Guidelines for making public statements
(Adopted by the Board of Directors February 28, 2023)
I. What Constitutes an Academy Public Statement
For purposes of these Guidelines, an Academy “public statement” is a written or oral statement made on behalf of the organization or any Academy committee (e.g., board, council, committee, subcommittee, taskforces, etc.) to any other entity or the public. Statements of opinion representing the views of an individual member are not Academy public statements under these Guidelines. Examples of Academy public statements include:
A. Comment letters, testimony, amicus curiae briefs, or formal comments submitted to legislative, executive, judiciary, regulatory, and investigative bodies at the federal, state, and local levels.
B. Letters, oral presentations, or other submissions to professional and other interest groups or nongovernmental organizations (e.g., the American Bar Association, Financial Accounting Standards Board, the Government Accounting Standards Board, the International Accounting Standards Board, the National Association of Insurance Commissioners).
C. Articles, letters to the editor, and other expository submissions to the media, including newspapers, periodicals, television, radio, and other mass media.
D. Alerts, announcements, or other submissions to members or the public on topics impacting or important to members or the public where the Academy or the actuarial profession has a perspective to convey through various communication channels, such as social media posts, videos, emails, and other communication options.
II. The Scope of Academy Public Statements
Academy public statements should be consistent with the Mission and Vision of the Academy and grounded in actuarial science or principles. However, it may be appropriate for the Academy to issue a public statement that goes beyond the areas where the actuary’s knowledge is unique if that statement will contribute to discourse on an issue that is of interest to the Academy, its members, and the public.
The scope, tone, and nature of an Academy public statement should reflect the integrity and credibility of the actuarial profession as well as the independent and objective role of the Academy. Statements should contain a clear, concise, and balanced presentation of significant facts and valid inferences, including relevant benefits and costs. An Academy public statement may express diverse and balanced opinions based upon significant fact and valid inferences, consistent with the Academy’s mission and vision to provide the public and actuarial professionals practicing in the U.S. with the benefit of the full range of the profession’s capabilities.
While a public statement should not advocate for specific positions on issues or specific solutions to address those issues, it may be appropriate to point out relevant economic, social, and political implications insofar as these implications can be objectively determined and referenced.
III. Development and Delivery of Public Statements
Academy members and staff should generally follow these Guidelines in the development and delivery of Academy public statements, although these procedures may be modified from time to time to ensure the timeliness and effectiveness of certain statements. In particular, mass media communications (print, broadcast, or online) are considered to be a special form of public communication because media deadlines frequently prevent the utilization of the review processes described in these Guidelines. When letters to the editor, radio or television interviews, or other media submissions are anticipated, the Academy’s communications team will provide special guidance and direction to the chairperson of the Academy committee and the relevant Board officer, e.g. Academy leadership and practice council Vice President (VP) or their designee, that prepared the public statement or the member who is expected to act as the Academy’s spokesperson. Academy communications staff will manage the outreach to and relationship with the media contact on behalf of the Academy, and any spokesperson should be media trained before participating in media outreach on behalf of the Academy.
A. Identification of Issues. In deciding whether to issue a public statement and what the content of the statement will be, Academy committees should coordinate with appropriate staff (including relevant staff liaison, fellow, and/or senior staff member), committee chairpersons, or Board officers. Academy staff may identify an issue that is not specifically actuarial in nature but may be important to the Academy, its members, and the public.
B. Authority to Proceed. Academy public statements should be coordinated by Academy staff and only issued with the agreement of the Academy Board officer (i.e., President, President-Elect, relevant Vice President, Secretary-Treasurer) or the Past President; and the Academy Executive Director or designated senior staff member, subject to applicable peer, legal, policy, and communications review. If staff or relevant officers identify a matter that may warrant an Academy public statement, they will assign it to an appropriate Academy committee to develop. If staff or relevant officers identify a matter that may warrant an Academy public statement on a topic that is not related to actuarial practice but is important to the Academy, its members, and the public, the Executive Director and Director of Communications will coordinate with the members of the Presidential Advisory Council. Academy communications staff will manage the development and distribution of such statements on behalf of the Academy. If an Academy committee identifies a matter that may warrant a public statement, the committee may develop the public statement if authorized to do so by the Academy senior staff and by the relevant Academy Board officer. If a committee identifies an issue that is significant for more than one practice area, staff leaders and the relevant Academy Board officers will discuss the matter, determine which Academy committee will develop the statement, and then arrange for proper coordination among interested Academy committees, including whether the statement should be issued jointly. VPs may, at their discretion, seek advice from their practice councils and other VPs to resolve “jurisdictional” issues and achieve proper coordination.
