Public Policy Comments and Letters

ERM/ORSA Committee Comments on NAIC’s “Draft Form A Review Best Practices” Exposure

ERM/ORSA Committee comments to the NAIC’s National Treatment and Coordination (E) Working Group on its “Draft Form A Review Best Practices” exposure document. (August 17, 2016)

Task Force Comments on Fed's Proposed Rule on Enhanced Prudential Standards

Financial Regulatory Task Force comments to the Federal Reserve Board (Fed) on its proposed rule on Enhanced Prudential Standards for Systemically Important Insurance Companies. (August 17, 2016)

Multiemployer Subcommittee Comments on Mergers and Transfers Between Plans

Multiemployer Subcommittee comment letter on the Pension Benefit Guaranty Corporation’s (PBGC) proposed rule on mergers and transfers between multiemployer plans.
(August 5, 2016)

Work Group Comments to NAIC on AG 49

Life Illustrations Work Group comments to the NAIC's IUL Illustrations (A) Subgroup regarding the extension of Actuarial Guideline 49 (AG 49) to all inforce life insurance illustrations. (August 1, 2016)

Work Group Comments to NAIC on Life Risk-Based Capital Formula

Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on how operational risk, including a prospective growth charge, might be better reflected in the Life Risk-Based Capital Formula. (July 27, 2016)

Joint FRC/COPLFR Letter on SEC S-K Disclosure Requirement

Financial Reporting Committee (FRC) and Committee on Property and Liability Financial Reporting (COPLFR) comments to the SEC on its concept release on the modernization of certain disclosure requirements in Regulation S-K. (July 21, 2016)

Work Group Comments to LATF on Statutory Valuation Interest Rates

SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 Subgroup of the Life Actuarial Task Force (LATF) in a question-and-answer format on the determination of statutory valuation interest rates. (July 15, 2016)

Pension Committee Comments on Improving Availability of IRS Actuaries with the Profession

Pension Committee comment letter on the decision by the Internal Revenue Service (IRS) to limit the pension actuaries’ potential to interact with IRS actuaries and other experienced employee-benefits personnel.
(July 15, 2016)

COPLFR Letter to NAIC on Inconsistencies in Loss Reserve Instructions for International Insurers

Comment letter from the Committee on Property and Liability Financial Reporting (COPLFR) to the NAIC noting inconsistencies in the instructions for certification of loss reserves for international insurers. (July 7, 2016)

LRWG Comments to LATF on VM-20 Product Aggregation

Life Reserves Work Group (LRWG) comments to the NAIC's Life Actuarial Task Force (LATF) on the exposed NAIC staff Amendment Proposal Form (APF) on VM-20 product aggregation. (July 5, 2016)

Council Comments to LATF on the Qualified Actuaries

Life Practice Council comments to the NAIC's Life Actuarial Task Force (LATF) on the qualified actuaries’ responsibilities to the interests of the company versus the commissioner. (June 30, 2016)

Subgroup Comments to LATF on Consolidated ACLI and Academy APF

Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on on the Consolidated ACLI and Academy Amendment Proposal Form. (June 22, 2016)

Pension Committee Comments on Late Premium Payment Relief

Pension Committee comment letter to the Pension Benefit Guarantee Corporation (PBGC) expressing appreciation for proposed regulations providing a reduction or partial waiver of the penalty due upon the late payment of premiums to the single employer and multiemployer insurance programs.
(June 22, 2016)

Subgroup Comments to LATF on Section 4 of VM-G

Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on Section 4 of the Valuation Manual-G. (June 10, 2016)

Pension Committee Comments on 2017 Applicable Mortality Tables

Pension Committee comment letter to the IRS and Treasury requesting that the 2017 Applicable Mortality Tables be issued as soon as possible. (June 10, 2016)

Intersector Group Notes from March Meeting with Treasury, IRS

Intersector Group notes of its March 2016 meeting with the Treasury Department and Internal Revenue Service. (June 7, 2016)

Intersector Group Notes from March Meeting with PBGC

Intersector Group notes of its March 2016 meeting with the Pension Benefit Guaranty Corporation (PBGC). (June 7, 2016)

Solvency Committee Comments on "Operational Risk 2016 Factors"

Solvency Committee comments to the NAIC's Operational Risk (E) Subgroup on its "Operational Risk 2016 Factors" exposure document. (June 6, 2016)

Subgroup Comments to LATF on Combined Revisions to VM-G

The Role of the Actuary Subgroup comments to the NAIC's Life Actuarial Task Force (LATF) on combined revisions regarding VM-G of the Valuation Manual. (June 3, 2016)

Council Letter to U.S. Senate Committee on Flood Insurance

Casualty Practice Council and P/C Extreme Events Committee letter to U.S. Senate Banking, Housing and Urban Affairs Committee on HR 2901, The Flood Insurance Market Parity and Modernization Act, concerning an expanded role for private insurers in the flood insurance marketplace. (May 25, 2016)