Life Comments and Letters

Risk Management and Solvency Committee comments to the IAIS on its Draft Standard on Group-wide Regulatory Requirements and Guidance on Group-wide Supervision Framework. (August 10, 2010)
Life Products Committee letter to Massachusetts Governor Deval Patrick regarding a bill (HB 889) to allow gender pricing at the Savings Bank Life Insurance Company. (June 4, 2010)
Invested Asset Work Group letter to the Capital Adequacy Task Force regarding the proposed increase to commercial real estate mortgage risk based capital. (June 2, 2010)
Life Practice Council letter to the National Association of Insurance Commissioners (NAIC) (EX) Working Group and Life Insurance and Annuities (A) Committee on principles-based valuation and capital approach (PBA) for life insurance. (May 12, 2010)
Life Financial Reporting Committee and Financial Reporting Committee comments on the FASB on exposure draft, Proposed ASU-Financial Services-Insurance (Topic 944): "Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts." (February 12, 2010)
Response from the LRWG on New York Insurance Department’s proposed changes to the use of economic scenarios in VM-20 (December 3, 2009)
Annuity Illustration Work Group letter to the Annuity Disclosure Working Group with more suggested revisions to an ACLI proposal for a model annuity illustration. (November 6, 2009)
Annuity Illustration Work Group comment letter to the NAIC Annuity Disclosure Working Group with suggested revisions to the ACLI model proposal. (September 14, 2009)
Life Financial Reporting Committee and Financial Reporting Committee comments to the IASB on its "Exposure Draft, Financial Instruments: Classification and Measurement." (September 14, 2009)
Valuation Table Team comment letter on concerns expressed by the American Council of Life Insurers to LHATF regarding the 2008 VBT Tables developed by the Valuation Basic Table Team. (July 28, 2009)
Annuity Illustrations Work Group comments to the Annuity Disclosure Working Group on a draft ACLI proposal for an annuity illustrations model regulation. (June 5, 2009)
Life Governance Team comments to the PBR (EX) Working Group on the latest exposure draft of the Valuation Manual section addressing corporate governance. (June 5, 2009)
Preferred Mortality POG report to LHATF on developing a 2008 CSO table, including the advantages and disadvantages of proceeding with development of a new table. (June 2, 2009)
Financial Soundness/Risk Managment Committee comments to NAIC Statutory Accounting Principles (E) Working Group on SSAP No. 56 exposure draft. (April 30, 2009)
Life Financial Soundness/Risk Management Committee comments on company generated scenarios. (August 31, 2008)
Reinsurance Work Group comments to the NAIC on risk transfer rules. (July 15, 2008)
Life Tax Steering Group comments on an IRS notice to life insurers about potential federal income tax issues concerning proposed principle-based reserving and proposed Actuarial Guideline VA-CARVM. (May 1, 2008)
Comments from Life, Health, and Casualty Practice Councils on life and health insurance principles proposed by the NAIC's Principle-based Reserving (EX) Working Group. (August 17, 2007)
Life Products Committee comments to the NAIC on travel-related life insurance provisions in a draft model trade law. (July 31, 2007)
Nonforfeiture Improvement Work Group follow-up questions on responses to LHATF questionnaire. (June 30, 2007)