Public Policy Comments and Letters

Pension Committee comments to the Internal Revenue Service regarding the proposed regulations for nondiscrimination relief for closed defined benefit plans.
(April 28, 2016)
Pension Practice Council comments to the Department of Defense regarding the use of personal discount rates to calculate lump-sum payments from military pensions as required in the National Defense Authorization Act for Fiscal Year 2016.
(April 27, 2016)
Casualty Practice Council and P/C Extreme Events Committee letter to U.S. House of Representatives on HR 2901, The Flood Insurance Market Parity and Modernization Act, concerning an expanded role for private insurers in the flood insurance marketplace. (April 26, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 Subgroup of the Life Actuarial Task Force (LATF) on questions and answers in response to statutory regulations regarding the determination of statutory valuation interest rates. (April 25, 2016)
Life Reserves Work Group (LRWG) comments to the NAIC’s Life Actuarial Task Force (LATF) on currently exposed amendment proposal forms on net premium reserves. (April 25, 2016)
Life Reserves Work Group (LRWG) comments to the NAIC’s Life Actuarial Task Force (LATF) on currently exposed amendment proposal forms on term and universal life insurance with secondary guarantees. (April 25, 2016)
Pension Accounting Committee comments to the Financial Accounting Standards Board on its exposure draft on changes to the disclosure requirements for defined benefit plans.
(April 25, 2016)
Risk Sharing Subcommittee letter to the Centers for Medicare & Medicaid Services (CMS) with comments on its recent discussion paper, HHS-Operated Risk Adjustment Methodology. The letter includes comments on partial year enrollment, use of pharmacy data, use of concurrent versus prospective model, high-risk enrollee pooling, recalibration of the model, and the transfer formula.  (April 22, 2016)
Casualty Practice Council comments on the Actuarial Standards Board's (ASB) second exposure draft of the proposed actuarial standards of practice for Property/Casualty Ratemaking. (April 21, 2016)
Health Care Receivables Factors Work Group recommendation on credit risk factors for health care receivables to the NAIC’s Health Risk Based Capital (E) Work Group. (April 15, 2016)
Premium Review Work Group letter to CCIIO with comments on the 2017 unified rate review template (URRT). (March 30, 2016)
Health Solvency Subcommittee letter to the NAIC’s Health Risk-Based Capital (E) Working Group with comments on Proposal 2016-01-H’s individual premiums and claims footnote. (March 28, 2016)
Role of the Actuary Subgroup comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on revisions to Section VM-31 of the Valuation Manual applicable to qualified actuaries for clarification and consistency with the Standard Valuation Law. (March 25, 2016)
Joint Academy Life Experience Committee and SOA Preferred Mortality Oversight Group comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on the removal of the provisions for unisex rates as applied to reserves. (March 17, 2016)
Senior Pension Fellow Ted Goldman comments to the Senate Finance Committee on its hearing, “The Multiemployer Pension Plan System: Recent Reforms and Current Challenges.”
(March 17, 2016)
Comments to the NAIC executive committee by the Price Optimization Task Force on changes made to the proposed Price Optimization White Paper. (March 15, 2016)
Life Illustrations Work Group comments to the NAIC’s IUL Illustration (A) Subgroup on revisions to Actuarial Guideline (AG) 49. (March 14, 2016)
Role of the Actuary Subgroup comments to the NAIC’s Life Actuarial (A) Task Force (LATF) on revisions to the Corporate Governance Guidance Appendix, Section VM-G, of the Valuation Manual applicable to qualified actuaries for clarification and consistency with the Standard Valuation Law. (March 10, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's V-22 Subgroup of the Life Actuarial Task Force on statutory regulations regarding the determination of statutory valuation interest rates. (February 23, 2016)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed accounting standards update, Fair Value Measurement (Topic 820): Disclosure Framework. (February 18, 2016)