No. A software tool would be similar to a computer program, which is referenced in the U.S. Qualification Standards Appendix 1, Part II, Section D, as a communication that is not an SAO when used alone without an opinion about what the results suggest (Section 1 and Appendix 1).

Last updated December 2014

A: When an actuary is asked, “What is the health care trend you have experienced for your commercial business?” and he or she replies, “10%.”
 
B: When an actuary is asked, “What is the expected health care trend for your commercial business for next year?” and he or she replies, “10%.”

Situation A is not an SAO, assuming the actuary's reply is based on compiled data alone without any actuarial considerations.
 

No. Actuaries must comply with the USQS before issuing their first SAO in the United States (Section 1 and Appendix 1).  There are differences between the CAS and SOA CPD requirements and the USQS continuing education requirements, and therefore it is important to note that any actuary credentialed by any of the five U.S.-based actuarial organizations that issue SAOs in the US must meet the USQS prior to providing SAOs. An actuary does not need to be a member of the American Academy of Actuaries to be required to adhere to the USQS.

The definition of an SAO in the U.S. Qualification Standards (USQS) is very broad, and it is likely that many actuarial communications fall under the definition of an SAO. Actuaries are reminded that if they issue just one SAO in a calendar year, they need to comply with the USQS. The combination of the broad definition of an SAO and the fact that issuing just one SAO requires compliance means that most actuaries performing Actuarial Services in the U.S.

Although the U.S. Qualification Standards (USQS) contemplates some situations where it may be possible for an actuary to label an SAO a “draft” for purposes of the Principal’s expectation and reliance, great care must be taken not to try to strain interpretations of what a reasonable Principal would consider an SAO regardless of the word “draft” on an opinion. Appendix 1 of the USQS contains more detailed information on this subject.

Enrolled actuaries who are also members of one or more of the five U.S.-based actuarial organizations and who issue Statements of Actuarial Opinion (SAOs) must satisfy the USQS CE requirements except in the event that the enrolled actuary issues only SAOs related to Form 5500 Schedule B certification and other ERISA forms. Enrolled actuaries who issue only Schedule B certification and other ERISA forms are encouraged to comply with the USQS (Section 2.2.8). Enrolled Actuaries are required to comply with the CE requirements issued by the Joint Board for the Enrollment of Actuaries.

Section 5 of the U.S. Qualification Standards (USQS) states that every Statement of Actuarial Opinion should include an appropriate acknowledgement of the actuary’s qualifications. ASOP No. 41, Actuarial Communications, notes that actuarial communications are often an ongoing and iterative process. As such, it may not be necessary for an actuary to include his or her qualifications in every piece of communication.

Actuaries issuing Statements of Actuarial Opinion in the United States must comply with all of the requirements in the USQS regardless of their status as “retired” (Sections 2 and 3).  If an actuary is retired and does not issue any SAOs, then the USQS would not apply to that actuary. However, there are no grace periods in the USQS for retirees, so, if an actuary issues an SAO, even one SAO and even on a “free” basis in the U.S., he or she must meet the USQS including the CE requirements.

Last updated December 2014