Multiemployer Plans Subcommittee letter to the Pension Benefit Guaranty Corporation (PBGC) with proposed modifications to the multiemployer pension plan provisions of the Pension Protection Act (PPA). (October 26, 2011)

DTA Bridge Group letter to the NAIC relating to the SSAP No. 101 - Income Taxes, A Replacement of SSAP No. 10R and SSAP No. 10 recently adopted by the NAIC’s Statutory Accounting Principles Working Group. (October 25, 2011)

Pension Committee letter to the IRS and Department of Labor concerning a possible error in the instructions for Form 5500, Schedule H on the reporting of premium payments made to the PBGC from qualified DB plan assets.  (October 17, 2011)

Pension Practice Council comments to the Governmental Accounting Standards Board (GASB) to two exposure drafts on pension accounting and financial reporting by employers. (October 14, 2011)

Joint work group of the SOA Long-Term Section Council and the Academy’s Federal Long-Term Care Task Force letter to HHS Secretary Sebelius regarding the department’s extension of the Genetic Information Nondiscrimination Act (GINA) to long-term care insurance in proposed regulations. (October 13, 2011)

Pension Committee comment letter to the Actuarial Standards Board regarding the discussion draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (October 12, 2011)

Tax Work Group, in conjunction with the Nonforfeiture Improvement Work Group, follow-up comment letter to the Life Actuarial Task Force with suggested revisions to VM-20. (October 12, 2011)

Casualty Practice Council comments to the NAIC’s Casualty Actuarial & Statistical Task Force on its proposed 2012 Actuarial Opinion Instructions. (October 10, 2011)

Exchanges Work Group comments to CMS in response to proposed regulations establishing health insurance exchanges and qualified health plans under the ACA.  (October 06, 2011)

Medicare Supplement Work Group letter to the NAIC Medigap PPACA Subgroup offering comments on the subgroup’s new discussion paper, Medicare Supplement Insurance First Dollar Coverage and Cost-Shares.

(October 04, 2011)

Tax Work Group in conjunction with the Nonforfeiture Improvement Work Group comment letter to the Life Actuarial Task Force regarding issues associated with proposed language in VM-02. (October 03, 2011)

Financial Reporting Committee letter to the Public Company Accounting Oversight Board (PCAOB) on the issues surrounding the auditor’s report based on recent investor feedback. The committee’s comments included a recommendation to increase disclosure and provide more detail to the auditor's reporting model. (September 30, 2011)

Pension Committee comment letter to the Pension Benefit Guaranty Corporation regarding the calculation of unfunded vested benefits for at risk pension plans. (September 22, 2011)

Social Security Committee letter urging the president, congressional leaders, and the Joint Select Committee on Deficit Reduction to improve the long-term solvency and sustainability of Social Security.

(September 22, 2011)

Medicare Steering Committee comment letter to the members of the new Joint Select Committee on Deficit Reduction urging action to improve the long-term solvency and sustainability of the Medicare program. (August 31, 2011)

Public Interest Committee second follow-up letter to Chairman Johnson and Ranking Member Becerra of the House Ways and Means Subcommittee on Social Security regarding Academy's congressional testimony.

(August 26, 2011)

Committee on Property and Liability Financial Reporting comments to the AICPA regarding its working draft of Audit and Accounting Guide Property and Liability Insurance Entities. (August 26, 2011)

Solvency Committee's comments to the International Association of Insurance Supervisor (IAIS) on its concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. These comments further address the methods of operating group-wide supervision of internationally active insurance groups. (August 25, 2011)

ERM Committee comments to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual supporting its view that the manual offers ORSA guidance which focuses on the most fundamental components of a strong ERM framework. (August 25, 2011)

Medicare Supplement Work Group letter to the NAIC's Medicare Supplement Refund Formula Subgroup with a proposed charge to have the work group review the Medicare Supplement Refund Formula for potential changes that may need to be addressed.

(August 24, 2011)

Solvency Committee comments to the NAIC on its ComFrame Concept Paper Draft US Responses and supports the position that the modules should be outcome-oriented rather than prescriptive. (August 15, 2011)

Letter following up Public Interest Committee congressional testimony to House Ways and Means Subcommittee on Social Security. (August 15, 2011)

Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisor (IAIS) concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. The committee addressed questions presented in the paper relating to Own Risk & Solvency Assessment (ORSA), corporate governance, and Enterprise Risk Management. (July 27, 2011)

Property/Casualty RBC Committee update in response to the NAIC's request for assistance with the Solvency Modernization project on the NAIC's Risk-Based Capital formulas. This update discusses the Committee's progress toward providing recommendations for improving the correlation/covariance methodologies used in the P/C RBC formula. (July 21, 2011)

Flood Insurance Subcommittee letter to the U.S. Senate Banking, Housing & Urban Affairs Committee concerning the actuarial implications of S. 1091, "The Consumer Option for an Alternative System to Allocate Losses (COASTAL) Act." The bill would reauthorize the NFIP for an additional five years and would create a system for allocating losses between wind and water for "slab claims," in which no physical structure remains. (July 11, 2011)

Pension Committee comment letter to the Joint Board for Enrollment of Actuaries regarding final regulations and continuing education requirements for enrolled actuaries. (June 29, 2011)

Premium Review Work Group comments to CMS in response to the revised preliminary justification and consumer disclosure forms for purposes of rate review disclosure and reporting requirements. (June 28, 2011)

Financial Regulatory Reform Task Force letter to the Department of the Treasury outlining the metrics intended to aid in identifying systemic risk in the insurance sector. (June 24, 2011)

Pension Practice Council and Public Plans Subcommittee comment letter to the Securities and Exchange Commission requesting that public pension plans be excluded from the definition of "investment strategies" and that enrolled actuaries and members of the five U.S.-based actuarial organizations be excluded from the definition of "municipal advisors" to the extent they are providing actuarial services that are governed by the Actuarial Standards of Practice and the Code of Professional Conduct. (June 22, 2011)

Pension Committee letter to the Internal Revenue Service with concerns about the implications of the proposed modifications to Circular 230 and registration requirements for PTINs and the application of these rules to various reporting requirements for retirement plan professionals. (June 14, 2011)