Public Policy Comments and Letters

Tax Work Group comment letter to the NAIC’s Statutory Accounting Principles (E) Working Group on federal income tax reform. 
(February 16, 2018)
COPLFR letter to the NAIC's Casualty Actuarial and Statistical Task Force, with survey findings regarding reports for currency conversion and intercompany quotashare pooling. (February 15, 2018)
C1 Work Group comment letter to the NAIC’s Investment Risk-Based Capital (E) Working Group on proposed risk based capital C1 factors for corporate bonds. 
(February 14, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Interim Consultation Paper on Activities-Based Approach (ABA) to Systemic Risk dated December 8, 2017. (February 13, 2018)
Committee comments to Office of Regulations and Interpretations within the Employee Benefits Security Administration in response to the Department of Labor's proposed rule on the definition of employer—small business health plans. (February 9, 2018)
Annuity Illustration Work Group comment letter to the NAIC on proposed changes to the Annuity Disclosure Model Regulation (#245). (January 31, 2018)
Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the revised Insurance Core Principle (ICP) Enterprise Risk Management (ERM) for Solvency Purposes and ComFrame material integrated with ICP 16 consultation package dated November 8, 2017. (January 30, 2018)
Committee comments to Office of the Assistant Secretary for Planning and Evaluation in response to the Department of Health and Human Services’ request for information on promoting healthcare choice and competition. (January 25, 2018)
Financial Regulatory Task Force comments to the U.S. Senate on S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act. (January 17, 2018)
Big Data Task Force comments to the NAIC's Big Data (EX) Working Group on recent exposures.  (January 12, 2018)
Role of the Actuary Subgroup Amendment Proposal Form to the NAIC Life Actuarial (A) Task Force on the definition of Actuarial Opinion.  (January 11, 2018)
Non-Guaranteed Elements Work Group comment letter to the NAIC's Life Insurance Buyer's Guide (A) Working Group on the CEJ Expanded Outline Exposure Draft. (January 3, 2018)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed updates to market risk benefits in the accounting for long-duration contracts. (December 18, 2017)
Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed updates to the accounting for long-duration contracts. (December 15, 2017)
Non-Guaranteed Elements Work Group Comment Letter to NAIC Life Insurance Buyer's Guide (A) Working Group on "10 Things You Should Know Before Purchasing Life Insurance" exposure draft.  (December 14, 2017)
Health Practice Council comments to the U.S. House and Senate on the potential inclusion of individual mandate repeal in The Tax Cuts and Jobs Act. (December 12, 2017)
Life Practice Council comment letter to NAIC Financial Condition (E) Committee raising concerns over the process by which the NAIC is developing changes to the statutory framework for variable annuities (VAs), including both C-3 Phase II for risk-based capital (RBC) and Actuarial Guideline (AG) 43 reserve requirements. (November 28, 2017)
Risk Sharing Subcommittee and Premium Review Work Group letter to the U.S. Department of Health and Human Services (HHS) regarding the proposed rule for the 2019 benefit and payment parameters. The comments address proposed changes to the risk sharing mechanisms, special enrollment periods, essential health benefits, minimum essential coverage, and medical loss ratios.
(November 27, 2017)
Health Practice Council comments to the U.S. Senate on a proposal in the Tax Cuts and Jobs Act to eliminate the ACA's individual mandate. (November 21, 2017)
Multiemployer Plans Committee comments to the Pension Benefit Guaranty Corporation (PBGC) on modifications to the instructions for the 2017 Schedule MB (Multiemployer Defined Benefit Plan Actuarial Information) of the Form 5500.
(November 20, 2017)