Public Policy Comments and Letters

Pension Practice Council Vice-President, Don Segal, letter to the editor of The Economist in response to an article about the problems associated with defined benefit (DB) pension plans. An abridged version of the letter was published. (February 4, 2006)
Financial Reporting Committee response to a FASB invitation to comment on the treatment of liabilities and assets with uncertainties in financial reporting. (January 11, 2006)
Comments from COPLFR about draft Bermuda Monetary Authority guidance on the role of the loss reserve specialist. (December 22, 2005)
Life Practice Council comment letter to the SEC about the treatment of equity-indexed annuities as insurance rather than securities. (December 21, 2005)
Life Reserves Working Group memo to New York Insurance Department about discount rates. (December 21, 2005)
Pension Practice Council letter to the Government Accountability Office (GAO) commenting on a GAO report about cash balance pension plans. The GAO responded to the PPC with a letter addressing council concerns. (December 5, 2005)
Letter from Pension Practice Council Vice-President Don Segal to the editor of the Financial Times responding to misrepresentations about the role of actuaries in pension accounting. (December 2, 2005)
Pension Practice Council request to the Internal Revenue Service (IRS) for a technical advice ruling related to IRS Circular 230 regulations. (October 3, 2005)
Workers' Compensation Subcommittee letter expressing concern about a Senate asbestos bill's effects on the workers' compensation system. (September 8, 2005)
Universal Life Work Group update of draft framework for principle-based life reserve valuation describing initial modeling results. (September 1, 2005)
Subgroup on LTC Experience Forms letter that addresses several issues raised by the NAIC in response to the Academy's Long-Term Care Experience Subgroup's May 20, 2005 letter with proposed revisions to the LTC experience reporting instructions and forms. (August 18, 2005)
Pension Accounting Committee letter to the Financial Accounting Standards Board (FASB) about a FASB project to reconsider pension and other post-retirement benefit accounting. (August 18, 2005)
Extreme Events Committee comments on a Treasury Department study of TRIA, the Terrorism Risk Insurance Act. (August 2, 2005)
Federal Health Committee letter in response to HR 2355, the Health Care Choice Act of 2005, which contained language that would allow a non-actuary to offer statements of opinions on reserves. The letter recommended only a member of the Academy be permitted to provide such an opinion. (July 19, 2005)
Academy follow-up letter to GAO on the role of actuaries in insurance. (June 6, 2005)
Universal Life Work Group draft framework for principle-based life reserve valuation (Main report with hyperlinks to several other documents). (June 1, 2005)
Life Risk Based Capital Working Group status report on the Modco project. (June 1, 2005)
Academy letter to Sen. Ted Kennedy responding to questions related to Academy testimony on Pension Benefit Guaranty Corporation (PBGC) reform. (May 31, 2005)
Committee on Property and Liability Financial Reporting comments in response to a draft "Statement of Principles Regarding Property and Casualty Loss and Loss Adjustment Expense Reserves" issued by the Casualty Actuarial Society's Task Force on Reserving Principles. (May 30, 2005)
Letter to the NAIC from the LTC Experience Forms Subgroup on proposed LTC loss experience exhibit forms (Forms 1, 2, and 3) along with the proposed instructions. This was updated in August 2005 in a subsequent letter to NAIC. (May 20, 2005)