C. Development of Public Statements. Academy committees will prepare Academy public statements and supporting materials as follows:
- An Academy public statement generally reflects the opinions of the Academy committee that prepared it and should represent the Academy’s overall mission, vision, and strategic goals. In addition, it may be appropriate for the committee to involve other Academy members whom the committee identifies and considers to have pertinent expertise. In some instances, the chairperson of the committee preparing the public statement may decide, in coordination with staff and with the approval of the relevant officer, that it would be beneficial to involve non-Academy members, including non-actuaries.
- When addressing issues that are expected to be controversial, the chairperson and relevant Academy Board officer should seek broader input from staff and Academy leadership. If member input is deemed appropriate, Academy staff will select the means used to obtain that input in appropriate consultation with the Academy president and the chairperson of the committee preparing the public statement. Academy staff and the relevant Board officer are initially responsible for determining whether an issue is expected to be controversial and the appropriate course of action.
- Staff is available to facilitate the preparation and distribution of Academy public statements, and committee members will work collaboratively with staff to produce statements that are consistent with the Academy’s mission, vision, and previous public statements.
- Staff may also develop Academy public statements (e.g., amicus curiae briefs) from time to time. Such statements may be developed with the input of the appropriate chairperson and relevant Board officer and should be circulated to the members of an appropriate Academy committee and practice council for comment before release, absent extraordinary time constraints.
- The chairperson should seek a consensus of the group that prepares the public statement. If there is a substantial lack of consensus, the chairperson may elect to incorporate the various perspectives into the statement, refer the issue to the relevant Board officer and/or senior staff, or decide not to issue the public statement. In some cases, time constraints may prevent the entire committee from participating in the completion of a particular statement, and the task of drafting the statement may be left to the chairperson or the chairperson’s designee(s). In such cases, the drafters should communicate with and seek maximum input from available committee members to the extent possible.
- A relevant Board officer and senior staff may agree to release a statement before completion of peer review only under extraordinary circumstances and with the approval of the appropriate Board and senior staff member. Otherwise, no Academy public statement should be released or presented without appropriate peer review. The appropriate level of peer review varies, depending on the level of risk and exposure of the statement. Before release, statements must be approved by the relevant officer or designee and Academy public policy and communications staff, and, when called for, legal/professionalism staff. Peer review usually should include one or more Academy members who are not involved in the drafting/development of the statement in addition to the relevant officer (or designee) and staff. The peer reviewers, to be selected by the chairperson with approval of the relevant officer, should be knowledgeable and experienced in the subject matter and the Academy’s role in conveying unbiased, independent, and objective analysis, perspective, and expertise.
- The decision to issue a final public statement rests with the relevant Board officer and senior Academy staff. The Board officer may delegate this responsibility to staff leadership, the committee chairperson, or other designee. For issues of major importance or those deemed controversial, the Executive Director, President and Academy General Counsel should also be consulted before the statement is released to its intended audience.
- When deemed appropriate by the relevant Board officer, a recommendation should be made to the President that a proposed statement be submitted to the Board of Directors for review before issuance. The Board may modify or disapprove a public statement if it believes such action is in the best interests of the Academy.
D. Presentation of Public Statements. The committee issuing an Academy public statement must be identified as responsible for the statement with sufficient disclaimers that make clear a distinction between what is an Academy statement versus a statement from a specific committee. Except when the forum requires it—for example, in court proceedings or international settings—blanket sponsorship by the entire Academy may not be stated or implied, unless the statement is issued by the President or the Board of Directors. While statements issued by the President or the Board of Directors may be identified as being made on behalf of the Academy, statements made by individuals or committees should not be identified as such.
