Public Policy Comments and Letters

Casualty Practice Council comments on the ASB's third exposure of the proposed Actuarial Standards of Practice (ASOP), Estimating Future Costs for Prospective Property/Casualty Risk Transfer and Risk Funding. (April 27, 2017)
ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Setting Assumptions exposure draft. (April 27, 2017)
Premium Review Subgroup comments to the Center for Consumer Information and Insurance Oversight on the final 2018 unified rate review template (URRT) instructions. (April 27, 2017)
Pension Practice Council letter to Congressional leaders on pension-related revenue offsets. (April 18, 2017)
Workers' Compensation Committee comment letter to California's Offfice of Self-Insured Plans regarding guidance on actuarial reports on self-insured workers' compensation plans. (March 30, 2017)
Pension Committee comment letter to the IRS on the proposed update to mortality tables for determining the present value for defined benefit pension plans. (March 30, 2017)
Notes from the Multiemployer Plans Subcommittee meeting on Feb. 22 with officials of the Treasury and Labor departments, and Pension Benefit Guaranty Corporation to discuss applications by multiemployer pension plans in critical and declining status to suspend benefits or partition liabilities. (March 23, 2017)
Indivdiual and Small Group Markets Committee and Medicaid Subcommittee comments on H.R. 1628, the American Health Care Act, the proposed legislation to repeal and replace provisions in the Affordable Care Act. (March 22, 2017)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on a draft report on operational life risk-based capital. (March 17, 2017)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on the VM-22 Maximum Valuation Interest Rates for Income Annuities draft report. (March 14, 2017)
Pension Committee comments to the U.S. Treasury Department requesting guidance from the IRS and Treasury to resolve uncertainties that exist as to how variable annuity plans should be valued for minimum funding and Internal Revenue Code (IRC) §417(e) purposes.
(March 9, 2017)
Individual and Small Group Markets Committee comments to the U.S. House Committee on Education and the Workforce on  H.R. 1101, the Small Business Health Fairness Act, related to association health plans.
(March 8, 2017)
Individual and Small Group Markets Committee letter to the Centers for Medicare & Medicaid Services regarding the proposed rule for market stabilization. (March 7, 2017)
Financial Reporting Committee comments to the International Actuarial Association (IAA) on the exposure draft of its “Risk Adjustments for Financial Reporting of Insurance Contracts under International Financial Reporting Standards No. X” monograph. (February 28, 2017)
Multiemployer Pension Plans Subcommittee comments to the Pension Benefit Guaranty Corporation (PBGC) on alternative two-pool withdrawal liability methods. (February 24, 2017)
Pension Committee comment letter to the IRS on proposed regulations to the minimum present value requirements for defined benefit (DB) plan distributions. (February 24, 2017)
SVL Interest Rate Modernization Work Group comments on a revised weighting methodology proposal to the NAIC's VM-22 (A) Subgroup. (February 17, 2017)
AG 43/C-3 Phase II Work Group comments to the NAIC’s Variable Annuities Issues (E) Working Group on version 1 of the draft specifications for the second quantitative impact study. (February 3, 2017)
ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers exposure draft. (January 31, 2017)
Health Financial Reporting and Solvency Committee comments to the Long-Term Care Valuation (B) Subgroup on asset treatment for stand-alone LTC asset adequacy analysis. (January 26, 2017)