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.  

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 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.

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. 

The Climate-Related Financial Disclosures Work Group and the Actuaries Climate Index/Actuaries Climate Risk Index Work Group comments to the New York State Department of Financial Services on financial risks related to climate change.

The Climate-Related Financial Disclosures Work Group and the Actuaries Climate Index/Actuaries Climate Risk Index Work Group comments to the U.S. Securities and Exchange Commission on climate disclosures.

ERM/ORSA Climate-Related Financial Disclosures Work Group comments to the NAIC Climate and Resiliency (EX) Task Force's Climate Risk Disclosure Workstream. 

Solvency Committee comments to the Federal Insurance Office on its Study on the Insurance Capital Standard (FIO ICS Study).

ERM/ORSA Committee's Climate Related Financial Disclosures (CRFD) Work Group comments to International Association of Insurance Supervisors (IAIS) on its Application Paper on the Supervision of Climate-related Risks in the Insurance Sector. 

Data Science and Analytics Committee (DSAC) Chair, Dorothy Andrews, addressed the issue of Race in Insurance Underwriting in a meeting convened by the National Council of Insurance Legislators and shared an update on the DSAC's work on the topic.

Data Science and Analytics Committee (DSAC) Chair, Dorothy Andrews, addressed the issue of Race in Insurance Underwriting in a meeting convened by the National Council of Insurance Legislators and shared an update on the DSAC's work on the topic.

The Financial Reporting Committee and Life Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) regarding indexing and modco embedded derivatives.

The Financial Reporting Committee comments to the American Institute of Certified Public Accountants (AICPA) regarding Targeted Improvements to Long-Duration Contracts Implementation Issue 11AC (ceded reinsurance), to be included in the Audit and Accounting Guide: Life and Health Insurance Entities.