Vice presidents of the Academy’s Casualty Practice Council, Health Practice Council, Life Practice Council, and Risk Management and Financial Reporting Council provided comments to the NAIC’s newly established Risk-Based Capital (RBC) Model Governance (EX) Task Force on the task force’s 2025 goals and proposed charges.

The Data Science and Analytics Committee (DSAC) submitted comments to the International Association of Insurance Supervisors (IAIS) on IAIS' public consultation draft application paper on the supervision of artificial intelligence (AI).

The Financial Reporting Committee and the Life GAAP Reporting Committee sent an agenda request letter to the Financial Accounting Standards Board (FASB) encouraging FASB to consider a project related to portfolio layer method (PLM) hedge accounting for liabilities.

The Data Science and Analytics Committee commented to the U.S. Department of the Treasury on the Request for Information (RFI) on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector.

The Prudential Regulation Committee submitted comments to the International Association of Insurance Supervisors (IAIS) on its public consultation on climate risk supervisory guidance – ICP guidance and supporting material.

The Prudential Regulation Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Capital Adequacy (E) Task Force on the exposure draft of Risk-Based Capital Preamble, 2024-16-CA.

The ERM/ORSA Committee submitted comments to the Actuarial Standards Board regarding the proposed revision of Actuarial Standard of Practice (ASOP) No. 7, Analysis of Life, Health, or Property/Casualty Insurance Cash Flow Risk.

The Financial Reporting Committee and the Life GAAP Reporting Committee sent a comment letter to the Financial Accounting Standards Board (FASB) on the exposure draft of Chapter 6: Measurement, of Concepts Statement No. 8, Conceptual Framework for Financial Reporting.

The Prudential Regulation Committee submitted comments to the International Association of Insurance Supervisors (IAIS) on its consultation draft application paper on climate risk scenario analysis in the insurance sector.

The ERM/ORSA Committee's comments submitted to the Actuarial Standards Board (ASB) in response to the request of the ASB’s Enterprise Risk Management Committee to provide written comments on the Proposed Actuarial Standard of Practice: Enterprise Risk Management exposure draft.

The Risk Management and Financial Reporting Committee submitted comments on Sept. 1 to the NAIC on their Draft Model Bulletin Use of Algorithms, Predictive Models, and Artificial Intelligence Systems by Insurers. The comments, crafted in collaboration with the Academy’s Casualty, Life and Health Practice Councils, laud the framework’s focus on decisions as the key point of interest, and note the model will serve as a guide in assessing the depth and breadth of any necessary documentation and governance. The written comments compliment verbal comments given during the NAIC Summer Meeting last month.

The Prudential Regulation Committee sent a comment letter to the Federal Stability Oversight Council (FSOC) regarding FSOC's proposed Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies.

The Academy’s Climate Change Joint Task Force (CCJTF) submitted comments to the International Sustainability Standards Board (ISSB) on their Exposure Draft IFRS S2 Climate-related Disclosures. The draft builds upon the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD).

The Academy’s Climate Change Joint Task Force (CCJTF) submitted comments to the Securities and Exchange Commission (SEC) on their request for public input on the proposed rule, the “Enhancement and Standardization of Climate-Related Disclosures for Investors.”

The IFRS 17 Work Group of the Financial Reporting Committee submitted comments to International Financial Reporting Standards (IFRS) Foundation Interpretations Committee Chairperson Bruce Mackenzie on the foundation’s tentative agenda decision Transfer of Insurance Coverage under a Group of Annuity Contracts (IFRS 17).

The ERM/ORSA Committee's comments submitted to the IAIS as part of the association's Public Consultation on the Development of Liquidity Metrics: Phase 2.  

Climate Related Financial Disclosures Work Group report submitted to the NAIC’s Climate and Resiliency (EX) Task Force. This accompanies a comment letter from the Academy’s Climate Change Joint Task Force that addresses an exposed proposal by the NAIC for a new climate disclosure, based on the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) guideline and includes a series of observations and three specific suggestions. The report and associated comment letter to the NAIC are based upon research conducted by the Academy’s Climate-related Financial Disclosures Work Group.

Comment letter submitted to NAIC’s Climate and Resiliency (EX) Task Force. The comment letter from the Academy’s Climate Change Joint Task Force addresses an exposed proposal by the NAIC for a new climate disclosure, based on the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) guideline and includes a series of observations and three specific suggestions. The comments are based on research conducted by the Academy’s Climate-related Financial Disclosures Work Group.

Climate Change Joint Task Force comments to the U.S. Department of the Treasury and Federal Insurance Office (FIO) request for information (RFI) relating to regarding FIO's future work relating to the insurance sector and climate-related financial risks. 

The Data Science and Analytics Committee submitted comments in response to a joint request for information and comment from several federal agencies regarding financial institutions’ use of artificial intelligence (AI) and machine learning.