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.

The P/C Extreme Events and Property Lines Committee submitted a comment letter to the California Department of Insurance for the Department's upcoming public workshop on Catastrophe Modeling and Insurance. 

The Health Practice Council’s Medicaid Committee submitted a comment letter to the Centers for Medicare & Medicaid Services’ (CMS) notice of proposed rulemaking (NPRM), Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality (Managed Care NPRM).

The Life Reserves Work Group submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force (LATF) on the extended April 20 exposure of APF 2023-06.

Comments from the Pension Committee, Multiemployer Plans Committee, and Public Plans Committee to the Actuarial Standards Board regarding the exposure draft of the proposed revision of Actuarial Standard of Practice (ASOP) No. 27, Selection of Assumptions for Measuring Pension Obligations  and the repeal of ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations.

The Committee on Property Liability and Financial Reporting (COPLFR) submitted a comment letter to the Internal Revenue Service (IRS) on an exposure on Micro-Captive Listed Transactions and Micro-Captive Transactions of Interest. 

The Life Valuation Committee submitted a comment letter to the NAIC’s Statutory Accounting Principles Working Group on 2023 Net Negative (Disallowed) Interest Maintenance Reserve (INT 23-01T).

The Life Valuation Committee submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force on the Optional AOM and PBR Actuarial Reporting Template for Interest Maintenance Reserve.

The Tax Work Group released a white paper, 2017 and 2021 Legislative Changes to the Definition of Life Insurance, that focuses on summarizing changes to the relevant sections of sections 7702 and 7702A of the Internal Revenue Code.

The Life Reserves Work Group submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force (LATF) on the April 20 exposure of APF 2023-06.

The C1 Work Group submitted a comment letter to the NAIC’s Risk-Based Capital Investment Risk and Evaluation (E) Working Group on Exposure 2023-09-IRE – Interim Residual Tranche C1 Factor.

The Index-Linked Variable Annuity 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 Index-Linked Variable Annuity Products.

The Casualty Practice Council submitted a comment letter to the Actuarial Standards Board (ASB) on the second exposure draft of ASOP No. 29, Expense Provisions in Property/Casualty Insurance Ratemaking.

The Committee on Property Liability and Financial Reporting (COPLFR) submitted a comment letter to the National Association of Insurance Commissioners (NAIC) Casualty Actuarial and Statistical (C) Task Force proposing a modification to the Annual Statement blank that would eliminate the distinction between “short-tailed” and “long-tailed” lines of business in Schedule P.

The Committee on Property Liability and Financial Reporting (COPLFR) and the Health Practice Council’s Committee on Financial Reporting and Solvency submitted a comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed exposure to add instructions for the appointed actuary and qualified actuary contacts to the Jurat electronic only section in order to address any actuarial questions.

The Variable Annuity Reserve and Capital Work Group (VARCWG) submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force (LATF) on APF 2023-05; specifically, hedging language to address index credit hedging in VM-21.

The Life Reserves Work Group (LRWG) submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force (LATF) on proposed changes to VM-20 outlined in APF 2023-03 (Part 1).

The Life Valuation Committee submitted a comment letter to the National Association of Insurance Commissioners' Life Actuarial (A) Task Force (LATF) on the Valuation of Securities (VOSTF) Task Force’s referral to LATF on Bond Risk Measures.

The Long-term Care Reform Subcommittee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Actuarial (B) Working Group featuring an Academy issue brief, Long-Term Care Insurance: Considerations for Treatment of Past Losses in Rate Increase Requests (October 2018), in response to a working group concern about the lack of a consistent definition of “past losses” in the context of recoupment.