Public Policy Comments and Letters

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)
Intersector Group notes of its September 2016 meeting with the Treasury Department and Internal Revenue Service. (October 6, 2016)
Intersector Group notes of its September 2016 meeting with the Pension Benefit Guaranty Corporation (PBGC). (October 6, 2016)
Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2018 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, market reforms, and rate review provisions. (October 6, 2016)
C1 Work Group comments to the NAIC's Investment Risk Based Capital Working Group in response to the “Proposal for Life Bond Granularity and Related Issues” dated Sept. 6, 2016. (October 5, 2016)
Life Illustrations Work Group comments to the Actuarial Standards Board (ASB) on revisions to ASOP No. 24 Revision–Compliance with the NAIC Life Insurance Illustrations Model Regulation. (September 29, 2016)
Stress Testing Work Group comments to the NAIC's Stress Testing (E) Subgroup on providing assistance to help meet its charge. (September 28, 2016)
Nonforfeiture Modernization Work Group comments to the NAIC's Life Actuarial Task Force (LATF) with regard to potentially updating standard nonforfeiture laws. (September 28, 2016)
Health Practice Council letters to both the U.S. House and Senate on potential adverse consequences of legislation to weaken the Affordable Care Act’s (ACA) individual mandate. (September 22, 2016)
SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on Non-Jumbo and Jumbo Sample Calculations on valuation interest rates. (September 21, 2016)
Intersector Group meeting notes excerpt regarding Form 5500 clarifications from its September 2016 meeting with the Treasury Department and Internal Revenue Service. (September 19, 2016)
Financial Regulatory Task Force comments to the Federal Reserve Board (Fed) on its proposed rule on Capital Requirements for Supervised Institutions Significantly Engaged in Insurance Activities.
(September 16, 2016)
Pension Committee comments to U.S. Senate Special Committee on Aging Chairman Susan Collins on efforts to encourage open multiple employer plans.
(September 1, 2016)
Life Products Committee comments to the Actuarial Standards Board (ASB) on the proposed Actuarial Standard of Practice (ASOP) that applies to the pricing of life insurance and annuity products. (August 24, 2016)
Lifetime Income Risk Joint Task Force comment letter to the Department of Labor concerning proposals for increasing retiree income options, with a focus on additional safe harbors that encourage delivering lifetime income.
(August 19, 2016)
ERM/ORSA Committee comments to the NAIC’s National Treatment and Coordination (E) Working Group on its “Draft Form A Review Best Practices” exposure document. (August 17, 2016)
Financial Regulatory Task Force comments to the Federal Reserve Board (Fed) on its proposed rule on Enhanced Prudential Standards for Systemically Important Insurance Companies. (August 17, 2016)