Life Capital Adequacy Subcommittee comment letter to the NAIC’s Life Risk-Based Capital (E) Working Group regarding double counting of the Asset Valuation Reserve in both RBC and Asset Adequacy Analysis.
(October 11, 2013)

P/C Risk-Based Capital Committee comment letter to the National Association of Insurance Commissioners on the Reinsurance Association of America's discussion draft on reinsurance credit risk. (October 08, 2013)

Pension Committee comments to the Employee Benefits Security Administration (EBSA) regarding certain disclosures on the Annual Funding Notice for defined benefit plans. (October 03, 2013)

Pension Committee letter to the Pension Benefit Guaranty Corporation (PBGC) that supports the proposed regulations on premium rates, payment of premiums, and reducing regulatory burdens. (October 02, 2013)

The Enterprise Risk Management Committee comments to the Financial Stability Board on its paper, “Principles For an Effective Risk Appetite Framework.” (September 30, 2013)

AG 43/C-3 Phase II Work Group comment letter to the NAIC C-3 Phase II/AG 43 (E/A) Subgroup regarding recent amendment with modifications to current total return gross wealth ratios for Actuarial Guideline 43.  
(September 30, 2013)

Pension Committee comments to the Actuarial Standards Board on its recent modeling ASOP exposure draft that included concerns that the potential ASOP could be applied too broadly. (September 27, 2013)

Pension Finance Task Force letter to the Financial Accounting Standards Board (FASB) that provides suggestions, based on financial economics, to improve accounting for single employer pension plans, an issue that FASB may consider revisiting. (September 26, 2013)

Pension Committee comments to the Internal Revenue Service regarding the Annual Return/Report of Employee Benefit Plan (Form 5500) that focus on the electronic submission of data on Schedules SB and MB. (September 23, 2013)

Terrorism Risk Insurance Subcommittee comment letter to the Federal Insurance Office on the long-term availability and affordability of insurance for terrorism risk. (September 16, 2013)

MLR Work Group comments to CMS that reiterate previous comments on the proposed rule implementing medical loss ratio (MLR) requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (September 06, 2013)

Health and Pension Practice Council letter to the Actuarial Standards Board on coordinating Actuarial Standards of Practice (ASOP) affecting pension and retiree group benefits. (August 30, 2013)

Joint Committee on Retiree Health comments to the Actuarial Standards Board on revisions to a second exposure draft of ASOP No. 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Program Periodic Costs or Prefunding Contributions. (August 30, 2013)

Nonforfeiture Modernization Work Group update to the Life Actuarial Task Force regarding nonforfeiture treatment of certain fixed deferred annuities under the proposed gross premium nonforfeiture method approach.

(August 22, 2013)

Aggregate Margin Task Force proposal to replace individual margin in VM-20 with aggregate margin approach.

(August 22, 2013)

Annuity Reserve Work Group report to the Life Actuarial Task Force on potential reserve methodology for non-variable annuities in VM-22.

(August 22, 2013)

Proposal by the Actuarial Guideline 33 Non-Elective Task Force to the NAIC Life Actuarial Task Force regarding reserves for non-elective incidence under Actuarial Guideline 33.   (August 22, 2013)

Pension Committee comments on Department of Labor’s advance notice of proposed rulemaking regarding pension benefit statement requirements under section 105 of the Employee Retirement Income Security Act of 1974. (August 07, 2013)

Letter from Senior Pension Fellow Don Fuerst to Chairman Johnson and Ranking Member Becerra of the House Ways and Means Subcommittee on Social Security in response to questions from Chairman Johnson following Fuerst’s May 23 testimony to the subcommittee. (July 31, 2013)

Comment letter from the C1 Work Group to the NAIC Investment Risk-Based Capital Working Group on Illinois’ common stock proposal for C1 Risk-based Capital.  
(July 24, 2013)

Extreme Events Committee comment letter to the Federal Insurance Office on the current state of the market for natural catastrophe insurance. (June 24, 2013)

PBR Strategy Subgroup comment letter to the NAIC Principle-Based Reserving Implementation (EX) Task Force on the May 9 drafts of the PBR legislative and educational briefs.  
(June 11, 2013)

COPLFR comment letter to the California Office of Self Insurance Plans concerning proposed final regulations on the state’s workers’ compensation self-insurance plans. (June 07, 2013)

The Solvency Committee submitted comments to the NAIC on its revised version of a draft white paper on the Solvency Modernization Initiative and insurance regulation. (June 06, 2013)

Pension Committee comments to the Pension Benefit Guaranty Corporation regarding its proposed rule on reportable events under ERISA Section 4043. (June 03, 2013)

Pension Finance Task Force comments to the Actuarial Standards Board on revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2013)

Pension Committee comments to the Actuarial Standards Board on revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2013)

PBR Strategy Subgroup comment letter to the NAIC Principle-Based Reserving Implementation (EX) Task Force regarding the potential impact of PBR in its draft legislative brief.  
(May 06, 2013)

Life Practice Council comment letter to the NAIC Principle-Based Reserving Implementation (EX) Task Force praising additional language in the April 3 NAIC PBR Draft Implementation Plan and offering assistance with evaluating and updating the PBR methodology.   
(May 06, 2013)

Casualty Practice Council comment letter to the Bank for International Settlements on its mortgage insurance document. (May 01, 2013)