RMFRC Comments and Letters

Reinsurance Committee comments to the National Association of Insurance Commissioners (NAIC) on the draft Certified Reinsurers and Passporting Public Document. (September 11, 2015)
Solvency Committee comments to the National Association of Insurance Commissioners (NAIC) on the Discussion Draft on Approaches to a Group Capital Calculation dated July 23, 2015. (August 7, 2015)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Higher Loss Absorbency Capacity for Global Systemically Important Insurers (G-SIIs) public consultation document dated June 25, 2015. (August 6, 2015)
The Casualty Practice Council, Health Practice Council, Life Practice Council, and Risk Management and Financial Reporting Council comments to the National Association of Insurance Commissioners (NAIC) on its Financial Condition (E) Committee questionnaire that examines the reasons for single-state solutions to help regulators develop a process for creating a uniform framework for state-based regulation. (July 27, 2015)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on issues raised during the May 21, 2015 educational session related to retrospective unlocking in long-duration contracts. (July 22, 2015)
Risk Management and Financial Reporting Council (RMFRC) comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers discussion draft. (July 21, 2015)
The Financial Reporting Committee, Pension Accounting Committee, Casualty Committee on Property and Liability Financial Reporting, Health Financial Reporting and Solvency Committee, and Life Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) “The Auditor's Use of the Work of Specialists” consultation paper. (July 15, 2015)
Risk Management and Financial Reporting Council letter to the Federal Reserve Board on issues related to a “margin over current estimate” (MOCE) for international insurance capital standards. (July 14, 2015)
Financial Regulatory Task Force (FinReg) letter to the U.S. House Financial Services Committee (HFSC) on the Financial Stability Oversight Council (FSOC) 2015 annual report. (June 17, 2015)
Risk Management and Financial Reporting Council comments to the International Association of Insurance Supervisors (IAIS) on Insurance Core Principle (ICP) 8: Risk Management and Internal Controls. (May 12, 2015)
ERM/ORSA Committee comments to the International Association of Insurance Supervisors (IAIS) on its draft issues paper Conduct of Business Risk and its Management. (May 1, 2015)
Financial Reporting Committee comments on the Financial Accounting Standards Board's (FASB) proposed accounting standards update-Derivatives and Hedging (Topic 815): Disclosures about Hybrid Financial Instruments with Bifurcated Embedded Derivatives. (April 30, 2015)
Risk Management and Financial Reporting Council and Financial Reporting Committee comments to the Federal Insurance Office (FIO) on U.S. GAAP loss recognition testing and Insurance Core Principle (ICP) 14 current estimates. (April 27, 2015)
Financial Regulatory Task Force comments to the Financial Stability Oversight Council (FSOC) on the impact of insurance asset management products and activities to U.S. financial stability. (March 23, 2015)
Solvency Committee comments to the International Association of Insurance Supervisors on the Risk-based Global Insurance Capital Standard public consultation document dated Dec. 17, 2014. (February 6, 2015)
Financial Reporting Committee comments to the International Accounting Standards Board (IASB) on its treatment of participating contracts in its insurance contracts project in follow-up to a November conference call. (December 23, 2014)
Financial Regulatory Task Force comments to the Government Accountability Office (GAO) on its global capital standards report. (December 16, 2014)
Risk Management and Financial Reporting Council comments to the Financial Stability Board (FSB) on the consultative document: Recovery and Resolution Planning for Systemically Important Insurers: Guidance on Identification of Critical Functions and Critical Shared Services. (December 15, 2014)
Solvency Committee comments to the National Association of Insurance Commissioners on the U.S. Group Capital Methodology Concepts Discussion Paper. (December 5, 2014)
Solvency Committee comments to members of the U.S. House of Representatives and the U.S. Senate in support of passage of the Insurance Capital Standards Clarification Act of 2014, which clarifies that the Federal Reserve has the authority to differentiate between banks and insurers in terms of capital requirements. (December 2, 2014)