Public Policy Comments and Letters

Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force exposure draft containing potential changes to the P/C Statement of Actuarial Opinion Instructions to address the CASTF’s “Attestation” charge. (May 11, 2018)
AG43/C3P2 Work Group comment letter to NAIC on Recommendation #9. (May 11, 2018)
Life Illustrations Work Group comment letter to NAIC Life Insurance Illustration Issues Working Group on draft changes to Model #582. (April 30, 2018)
Comment letter from  Senior Casualty Fellow Kevin Ryan to the International Association of Insurance Supervisors on climate change risks to the insurance sector. (April 27, 2018)
RBC Tax Reform Work Group follow-up letter to NAIC Life Risk-Based Capital Working Group on additional comments regarding impact of changes to corporate tax rate on risk-based capital calculation.  (April 24, 2018)
PBR Model Governance Work Group amendment proposal form to NAIC on universal life with secondary guarantees net premium reserve lapse rate.  (April 23, 2018)
Committee comments on a proposed rule that would lengthen the maximum period of short-term, limited-duration (STLD) insurance through amending the definition of STLD. (April 6, 2018)
Non-Guaranteed Elements Work Group comment letter on the NAIC March 19 draft life insurance buyer's guide.  (April 4, 2018)
Life Experience Committee presentation to NAIC on analysis and comparison of reserves for Guaranteed Issue (GI) plans.  (March 22, 2018)
Financial Reporting Committee questions for consideration by the IFRS Transition Resource Group on IFRS 17 Insurance Contracts. (March 22, 2018)
Life Experience Committee letter to NAIC responding to ACLI comment on accelerated underwriting data elements.  (March 20, 2018)
Workers’ Compensation Committee discussion of comparisons between states of workers’ comp rates. (March 16, 2018)
RBC Tax Reform Work Group comment letter to NAIC on changes to Life Risk-Based Capiutal calculations as a result of tax reform.  (March 16, 2018)
Multiemployer Plans Committee letter to the Joint Select Committee on Solvency of Multiemployer Pension Plans offering the expertise of the Multiemployer Plans Committee as a resource to the Joint Select Committee. (March 12, 2018)
Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force’s (CASTF) exposure draft on the appointed actuary’s public attestation and supporting confidential documentation. (March 7, 2018)
Letter from Academy Past President Mary D. Miller to the NAIC on the Casualty Actuarial and Statistical Task Force’s (CASTF) request for comments on the three-year experience period—seeking proposals. (March 7, 2018)
Committee comments on the definition of ‘‘Employer’’ under section 3(5) of ERISA—Association Health Plans. (March 5, 2018)
Health Practice Council comments to the Idaho Department of Insurance on allowing health insurers to offer state-based plans that are not compliant with the Affordable Care Act in Idaho. (March 2, 2018)
AG43/C3P2 Work Group comment letter to NAIC on proposed modifications to Actuarial Guideline XLIII and C-3 Phase II. (March 2, 2018)
ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers second exposure draft. (March 1, 2018)