Life Comments and Letters

Life Reserves Work Group (LRWG) comment letter to the National Association of Insurance Commissioners’ Life Actuarial Task Force exposed VM-20 Amendment Proposal Form (APF) on term insurance riders, labeled VM Maintenance Agenda Item 2017-40. (August 28, 2017)
Life Experience Committee amendment proposal form to the NAIC's Life Actuarial Task Force to implement guaranteed issue mortality tables under current formula requirements. (August 4, 2017)
Life Experience Committee amendment proposal form to the NAIC's LIfe Actuarial Task Force to implement guaranteed issue mortality tables under principle-based reserve requirements. (August 4, 2017)
C1 Work Group comments to the NAIC's Investment Risk-Based Capital Working Group (IRBC) on their recent proposal on RBC requirements for real estate. (July 24, 2017)
Accelerated Underwriting Project Oversight Group (reporting to the Academy's Life Experience Committee and SoA's Preferred Mortality Oversight Group) comments to NAIC's Life Actuarial Task Force (LATF) discussing future experience study data elements. (July 14, 2017)
VM-31 Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on an amendment to eliminate the summary of methods and assumptions that covers multiple product groups in the executive summary.  (July 10, 2017)
Non-Guaranteed Elements Work Group comments to the New York Department of Financial Services on re-proposed 11NYCRR 48 (insurance regulation 210) on life insurance and annuity non-guaranteed elements. (June 22, 2017)
C1 Work Group comments to the NAIC with revised recommendations on corporate bond risk-based capital (RBC) factors based on changes to the representative portfolio. (June 8, 2017)
PBR Governance Work Group comments to the Actuarial Standards Board (ASB) on the exposure draft for a new ASOP, Principle-Based Reserves for Life Products. (May 31, 2017)
Operational Risk Work Group comments to the NAIC on the implementation of the Life Risk-Based Capital operational risk factor.  (May 25, 2017)
Life Reserves Work Group amendment proposal form to the National Association of Insurance Commissioners Life Actuarial Task Force regarding the VM-20 wording on modeling of policy loans and separate account assets. (May 12, 2017)
Life Reserves Work Group comments on the National Association of Insurance Commissioners' (NAIC) Life Actuarial Task Force exposed amendment proposal form related to additional definitions under VM-20. (May 2, 2017)
Life Reserves Work Group comments on the National Association of Insurance Commissioners' (NAIC) Life Actuarial Task Force exposed amendment proposal form related to VM-20 Section 2G on model segmentation and the proposed alternative guidance note.
(May 2, 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)
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)
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)
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)