Life Comments and Letters

Casualty, Health, Life, and Professionalism Council comments to the NAIC’s Joint Qualified Actuary (A/B/C) Subgroup in response to its request for comments to a list of nine questions in anticipation of the Subgroup’s meeting at the NAIC Spring National Meeting on April 5, 2013. (March 27, 2013)
Separate Account Products Work Group (SAWG) comments on the December 20, 2012 document, “Review of Non-Variable, Insulated Products/Product Characteristics with Proposed Recommendations” exposed on January 9 by the NAIC Separate Account Risk (E) Working Group. (March 25, 2013)
Annuity Illustration Work Group comments to the Iowa Insurance Division on its March 18 draft memorandum: Annuity Illustrations; 191 Iowa Administrative Code rules 15.61-.69, based upon the new NAIC Annuity Disclosure Model Regulation.
(March 22, 2013)
C1 Work Group request for data from the NAIC Capital Markets Bureau for use to assist the NAIC's Investment Risk-Based Capital Working Group with developing the risk-based capital requirements for corporate bonds.  (March 18, 2013)
Contingent Annuity Work Group comments on the NAIC Contingent Deferred Annuity (A) Working Group's February 13 draft recommendation to the Life Insurance and Annuities (A) Committee. (February 20, 2013)
C1 Work Group comments on the NAIC Securities Valuation Office Staff Recalibration Project.  (February 12, 2013)
Councils' letter to NAIC's Joint Qualified Actuary (A/B/C) Subgroup on the subgroup's two new charges related to defining a "qualified actuary" and recommending a process to address "unprofessional" actuarial work. (February 11, 2013)
Deposit Fund Subgroup proposal for reserving synthetic GICs based upon the Subgroup's report presented to the Life Actuarial Task Force on November 28, 2012. (February 8, 2013)
Annuity Illustration Subgroup comments to the Iowa Insurance Division on its December 12, 2012 draft memorandum regarding annuity illustrations. (January 25, 2013)
Comments by the Annuity Illustration Subgroup to the NAIC Annuity Disclosures (A) Working Group on the November 28, 2012 draft of the Buyers Guide for Deferred Annuities. (January 18, 2013)
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)