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)
Risk Sharing Work Group comments to HHS on the interim final rule implementing amendments to the Notice of Benefit and Payment Parameters final rule. (April 30, 2013)
Comments to CMS on the proposed rule implementing MLR requirements for Medicare Advantage (MA) and Medicare prescription drug (Part D) programs. (April 25, 2013)
PBR Strategy Subgroup comment letter to the NAIC Principle-Based Reserves (EX) Task Force on its legislative brief outlining the ramifications of the Standard Valuation Law for state legislatures.
(April 22, 2013)
Academy letter to the president and Congressional leaders that encourages them to appoint at least one qualified actuary to the newly-established Military Compensation and Retirement Modernization Commission. (April 22, 2013)
Senior Health Fellow Cori Uccello's suggested language on actuarial value to the NAIC Consumer Information SUbgroup for inclusion in a "frequently asked questions" document. (April 01, 2013)
Medical Loss Ratio Work Group's comments to HHS on a proposed rule that requires issuers to offer a new type of individual health insurance policy covering contraceptive benefits. The comments focus only on the effect of the proposed rule on the MLR calculation. (March 28, 2013)
Casualty, Health, Life, and Professionalism Council comments to the NAIC’s Joint Qualified Actuary (A/B/C) Subgroup in response to its request for comments to a list of nine questions in anticipation of the Subgroup’s meeting at the NAIC Spring National Meeting on April 5, 2013.
(March 27, 2013)
Separate Account Products Work Group (SAWG) comments on the December 20, 2012 document, “Review of Non-Variable, Insulated Products/Product Characteristics with Proposed Recommendations” exposed on January 9 by the NAIC Separate Account Risk (E) Working Group. (March 25, 2013)
Annuity Illustration Work Group comments to the Iowa Insurance Division on its March 18 draft memorandum: Annuity Illustrations; 191 Iowa Administrative Code rules 15.61-.69, based upon the new NAIC Annuity Disclosure Model Regulation.
(March 22, 2013)
C1 Work Group request for data from the NAIC Capital Markets Bureau for use to assist the NAIC's Investment Risk-Based Capital Working Group with developing the risk-based capital requirements for corporate bonds. (March 18, 2013)
Long-Term Care Terminations Work Group letter to the NAIC regarding the formation of the work group that is charged with gathering data on terminations in long-term care insurance, and outlines its proposed tasks and timelines. (March 15, 2013)
Committee on Property & Liability Financial Reporting comment letter to the NAIC’s Blanks Working Group on its proposed changes to move all force-placed or lender-placed business from the current line to the write-in line of Schedule P. (March 07, 2013)
Rate Review Practice Note Work Group letter to CCIIO recommending several modifications to the unified rate review template and instructions associated with the final rules implementing the rate review and disclosure provisions in the ACA. (March 07, 2013)
International Accounting Standards Task Force papers on issues related to the Insurance Contracts project discussed at a November 2012 meeting with FASB staff. (March 05, 2013)
Contingent Annuity Work Group comments on the NAIC Contingent Deferred Annuity (A) Working Group's February 13 draft recommendation to the Life Insurance and Annuities (A) Committee. (February 20, 2013)
Academy's letter to President Obama and top administration officials urging them to require Academy membership as a qualification for any candidate to the chief actuary position at the Centers for Medicare & Medicaid Services. (February 19, 2013)
Councils' letter to NAIC's Joint Qualified Actuary (A/B/C) Subgroup on the subgroup's two new charges related to defining a "qualified actuary" and recommending a process to address "unprofessional" actuarial work. (February 11, 2013)