Academy public statements are not attributed to individual members of the group that developed them. In some cases, however, an individual member, like a chairperson, is identified as making statement on behalf of "committee" issuing the statement. In addition, identifying members of the group may add to the credibility of the statement or serve some other purpose, such as meeting the expectations of the intended audience. The decision to identify individual authors should be made in consultation with the relevant officer and Academy staff. Unless there is good reason not to do so, non-actuaries who participated in the formulation of the statement should be identified and their non-Academy member status and role identified in footnotes or otherwise. Any statement that involves issues of significance to multiple practice areas should clearly identify the practice areas to which the statement is intended to apply. All public statements should be dated and submitted in written form, with an oral presentation as appropriate.
If an oral presentation concerning an Academy public statement is to be made, the chairperson of the committee that developed the statement and relevant officer will select the person or persons to make the presentation with an expectation that they have completed relevant media training or made use of the Academy’s resources for making presentations. When an individual makes an oral presentation on an Academy public statement—for example, when testifying concerning the content of the statement before Congress—the individual should state that they have been designated as the representative of the Academy committee that prepared the public statement, and that the views expressed by the individual represent the consensus views of the Academy committee that prepared the public statement. No individual making an oral presentation on an Academy public statement should express the views of their client or employer when making the presentation. If, through questioning or other means, the individual is required to express a personal opinion concerning the subject of the public statement, the individual should identify the opinion expressed as their own and not the opinion of the Academy committee that developed the public statement or the Academy itself. Even when statements are responses to technical methodological inquiries, the general issue being addressed should be clearly specified in an initial sentence or two. A formal statement about the Academy should be included in the public statement. A member of the Academy who is identified as an Academy member when speaking on behalf of their client or company should reiterate that they are not representing the Academy.
Any member who participates in a media interview or other media contact should note that the views expressed by that member are not necessarily those of the Academy.
E. Distribution of Statements. After an Academy public statement has been completed and, if applicable, formally submitted, the statement will be available for broader distribution. The statement will be posted on the Academy’s website and may be disseminated through various Academy communications channels (e.g., email, newsletters, social media). If a statement rises to a more public level, the Academy may issue a media release as well or send the statement directly to interested reporters.
F. Letters to the editor. Letters to the editor should follow the steps below:
- The Communications Director should be contacted in anticipation of the development and submission of a letter to the editor. The originating chairperson or spokesperson and the director will discuss the communication objectives of the proposed letter and engage the relevant staff and VP, committee chair and/or primary drafter for input and support to move forward.
- The Communications Director will discuss the proposed letter to the editor with the staff liaison of the relevant Academy committee and work with staff to arrive at consensus on the value of the letter and its content, and also to identify an appropriate letter signer.
- The Communications Department and the letter signer will develop the letter with support and expedited reviews. These reviews will include peer, policy, and communications reviews of the final draft by the relevant staff and VP(s). When called for, the General Counsel will perform a legal/professionalism review of the final draft. The final draft will be shared with the Executive Director for a final organizational review.
IV. Description of the Academy
The description of the American Academy of Actuaries changes periodically, so the most recent and relevant one should be obtained by the Communications Director and used as appropriate.
V. International Public Statements
From time to time, the Academy may wish to make public statements in an international context. Statements by the Academy may be developed by the appropriate Academy committee in accordance with the preceding sections of these Guidelines, except that such statements will generally be issued on behalf of the Academy as a whole and should be reviewed by senior Academy staff and the President or the President’s designee before their release. Final approval to issue or join in an international public statement is generally granted by the President with advice of the VP(s) for the relevant practice area(s). When deemed appropriate by the President, the proposed statement will be submitted to the Board of Directors, which may modify or disapprove the statement if it believes such action is in the best interests of the Academy.
VI. Statements Requiring Immediate Action
On occasion, the Academy may need to comment within a shorter timeframe than required above. In those cases, the Executive Director will work with the Academy’s Communications Department to apply the criteria set forth in these guidelines and consult with the President, relevant VP, and other subject matter experts as appropriate during the process. These public statements will be made through social media, the Academy’s website, or Academy newsletter channels.