Life Comments and Letters

Valuation Table Team Comment Letter to LHATF on ACLI Concerns

Valuation Table Team comment letter on concerns expressed by the American Council of Life Insurers to LHATF regarding the 2008 VBT Tables developed by the Valuation Basic Table Team. (July 28, 2009)

AIWG Comments on Annuity Disclosure Model Regulation

Annuity Illustrations Work Group comments to the Annuity Disclosure Working Group on a draft ACLI proposal for an annuity illustrations model regulation. (June 5, 2009)

Life Governance Team Comments to NAIC PBR (EX) Working Group

Life Governance Team comments to the PBR (EX) Working Group on the latest exposure draft of the Valuation Manual section addressing corporate governance. (June 5, 2009)

Preferred Mortality POG Report to LHATF on 2008 CSO Table Development

Preferred Mortality POG report to LHATF on developing a 2008 CSO table, including the advantages and disadvantages of proceeding with development of a new table. (June 2, 2009)

FSRM Comments on SSAP No. 56 Exposure Draft

Financial Soundness/Risk Managment Committee comments to NAIC Statutory Accounting Principles (E) Working Group on SSAP No. 56 exposure draft. (April 30, 2009)

Comments on Company Generated Scenarios in VM-20

Life Financial Soundness/Risk Management Committee comments on company generated scenarios. (August 31, 2008)

Comments to NAIC on Proposed VM-20 Amendment 080329 005

Reinsurance Work Group comments to the NAIC on risk transfer rules. (July 15, 2008)

Comments on IRS Notice to Life Insurers on Potential Income Tax Issues

Life Tax Steering Group comments on an IRS notice to life insurers about potential federal income tax issues concerning proposed principle-based reserving and proposed Actuarial Guideline VA-CARVM. (May 1, 2008)

Comments on Life, Health Insurance Principles Proposed by NAIC PBRWG

Comments from Life, Health, and Casualty Practice Councils on life and health insurance principles proposed by the NAIC's Principle-based Reserving (EX) Working Group. (August 17, 2007)

Comments on Proposed Changes to Unfair Trade Practices Model Act

Life Products Committee comments to the NAIC on travel-related life insurance provisions in a draft model trade law. (July 31, 2007)

NIWG Follow-Up Questions to LHATF on Questionnaire

Nonforfeiture Improvement Work Group follow-up questions on responses to LHATF questionnaire. (June 30, 2007)

Comment Letter to FASB on Accounting for Life Insurance Contracts

Life Financial Reporting Committee comment letter to FASB on accounting for life insurance contracts acquired in a business combination. (April 2, 2007)

Updated Draft Actuarial Guidelines on Reserve Documentation and Disclosure

Life Reserves Work Group update on draft actuarial guidelines on reserve documentation and disclosure. (December 1, 2006)

Updated Actuarial Guideline PBR-VAL from LRWG

Updated Actuarial Guideline PBR-VAL from the Life Reserves Work Group presented to the National Association of Insurance Commissioners’ Life and Health Actuarial Task Force. (December 1, 2006)

Draft Model Regulation on Life Reserving Update

Life Reserves Work Group update of draft model regulation on principle-based life reserving. (December 1, 2006)

Summary of Changes in AG DIS, AG PBR-VAL and Life Reserving

Life Reserves Work Group summary of changes made in all three documents: AG DIS, AG PBR-VAL, and draft model regulation on principle-based life reserving. (December 1, 2006)

Comment Letter to State Regulators on Florida Travel Underwriting

Life Products Committee comment letter to state insurance regulators on Florida travel underwriting rule. (December 1, 2006)

LPC Paper for Testimony at NAIC Hearing on Considering Travel Destination in Life Underwriting

Life Products Council paper supporting a move to a principles-based system to the NAIC's Life Insurance and Annuities Committee regarding the travel underwriting issue. (September 9, 2006)

Updated Draft Actuarial Guidelines to NAIC Life and Health Actuarial Task Force

Life Reserve Work Group updated draft actuarial guidelines on reserve documentation and disclosure (AG DIS), on life valuation assumptions (AG PBR-VAL), updated draft model regulation on principle-based life reserving, and summary of changes to the NAIC's Life and Health Actuarial Task Force. (September 1, 2006)

PBRGWG Presentation on Draft Model Regulation on Principle-Based Peer Review

Principle-Based Review and Governance Work Group draft model regulations to the NAIC's Life and Health Actuarial Task Force regarding principles-based valuation review opinions. (September 1, 2006)