The Prudential Regulation Committee submitted comments to the International Association of Insurance Supervisors (IAIS) on its public consultation on climate risk supervisory guidance – ICP guidance and supporting material.

The Academy's C1 Subcommittee provided comments to the NAIC's Risk-Based Capital Investment Risk and Evaluation (E) Working Group on the exposed interim residual tranche proposal by Everlake Life Insurance Company.

The Casualty Practice Council submitted comments on the exposure draft of Actuarial Standard of Practice (ASOP) No. 7, Analysis of Life, Health, or Property/Casualty Insurance Cash Flow Risk.

The Prudential Regulation Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Capital Adequacy (E) Task Force on the exposure draft of Risk-Based Capital Preamble, 2024-16-CA.

The ERM/ORSA Committee submitted comments to the Actuarial Standards Board regarding the proposed revision of Actuarial Standard of Practice (ASOP) No. 7, Analysis of Life, Health, or Property/Casualty Insurance Cash Flow Risk.

The Retirement Practice Council and Pension Committee responded to a request for information (RFI) by the majority staff of the U.S. Senate Health, Education, Labor, and Pensions (HELP) Committee regarding ways to bolster the defined benefit pension system.

The Asset Adequacy and Reinsurance Issues Task Force provided comments to the Life Actuarial Task Force (LATF) regarding LATF's “AAT Reinsurance Exposure 031724” document. 

The Casualty Practice Council submitted comments on the exposure draft of Actuarial Standard of Practice (ASOP) No. 12, Risk Classification (for All Practice Areas).

The Variable Annuity Reserves and Capital Subcommittee sent comments to the NAIC’s Variable Annuities Capital and Reserve (E/A) Subgroup on the exposure draft of APF 2024-07 that proposes updates to the VM-21 Standard Projection Amount assumptions.

The Pension Committee submitted comments to the Actuarial Standards Board regarding the proposed revision of Actuarial Standard of Practice (ASOP) No. 12, Risk Classification (for All Practice Areas).

The Health Practice Council submitted comments on the exposure draft of Actuarial Standard of Practice (ASOP) No. 12, Risk Classification (for All Practice Areas).

The P/C Extreme Events and Property Lines Committee submitted a comment letter to the California Department of Insurance in advance of the department’s public workshop on its draft regulation that would modify state law to allow for catastrophe modeling to be used for wildfire, terrorism, and flood lines of homeowners and commercial insurance lines.

The C1 Subcommittee commented on the Oliver Wyman report on Asset-Backed Securities Residual Tranches that was exposed at the NAIC Spring National Meeting to the NAIC's Risk Based Capital Investment Risk and Evaluation (E) Working Group. 

The Financial Reporting Committee and the Life GAAP Reporting Committee sent a comment letter to the Financial Accounting Standards Board (FASB) on the exposure draft of Chapter 6: Measurement, of Concepts Statement No. 8, Conceptual Framework for Financial Reporting.

The Academy’s Health, Life, and Casualty practice councils submitted comments on New York State Department of Financial Services’ proposed insurance circular letter on the use of Artificial Intelligence Systems (AIS) and External Consumer Data and Information Sources (ECDIS) in insurance underwriting and pricing. The councils support efforts to curb underwriting and pricing methods that “reflect systemic biases and can reinforce and exacerbate inequality.”

The Variable Annuity Reserve and Capital Subcommittee commented to the NAIC’s Life Actuarial (A) Task Force on the order of operations between the interest maintenance reserve (IMR) and cash surrender value (CSV) floor in the VM-21 reserve calculation.

The Prudential Regulation Committee submitted comments to the International Association of Insurance Supervisors (IAIS) on its consultation draft application paper on climate risk scenario analysis in the insurance sector.

The Annuity Reserve and Capital Subcommittee commented to the NAIC’s Valuation Manual (VM)-22 (A) Subgroup of the Life Actuarial (A) Task Force on the Nov 2023 exposure of VM-31, VM-G, and the VM-22 PBR Supplement Blank.

The Health Practice Council’s Individual and Small Group Markets Committee and Active Benefits Committee responded to the DOL’s Employee Benefits Security Administration’s proposed rule on Association Health Plan’s definition of employer.

The Economic Scenario Generator Subcommittee submitted comments to the Life Actuarial Task Force (LATF) on the Dec 12 exposure of the updated Generator of Economic Scenarios (GOES) Targeting Criteria and Evaluation Statistics.

The Life Valuation Committee submitted a comment letter to the Life Actuarial Task Force (LATF) on the re-exposure of APF 2023-12 concerning equity return volatility in VM-30 cash-flow testing.

The Health Practice Council’s Health Care Delivery Committee, Individual and Small Group Markets Committee, and Active Benefits Committee responded to the Committee on Health, Education, Labor, and Pensions’ (HELP) request for information on access to gene therapies for patients with an ultra-rare disease.

The Health Practice Council’s Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services regarding the proposed rule for the 2025 Notice of Benefit and Payment Parameters.

The Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services’ Center for Consumer Information & Insurance Oversight (CCIIO) on the Draft 2025 Actuarial Value (AV) Calculator Methodology.

The Life Experience Committee released an issue paper, Considerations Regarding Dynamic Lapses in Actuarial Modeling. The issue paper explores items that impact lapses and discusses the impact of dynamic lapses on various life and annuity products, offers sample formulas for use in modeling, discusses how predictive analytics could be an alternative approach to model lapse behaviors, and provides sources of information on lapses.

The Life Index-Linked Variable Annuity (ILVA) Subcommittee submitted a comment letter to the ILVA Subgroup of the Product Standard Committee (PSC) Interstate Insurance Product Regulation Commission (IIPRC) on the November 14 exposure of the Standards for Individual Deferred Index Linked Variable Annuity Contracts and the draft amendments to the Additional Standards to Market Value Adjustment. 

The Economic Scenario Generator Subcommittee submitted comments to the Life Actuarial (A) Task Force on the October 18 exposure of the Generator of Economic Scenarios (GOES) corporate model decision. 

The Committee on Property and Liability Financial Reporting, submitted a comment letter to the Actuarial Standards Board (ASB) on the second exposure draft of ASOP no. 36, Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves.

The Health Solvency Subcommittee’s Health Underwriting Risk Factors Analysis Work Group sent a letter updating the NAIC’s Health Risk-Based Capital (E) Working Group (HRBC) on progress on the NAIC’s request to comprehensively review the H2—Underwriting Risk Component and the Managed Care Credit Calculation included in the HRBC formula.

The Life Practice Council and Casualty Practice Council submitted comments to the Colorado Division of Insurance on its draft regulation, Concerning Quantitative Testing of External Consumer Data and Information Sources, Algorithms, and Predictive Models Used for Life Insurance Underwriting for Unfairly Discriminatory Outcomes. The comments reiterated support for Colorado’s initiative to prevent unfairly discriminatory practices in insurance and shared actuarial perspectives related to the design of the data testing requirement.