Casualty Practice Council comments to NAIC’s Casualty Actuarial and Statistical Task Force on the CPC’s process for approving member actuaries to sign P/C NAIC opinions. (April 09, 2015)

Pension Practice Council and Multiemployer Subcommittee comment letter to the IRS and Treasury regarding the Request for Information on Suspensions of Benefits under the Multiemployer Pension Reform Act of 2014 (MPRA).  (April 07, 2015)

Pension Practice Council and Multiemployer Subcommittee comment letter to the Pension Benefit Guarantee Corporation regarding the Request for Information on Partitions and Facilitated Mergers under the Multiemployer Pension Reform Act of 2014 (MPRA). (April 06, 2015)

Risk Sharing Work Group letter to CMS with comments on the 2014 medical loss ratio (MLR) annual reporting form. (March 31, 2015)

Nonforfeiture Modernization Work Group update to the NAIC Life Actuarial (A) Task Force at the NAIC Spring 2015 National Meeting. (March 27, 2015)

Financial Regulatory Task Force comments to the Financial Stability Oversight Council (FSOC) on the impact of insurance asset management products and activities to U.S. financial stability. (March 23, 2015)

Life Capital Adequacy Committee (LCAC) comment letter to the NAIC Life Risk-Based Capital (E) Working Group regarding the latest exposure drafts related to the XXX/AXXX reinsurance framework. (March 20, 2015)

P/C Risk-Based Capital (RBC) Committee comment letter to the National Association of Insurance Commissioners’ Property/Casualty Risk-Based Capital Working Group on methods of properly quantifying reserve and premium underwriting factors. (March 13, 2015)

Life Illustrations Work Group comment letter to NAIC Life Actuarial (A) Task Force on exposed actuarial guideline for indexed universal life illustrations. (March 11, 2015)

The Terrorism Risk Insurance Subcommittee of the Casualty Practice Council sent a comment letter to the Federal Insurance Office of the Department of the Treasury regarding the process by which terrorist events are certified for purposes of triggering the Terrorism Risk Insurance Program (as recently amended). (March 06, 2015)

Casualty Practice Council comment letter to Actuarial Standards Board on exposure draft of a proposed Actuarial Standard of Practice (ASOP) on modeling. (March 04, 2015)

Pension Committee comment letter to the Actuarial Standards Board (ASB) regarding the second exposure draft of the proposed Actuarial Standard of Practice (ASOP) on modeling standards.  (March 01, 2015)

Health Practice Council comments urging HHS to consider implementing measures to counter the potential adverse consequences on health insurance premium rate filings in the event the Supreme Court rules for the petitioners in King v. Burwell. (February 24, 2015)

PBR Strategy Subgroup and Life Reinsurance Work Group comment letter to NAIC PBR Implementation (EX) Task Force on exposure of XXX/AXXX reinsurance supplemental proposal. (February 23, 2015)

Solvency Committee comments to the International Association of Insurance Supervisors on the Risk-based Global Insurance Capital Standard public consultation document dated Dec. 17, 2014. (February 06, 2015)

Pension Committee comment letter to the IRS regarding the use of mortality tables to calculate pension funding requirements for the years after 2015. (February 05, 2015)

Pension Committee comment letter regarding potential improvements in the operation of IRC Section 436 while still protecting the funded status of pension plans.
(February 05, 2015)

Casualty Practice Council comment letter to Actuarial Standards Board on exposure draft of a proposed Actuarial Standard of Practice on Property/Casualty Ratemaking. (January 31, 2015)

Casualty Practice Council comments on Casualty Actuarial Society’s statement of principles on P&C ratemaking exposure draft. (January 31, 2015)

Stress Testing Work Group comment letter to NAIC Stress Testing (E) Subgroup on stress testing proposal as an outline for field testing of life insurance reserves. (January 30, 2015)

Life Capital Adequacy Committee (LCAC) comment letter to the NAIC Life Risk-Based Capital (E) Working Group regarding exposure drafts related to the XXX/AXXX reinsurance framework.
(January 29, 2015)

Rate Review Practice Note Work Group letter to CCIIO with suggested recommendations for modifications to the unified rate review template (URRT) and actuarial memorandum instructions to provide further clarification on a number of issues. (January 16, 2015)

Life Practice Council brief and FAQ supporting the adoption of the NAIC model Standard Valuation Law and Principle-Based Reserves. (January 15, 2015)

Pension Practice Council (PPC) letter to Treasury Department regarding the benefits of allowing qualified defined benefit pension plans to provide longevity annuities directly, rather than requiring them to purchase an insurance contract.  (January 14, 2015)

Pension Committee comment letter to the PBGC regarding interpretation of plan provisions governing actuarial equivalence. (January 13, 2015)

Life Illustrations Work Group letter to NAIC Life Actuarial (A) Task Force regarding principles for a sound actuarial guideline on illustrations for life insurance products. (January 08, 2015)

Life Capital Adequacy Committee, Property and Casualty Risk-Based Capital Committee, and Health Solvency Work Group comments to the National Association of Insurance Commissioners (NAIC) on operational risk issues. (January 07, 2015)

Financial Reporting Committee comments to the International Accounting Standards Board (IASB) on its treatment of participating contracts in its insurance contracts project in follow-up to a November conference call. (December 23, 2014)

Risk Sharing Work Group letter to the U.S. Department of Health and Human Services (HHS) in response to the proposed rule on benefit and payment parameters for 2016. (December 22, 2014)

Pension Committee comment letter to the IRS regarding the updated final and newly proposed regulations for hybrid retirement plans. (December 18, 2014)