-based life reserving, and summary of changes to the NAIC's Life and Health Actuarial Task Force. (September 1, 2006)
Principle-Based Review and Governance Work Group draft model regulations to the NAIC's Life and Health Actuarial Task Force regarding principles-based valuation review opinions. (September 1, 2006)
Life Products Committee report to the NAIC's Life and Health Actuarial Task Force on short term changes needed to the standard nonforfeiture laws. (September 1, 2006)
Annuity Reserve Work Group report to the NAIC's Life and Health Actuarial Task Force regarding principle-based reserves for non-variable annuities. (September 1, 2006)
Risk Management and Financial Reporting Council letter to congressional leaders on the legislative definition of a qualified risk manager under Nonadmitted and Reinsurance Reform Act of 2006 (H.R. 5637). (September 1, 2006)
Joint American Academy of Actuaries/Society of Actuaries Review Team report to the NAIC's Life and Health Actuarial Task Force regarding a review of the interim mortality tables developed by Tillinghast and proposed for use by the ACLI. (August 29, 2006)
Pension Practice Council letter to the Internal Revenue Service (IRS) requesting technical guidance on regulatory issues related to IRS Circular 230. (August 29, 2006)
Financial Reporting Committee comments to FASB regarding Bifurcation of Insurance and Reinsurance Contracts for Financial Reporting. (August 24, 2006)
Committee on Federal Health Issues letter to Citizens' Health Care Working Group on its interim recommendations for improving health care. (August 24, 2006)
Medicare Supplement Work Group comments to NAIC's Medigap Modernization Subgroup of the Senior Issues Task Force identifying potential transitional issues that will need to be addressed as part of Medicare Supplement modernization that the Subgroup has recently taken up. (August 17, 2006)
Life Reserves Work Group responses to New York changes to model regulation for principle-based life reserving. (August 1, 2006)
Risk Management and Solvency Committee comments to the IAA on the draft IAIS document on asset-liability management. (July 26, 2006)
Risk Management and Solvency Committee comments to the IAA on the draft IAIS document on the insurer solvency assessment. (July 26, 2006)
Risk Management and Financial Reporting Council letter to the Senate recommending that the National Insurance Act of 2006 include a provision creating an Office of the Actuary. (July 17, 2006)
Joint Committee on Retiree Health letters to FASB expressing concern over proposed changes in financial accounting standards for pensions and OPEBs. (May 31, 2006)