Life Comments and Letters

Comment letter to the National Association of Insurance Commissioners' Principles-Based Reserving (E) Working Group with suggested changes to its November 2012 draft implementation plan for principle-based reserving of life insurance. (January 11, 2013)
Comments by the Annuity Illustration Subgroup on selected FAQs in the October 18, 2012 Iowa Insurance Division draft memorandum, Fixed Indexed Annuity Illustrations and Iowa Administrative code rules 15.61-.69. (December 11, 2012)
Comments by the Actuarial Guideline 43 / C-3 Phase II Work Group to the NAIC’s C-3 Phase II/AG 43 (E) Subgroup on its November 1, 2012 Work Plan Draft. (December 10, 2012)
Contingent Annuity Work Group comments on the definition of Contingent Deferred Annuities proposed by the ACLI and IRI and exposed by the Contingent Deferred Annuities (A) Working Group. (November 19, 2012)
Invested Asset Work Group comment letter to the NAIC Risk-based Capital (RBC) Working Group on American Council of Life Insurers’ Commercial Mortgage RBC Proposal. (November 14, 2012)
Life Practice Council comment letter to the NAIC commending the inclusion of a budget item for the purposes of “Actuarial Guideline 38/Principle-Based Reserving Implementation and Monitoring. (November 9, 2012)
Report to NAIC C-3 Phase II/Actuarial Guideline 43 Subgroup detailing ideas for a C-3 Phase II/Actuarial Guideline 43 review process.  (October 12, 2012)
Casualty, Life, Health, Professionalism, and Financial Reporting Council comments to the NAIC's Corporate Governance Working Group on its Proposed Responses to a Comparative Analysis of Existing U.S. Corporate Governance Requirements. (September 28, 2012)
C1 Work Group draft project plan to the National Association of Insurance Commissioners (NAIC) C1 Factor Review (E) Subgroup that covers the development of the bond Risk-based Capital (RBC) factors and changes to the RBC determination for structured securities. (August 3, 2012)
Comment letters to both the NAIC Life Actuarial Task Force and the Life and Annuities (A) Committee from the Academy's Life Practice Council and Life Financial Reporting/Risk Management Committee regarding the need for changes to the valuation manual as well as a formal updating and review process. (July 16, 2012)
Invested Asset Work Group comments to the NAIC Valuation of Securities (E) Task Force related to modification of the methodology for assigning classifications to investments and changing how classification decisions are implemented. (June 20, 2012)
Life Financial Soundness/Risk Management Committee presentation of NAIC's Life and Health Actuarial Task Force Amendment proposal outlining a simplified approach for determining prudent estimate mortality assumption for VM-20. (June 18, 2012)
Actuarial Guideline 43/C-3 Phase II Work Group comments to the NAIC C-3 Phase II/AG 43 Working Group regarding their current deliberations. (June 15, 2012)
Annuity Illustration Work Group comments to the NAIC Annuity Disclosure Working Group regarding the latest drafts of the NAIC Annuity Buyer’s Guides distributed on May 15, 2012. (June 15, 2012)
Life Practice Council letter to the NAIC Blanks Committee with comments on blanks proposal 2012-04. (May 14, 2012)
The Academy Life Valuation Subcommittee submitted a comment letter to the NAIC Joint Working Group of the Life Insurance and Annuities (A) Committee and Financial Condition (E) Committee regarding their draft Framework on Actuarial Guideline 38.
(January 30, 2012)
Contingent Annuity Issues Work Group analysis assisting the National Association of Insurance Commissioners in its work involving contingent annuities. (October 28, 2011)
Tax Work Group, in conjunction with the Nonforfeiture Improvement Work Group, follow-up comment letter to the Life Actuarial Task Force with suggested revisions to VM-20. (October 12, 2011)
Tax Work Group in conjunction with the Nonforfeiture Improvement Work Group comment letter to the Life Actuarial Task Force regarding issues associated with proposed language in VM-02. (October 3, 2011)
Invested Assets Working Group comments on the NAIC's Securities Valuation Office staff reports related to the rating agency working group charges. (February 24, 2011)