RMFRC Comments and Letters

Solvency Committee comments to the NAIC and IAA on the IAIS ComFrame paper concerning the relationship beween IAIGs and supervisors and the framework for supervisors to address group-wide activities and risks. (July 27, 2012)
Financial Regulatory Reform Task Force comments to the Federal Reserve on its proposed rule establishing additional prudential standards to apply to non-bank financial service companies identified by the Financial Stability Oversight Council as companies that could pose systemic risk. (April 30, 2012)
Risk Management and Financial Reporting Council letter to the Department of Treasury urging that actuarial science be one of the specific considerations for members of the proposed Financial Research Advisory Committee that will support the work of the Office of Financial Research. (April 13, 2012)
Financial Reporting Committee responses to questions posed in FASB's Revenue Recognition paper. (March 13, 2012)
International Accounting Standards Task Force comments on the topic of defining the contract boundary for insurance contracts. (December 21, 2011)
Financial Regulatory Reform Task Force comments to the FSOC on proposed rule relating to systemically important financial institutions. (December 19, 2011)
Financial Regulatory Reform Task Force comments to the FIO on how to modernize and improve the U.S. system of insurance regulation. (December 16, 2011)
ERM Committee comments on wording suggestions to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual recognizing the model risk for insurers. (October 28, 2011)
Financial Reporting Committee and International Accounting Standards Task Force response to the International Accounting Standards Board (IASB) on its Agenda Consultation 2011 paper. (October 27, 2011)
DTA Bridge Group letter to the NAIC relating to the SSAP No. 101 - Income Taxes, A Replacement of SSAP No. 10R and SSAP No. 10 recently adopted by the NAIC’s Statutory Accounting Principles Working Group. (October 25, 2011)
Financial Reporting Committee letter to the Public Company Accounting Oversight Board (PCAOB) on the issues surrounding the auditor’s report based on recent investor feedback. The committee’s comments included a recommendation to increase disclosure and provide more detail to the auditor's reporting model. (September 30, 2011)
ERM Committee comments to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual supporting its view that the manual offers ORSA guidance which focuses on the most fundamental components of a strong ERM framework. (August 25, 2011)
Solvency Committee's comments to the International Association of Insurance Supervisor (IAIS) on its concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. These comments further address the methods of operating group-wide supervision of internationally active insurance groups. (August 25, 2011)
Solvency Committee comments to the NAIC on its ComFrame Concept Paper Draft US Responses and supports the position that the modules should be outcome-oriented rather than prescriptive. (August 15, 2011)
Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisor (IAIS) concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. The committee addressed questions presented in the paper relating to Own Risk & Solvency Assessment (ORSA), corporate governance, and Enterprise Risk Management. (July 27, 2011)
Financial Regulatory Reform Task Force letter to the Department of the Treasury outlining the metrics intended to aid in identifying systemic risk in the insurance sector. (June 24, 2011)
Reinsurance Subcommittee letter to the IASB on its Insurance Contracts Exposure Draft regarding recognition of gains and losses on reinsurance ceded for long duration contracts. (April 11, 2011)
Solvency Committee comments to the IAA and additional comments to the NAIC on the IAIS paper, ICP 14: "Valuation for Solvency Purposes." (March 24, 2011)
Solvency Committee comments on the IAIS paper, ICP14: 'Valuation for Solvency Purposes.' (March 24, 2011)
ERM Committee comments to the NAIC on its U.S. Own Risk and Solvency Assessment (ORSA) Proposal. (March 18, 2011)