Comment / Letter

COPLFR Comments to NAIC on Title SAO Instructions

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Publish Date:

10/13/2026

Category:

Policy & Research

Topics:

Casualty, Insurance Reserving, NAIC

In this comment letter, Academy’s Committee on Property and Liability Financial Reporting responds to the NAIC’s Actuarial Opinion (C) Working Group’s recent exposure of the 2027 Title Statement of Actuarial Opinion Instructions. The letter addresses a selection option for Exhibit B Item 6, but notes that the instructions do not indicate when “not applicable” can used to determine whether there is a Risk of Material Adverse Deviation. It suggests identifying when that could apply in the instruction or removing it as an option.