Public Policy Comments and Letters

Standard Valuation Law Interest Rate Modernization Work Group comments to the NAIC’s Life Actuarial Task Force (LATF) on its “VM-22: Maximum Valuation Interest Rates for Income Annuities” exposure draft. (January 25, 2017)
Non-Guaranteed Elements Work Group comments to the New York state Department of Financial Services on Proposed 11 NYCRR 48 (Insurance Regulation 210) on life insurance and annuity non-guaranteed elements. (January 17, 2017)
LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (January 6, 2017)
Joint Property and Casualty Risk-Based Capital Committee and Health Solvency Subcommittee letter to the NAIC's Operational Risk Subgroup on proposed changes to the operational risk factor in risk-based capital (RBC) formulas for property/casualty and health. (December 19, 2016)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on proposed operational risk factors and growth charge for the life risk-based capital (RBC) formula. Appendix attached. (December 19, 2016)
GASB 74 Implementation Work Group comments on the GASB 74 implementation guide exposure draft that addresses financial reporting for postemployment benefit plans other than pension plans. (December 19, 2016)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed accounting standards update, Targeted Improvements to the Accounting for Long-Duration Contracts. (December 14, 2016)
Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of repealing provisions of the Affordable Care Act (ACA) without having a replacement approach in place, and the challenges faced by eliminating the reimbursements to insurers for cost-sharing reduction subsidies.
(December 7, 2016)
ERM/ORSA Committee comments to the NAIC’s Group Solvency Issues (E) Working Group on the Form F Guidance Manual exposure draft.
(December 5, 2016)
AG 43/C-3 Phase II Work Group comments to the Variable Annuities Issues (E) Working Group on the exposed proposal to revise Actuarial Guideline 43 (AG 43) and C-3 Phase II. (November 14, 2016)
Work Group Comments on Valuation Rate Buckets for Proposed VM-22 for Income Annuities Draft
SVL Interest Rate Modernization Work Group comments on valuation rate buckets to the NAIC's VM-22 (A) Subgroup on its exposure draft on the VM-22 maximum valuation interest rates for income annuities. (November 2, 2016)
Work Group Comments on Proposed VM-22 Maximum Valuation Interest Rates for Income Annuities Draft
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on its exposure draft on the VM-22 maximum valuation interest rates for income annuities. (November 2, 2016)
Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on proposed operational risk factors and growth charge for the life risk-based capital (RBC) formula. (October 31, 2016)
Pension Committee, Multiemployer Plans Subcommittee, and Public Plans Subcommittee comments to the Actuarial Standards Board (ASB) on a draft actuarial standard of practice (ASOP) on risk assessment and disclosure. (October 31, 2016)
Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on its NAIC Staff Memo - Inventory Method Items with Questions exposure draft.
(October 24, 2016)
Pension Committee (PC) comments to the Actuarial Standards Board (ASB) on the third exposure draft of a proposed actuarial standard of practice (ASOP) on modeling. (October 21, 2016)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Risk-based Global Insurance Capital Standard Version 1.0 public consultation document dated July 19, 2016. (October 19, 2016)
C1 Work Group comments to the NAIC's Investment Risk Based Capital Working Group on proposed RBC factors for fixed income securities for the NAIC’s life RBC formula. (October 17, 2016)
Casualty Practice Council (CPC)  and Committee on Property and Liability Financial Reporting (COPFLR) letter to the Actuarial Standards Board commenting on the third exposure draft for the proposed Actuarial Standard of Practice (ASOP) on modeling. (October 14, 2016)
Tax Work Group comments to the NAIC's Statutory Accounting Principles (E) Working Group in response to the Issue Paper No. 15X concerning the implementation of principle-based reserving (PBR). (October 6, 2016)