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.   

The Annuity Reserve and Capital Subcommittee submitted comments to the NAIC's Valuation Manual (VM)-22 Subgroup on the July 2023 exposure draft of the VM-22 Standard Projection Amount (SPA), reiterating its recommendation that the regulation not include a binding SPA.

The Health Practice Council’s Long-Term Care (LTC) Reform Committee submitted comments to the Office of the State Actuary for the state of Washington on key issues related to LTC financing and risk management. The letter provides information on considerations necessary to achieve and maintain long-term services and supports (LTSS) trust solvency for the WA Cares Fund Program.

The Pension Committee and Multiemployer Plans Committee responded to the Pension Benefit Guaranty Corporation’s (PBGC) request for comments regarding the proposed rule on Valuation Assumptions and Methods.

The Pension Committee submitted comments in response to the Department of Labor (DOL) Employee Benefits Security Administration’s (EBSA) Request for Information on a number of SECURE 2.0 provisions that impact the reporting and disclosure framework of the Employee Retirement Income Security Act of 1974 (ERISA).

The Health Practice Council’s Medicare Committee submitted a comment letter to the Centers for Medicare & Medicaid Services on the draft part one guidance for the Maximum Monthly Cap on Cost-Sharing Payments Program.

The ERM/ORSA Committee's comments submitted to the Actuarial Standards Board (ASB) in response to the request of the ASB’s Enterprise Risk Management Committee to provide written comments on the Proposed Actuarial Standard of Practice: Enterprise Risk Management exposure draft.

The Health Practice Council’s Individual and Small Group Markets Committee, Risk Sharing Subcommittee, and Active Benefits Committee submitted a comment letter to the Department of Health and Human Services (HHS), Department of Labor (DOL), and the Department of the Treasury on the Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Accident and Health Insurance notice of proposed rulemaking (NPRM).

The Risk Management and Financial Reporting Committee submitted comments on Sept. 1 to the NAIC on their Draft Model Bulletin Use of Algorithms, Predictive Models, and Artificial Intelligence Systems by Insurers. The comments, crafted in collaboration with the Academy’s Casualty, Life and Health Practice Councils, laud the framework’s focus on decisions as the key point of interest, and note the model will serve as a guide in assessing the depth and breadth of any necessary documentation and governance. The written comments compliment verbal comments given during the NAIC Summer Meeting last month.

P/C Committee on Equity and Fairness Chairperson Lauren Cavanaugh and Vice Chairperson Susan Kent presented at the Colorado Division of Insurance’s stakeholder meeting on Unfair Discrimination in Insurance Practices, focusing on private passenger auto insurance. They cited key points, illustrative examples, and the committee’s February issue brief, Approaches to Identify and/or Mitigate Bias in Property and Casualty Insurance.

The Prudential Regulation Committee sent a comment letter to the Federal Stability Oversight Council (FSOC) regarding FSOC's proposed Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies.

Academy Senior Life Fellow Nancy Bennett and Paul Navratil, chairperson of the Life Investment and Capital Adequacy Committee, presented to the U.S. Department of Labor’s ERISA Advisory Council public meeting on pension risk transfers on July 18. They gave an overview of life insurance regulations focused on the regulatory framework governing solvency requirements, including the establishment of liabilities and required capital for benefit obligations that are the result of a pension risk transfer. Additionally, the Academy submitted the Pension Committee’s recent issue brief, Buy-Out Group Annuity  Purchase Primer, for the meeting record as a resource on “buy-out” annuity contract transactions from a pension actuarial perspective.

The Life Index-Linked Variable Annuity (ILVA) Work Group submitted a comment letter to the ILVA Subgroup of the Product Standard Committee Interstate Insurance Product Regulation Commission on 2023 Compact Requirements for ILVA Products.