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 Life Actuarial (A) Task Force on the Optional AOM and PBR Actuarial Reporting Template for Interest Maintenance Reserve.

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 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.

Social Security Committee open letter to Congress introducing the Social Security Challenge, an interactive reform simulation to support the public dialogue on Social Security solvency.

The Life Practice Council, Health Practice Council, and Casualty Practice Council submitted a joint comment letter to the Colorado Division of Insurance on its recent exposure of a draft regulation on Governance and Risk Management Framework Requirements for Life Insurance Carriers’ Use of External Consumer Data and Information Sources, Algorithms, and Predictive Models: the first exposed implementation regulation for Colorado Revised Statute (C.R.S.) § 10-3-1104.9, signed into law on July 6, 2021.

The Health Practice Council’s Financial Reporting and Solvency Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Actuarial (B) Working Group inquiring if the Working Group might issue an accounting interpretation for the interaction between Actuarial Guideline LI (AG 51) and Appendix A-010.

The Life Reserves Work Group submitted a comment letter to the National Association of Insurance Commissioners (NAIC) LATF on the proposed changes to VM-20 outlined in APF 2023-03.

The C1 Work Group submitted a comment letter to the National Association of Insurance Commissioners (NAIC) VOS on the proposed methodology for collateralized loan obligations (CLOs).

The Life Practice Council and the Casualty Practice Council submitted a joint comment letter to the National Association of Insurance Commissioner’s Big Data and Artificial Intelligence (H) Working Group on its Artificial Intelligence/Machine Learning Model and Data Regulatory Questions Exposure.

The Health Solvency Subcommittee sent a comment letter responding to a request from the NAIC’s Health Risk-Based Capital (E) Working Group to provide additional investment return scenarios within the subcommittee’s summary of the Investment Income Adjusted Health H2 Experience Fluctuation Risk Factors.

Work Group Submits Comment Letter to the NAIC’s Risk-Based Capital Investment Risk and Evaluation (E) Working Group (RBCIRE WG).

The Health Practice Council’s Individual and Small Group Markets Committee and Risk Sharing Subcommittee submitted a comment letter to the Centers for Medicare & Medicaid Services’ (CMS) proposed rule for the 2024 Notice of Benefit and Payment Parameters (NBPP).

Work Group Submits Presentation to the NAIC’s Life Risk-Based Capital (E) Working Group (LRBCWG)

The P/C Committee on Equity and Fairness sent a comment letter to the District of Columbia Department of Insurance, Securities and Banking (DISB) on the DISB’s request for comment on its draft data call to support their study of unintentional bias in automobile insurance.

Annuity Reserves Work Group (ARCWG) Submits Comment Letter to NAIC Valuation Manual (VM)-22 (A) Subgroup