Public Policy Comments and Letters

Financial Reporting Committee (FRC) and Committee on Property and Liability Financial Reporting (COPLFR) comments to the SEC on its concept release on the modernization of certain disclosure requirements in Regulation S-K. (July 21, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 Subgroup of the Life Actuarial Task Force (LATF) in a question-and-answer format on the determination of statutory valuation interest rates. (July 15, 2016)
Pension Committee comment letter on the decision by the Internal Revenue Service (IRS) to limit the pension actuaries’ potential to interact with IRS actuaries and other experienced employee-benefits personnel.
(July 15, 2016)
Comment letter from the Committee on Property and Liability Financial Reporting (COPLFR) to the NAIC noting inconsistencies in the instructions for certification of loss reserves for international insurers. (July 7, 2016)
Life Reserves Work Group (LRWG) comments to the NAIC's Life Actuarial Task Force (LATF) on the exposed NAIC staff Amendment Proposal Form (APF) on VM-20 product aggregation. (July 5, 2016)
Life Practice Council comments to the NAIC's Life Actuarial Task Force (LATF) on the qualified actuaries’ responsibilities to the interests of the company versus the commissioner. (June 30, 2016)
Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on on the Consolidated ACLI and Academy Amendment Proposal Form. (June 22, 2016)
Pension Committee comment letter to the Pension Benefit Guarantee Corporation (PBGC) expressing appreciation for proposed regulations providing a reduction or partial waiver of the penalty due upon the late payment of premiums to the single employer and multiemployer insurance programs.
(June 22, 2016)
Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on Section 4 of the Valuation Manual-G. (June 10, 2016)
Pension Committee comment letter to the IRS and Treasury requesting that the 2017 Applicable Mortality Tables be issued as soon as possible. (June 10, 2016)
Intersector Group notes of its March 2016 meeting with the Treasury Department and Internal Revenue Service.  (June 7, 2016)
Intersector Group notes of its March 2016 meeting with the Pension Benefit Guaranty Corporation (PBGC). (June 7, 2016)
Solvency Committee comments to the NAIC's Operational Risk (E) Subgroup on its "Operational Risk 2016 Factors" exposure document. (June 6, 2016)
The Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on combined revisions regarding VM-G of the Valuation Manual. (June 3, 2016)
Casualty Practice Council and P/C Extreme Events Committee letter to U.S. Senate Banking, Housing and Urban Affairs Committee on HR 2901, The Flood Insurance Market Parity and Modernization Act, concerning an expanded role for private insurers in the flood insurance marketplace. (May 25, 2016)
Solvency Committee comments to the NAIC's Investment Risk-Based Capital (E) Working Group on its "Way Forward" exposure document. (May 19, 2016)
Life Reserves Work Group (LRWG) comments to the NAIC's Life Actuarial Task Force (LATF) on the Minnesota Department of Commerce Amendment Proposal Form (APF) on post-level term profit assumptions. (May 18, 2016)
Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on recommendations made in amendment proposal forms regarding VM-G of the Valuation Manual. (May 6, 2016)
LTC Reform Subcommittee comment letter to the Maryland Insurance Administration Public Hearing on Long-Term Care Insurance. (April 28, 2016)
Pension Committee comments to the Internal Revenue Service regarding the proposed regulations for nondiscrimination relief for closed defined benefit plans.
(April 28, 2016)