Multiemployer Plans Committee letter to Pension Benefit Guaranty Corporation (PBGC) advancing ideas regarding the Special Financial Assistance (SFA) application process for non-priority plans.
(January 12, 2023)The Individual and Small Group Markets Committee submitted comments to the Centers for Medicare & Medicaid Services’ Center for Consumer Information & Insurance Oversight (CCIIO) on the Draft 2024 Actuarial Value (AV) Calculator Methodology.
(January 12, 2023)Committee on Cyber Risk comments to the U.S. Department of the Treasury and Federal Insurance Office (FIO) request for comment (RFC) on cyber insurance and catastrophic cyber incidents in order to inform a joint assessment being conducted by the Department of the Treasury's Federal Insurance Office (FIO) and the Department of Homeland Security's Cybersecurity and Infrastructure Security Agency (CISA).
(December 14, 2022)Multiemployer Plans Committee comment letter to Pension Benefit Guaranty Corporation (PBGC) submitted in response to PBGC’s request for information on its proposed rule regarding a withdrawing employer's liability under a multiemployer plan.
(December 13, 2022)Comment letter from the Pension Committee and Retirement Policy and Design Evaluation Committee on provisions included in the Securing a Strong Retirement Act of 2022 (SECURE 2.0), the EARN Act, and the RISE & SHINE Act.
(December 07, 2022)Life Illustrations Work Group Submits Comments on Indexed Universal Life Illustrations Exposure
(November 03, 2022)Index-Linked Variable Annuity (ILVA) Work Group Submits Comments on Proposed Actuarial Guideline ILVA
(November 02, 2022)Comment letter from the Casualty Practice Council, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP 41, Actuarial Communications.
(November 01, 2022)Work Group Submits Instruction Supplement for Newly Adopted Life Insurance C-2 Mortality Factors
(October 21, 2022)Work Groups Submit LIBOR/SOFR Comment Letter to NAIC Life Actuarial (A) Task Force
(October 14, 2022)Comment letter from the Casualty Practice Council, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP 20, Discounting of Property/Casualty Unpaid Claim Estimates.
(September 30, 2022)Comment letter from the Committee on Property and Liability Financial Reporting, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP 36, Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves.
(September 29, 2022)Work Groups Submit LIBOR/SOFR Comment Letter to NAIC Life Actuarial (A) Task Force
(September 29, 2022)Index-Linked Variable Annuity Work Group Submits Comments on Proposed Actuarial Guideline ILVA
(September 16, 2022)The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee submitted a letter to the CCIIO on cost-sharing reduction (CSR) premium load factors. The letter was also submitted to state regulators and legislators. The letter first discusses using actual experience data/issuer pricing models to develop the load factor. It then discusses a method using federal actuarial value (AV) levels to develop the load and potential drawbacks of this approach.
(September 08, 2022)IWG Comment Letter on IUL Exposure
(September 06, 2022)The Health Equity Committee sent comments responding to the Centers for Medicare & Medicaid Services’ (CMS) request for information (RFI) that was seeking public comment on the Medicare Advantage program. The committee specifically focused on the health equity aspects of the questions posed within the RFI.
(August 30, 2022)Academy’s Index-Linked Variable Annuity Work Group comment letter
(August 23, 2022)The Casualty Practice Council submitted written comments to the Washington, D.C. Department of Insurance, Securities and Banking's (DISB) Request for Comments on evaluating unintentional bias in private passenger automobile insurance. The letter expanded on the Academy's previous comments to the DISB on recommended actuarial considerations for determining unintentional bias in auto insurance.
(August 22, 2022)Annuity Reserves and Capital Work Group Submits Comments on VM-22 Longevity Reinsurance Proposal
(August 12, 2022)The Academy’s Climate Change Joint Task Force (CCJTF) submitted comments to the International Sustainability Standards Board (ISSB) on their Exposure Draft IFRS S2 Climate-related Disclosures. The draft builds upon the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD).
(July 28, 2022)Life Illustrations Work Group Comment Letter
(July 28, 2022)The Casualty Practice Council submitted written comments following the Washington, D.C. Department of Insurance, Securities and Banking (DISB) on their hearing, "Initiative to Evaluate Unintentional Bias in Private Passenger Automobile Insurance." The letter expanded on the Academy's verbal presentation on the recommended actuarial considerations for determining unintentional bias in auto insurance.
(July 08, 2022)Comment Letter on Exposure 3.1 of the Proposed Actuarial Guideline ILVA
(July 08, 2022)Academy Comment Letter on APF 2022-04 Swap Spreads
(June 17, 2022)Comment Letter to the Senate Banking, Housing and Urban Affairs on NFIP
(June 17, 2022)The Academy’s Climate Change Joint Task Force (CCJTF) submitted comments to the Securities and Exchange Commission (SEC) on their request for public input on the proposed rule, the “Enhancement and Standardization of Climate-Related Disclosures for Investors.”
(June 17, 2022)The Health Practice Council’s Individual and Small Group Markets Committee and Active Benefits Subcommittee submitted comments to the Internal Revenue Service (IRS) on the proposed rule for “Affordability of Employer Coverage for Family Members of Employees.” The comments relate to provisions addressing the so-called “family glitch,” revisions to the employer coverage affordability test, and the Minimum Value (MV) Calculator.
(June 06, 2022)Comment letter from the Casualty Practice Council, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP No. 29, Expense Provisions.
(May 31, 2022)Extreme Events Committee comments to the House Financial Services Subcommittee on Housing, Community Development, and Insurance on the committee's proposed reauthorization and reforms of the National Flood Insurance Program, in advance of the congressional hearing.
(May 24, 2022)