Comments developed by a task force of the Life Practice Council to the Actuarial Standards Board (ASB) on the exposure draft of Actuarial Standard of Practice (ASOP) No. 24.
(November 09, 2021)The Health Equity Work Group sent a comment letter to the NAIC’s Special (EX) Committee on Race and Insurance – Workstream 5 (Health) on the exposure draft of the White Paper on Provider Network outline.
(November 05, 2021)The Committee on Property and Liability Financial Reporting (COPLFR) sent an updated version of its comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed changes to P/C annual statements. Many of the Committee’s previous comments stand unchanged but were edited in response to the modified exposure draft.
(October 21, 2021)Comments from the Pension Committee, Multiemployer Plans Committee, and Public Plans Committee to the Actuarial Standards Board regarding the third exposure draft of Actuarial Standard of Practice No. 4, Measuring Pension Obligations and Determining Pension Costs or Contributions.
(October 18, 2021)LTC Reform Subcommittee comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Insurance (EX) Task Force regarding the exposure drafts of the operational and actuarial sections of the Long-Term Care Insurance Multi-State Rate Review Framework released September 10 and September 15, 2021.
(October 08, 2021)Pension Committee comment letter responding to Financial Accounting Standards Board’s (FASB) June 2021 Invitation to Comment on its future standard-setting agenda.
(September 22, 2021)Health Care Delivery Committee and its Telehealth Work Group comments to the Centers for Medicare & Medicaid Services (CMS) on CMS’ proposed rule on Medicare, payment policies, and enrollment regulation updates.
(September 13, 2021)Long-term Care Reform Subcommittee comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care Insurance Reduced Benefit Options (EX) Subgroup regarding the July 22, 2021 exposure draft, Issues Related to LTC Wellness Benefits.
(September 03, 2021)Multiemployer Plans Committee letter to Pension Benefit Guaranty Corporation (PBGC) submitted in response to PBGC’s request for comments on its Interim Final Rule regarding Special Financial Assistance pursuant to the American Rescue Plan Act of 2021.
(August 11, 2021)The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed rule, Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond.
(July 28, 2021)Automobile Insurance Committee comments to the U.S. Department of the Treasury and Federal Insurance Office (FIO) request for information (RFI) relating to regarding FIO's future work relating to monitoring the availability and affordability of automobile (auto) insurance.
(July 26, 2021)Long-term Care Reform Subcommittee comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care (EX) Task Force regarding the June 10, 2021 exposure draft of the actuarial sections within the Long-Term Care Insurance Multi-State Rate Review Framework.
(July 26, 2021)Multiemployer Plans Committee comments to U.S. Department of the Treasury and Internal Revenue Service (IRS) relating to implementation of the multiemployer pension plans temporary funding relief provisions of the American Rescue Plan Act of 2021 (ARPA).
(July 23, 2021)Pension Committee comments to U.S. Department of the Treasury and Internal Revenue Service (IRS) relating to single-employer pension funding relief provisions enacted under the American Rescue Plan Act of 2021 (ARPA).
(July 23, 2021)The Annuity Reserves and Capital Work Group’s (ARCWG) proposed draft of revised NAIC VM-22 requirements for fixed annuity principle-based reserving framework. The following draft includes a version demonstrating the changes to the current VM-22 framework as well as a clean version of the document.
(July 16, 2021)
The Committee on Property and Liability Financial Reporting (COPLFR) sent a comment letter to the National Association of Insurance Commissioners (NAIC) Casualty Actuarial and Statistical (C) Task Force on proposed changes to P/C annual statements. The letter addresses such areas as definition of exposure, calendar date alignment, and existing alternative data sources.
(July 06, 2021)The Data Science and Analytics Committee submitted comments in response to a joint request for information and comment from several federal agencies regarding financial institutions’ use of artificial intelligence (AI) and machine learning.
(June 30, 2021)The Health Practice Council’s Individual and Small Group Markets Committee and the Active Benefits Subcommittee comments to the Departments of Health & Human Services, Labor, and the Treasury as the agencies develop proposed rules related to the recently enacted No Surprises Act pertaining to surprise medical billing.
(June 25, 2021)The Committee on Property and Liability Financial Reporting (COPLFR) sent a comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed changes to P/C annual statements. The letter addresses such areas as definition of exposure, calendar date alignment, and existing alternative data sources.
(June 25, 2021)The Climate-Related Financial Disclosures Work Group and the Actuaries Climate Index/Actuaries Climate Risk Index Work Group comments to the New York State Department of Financial Services on financial risks related to climate change.
(June 23, 2021)Pension Committee comment letter to Department of the Treasury and Internal Revenue Service providing suggestions for modification to rules relating to the maintenance and application of funding balances.
(June 21, 2021)The Life Reserves Work Group submitted a comment letter to the National Association of Insurance Commissioners’ (NAIC) Life Actuarial Task Force (LATF) on a Valuation Manual amendment proposal form regarding asset adequacy testing for reinsurance requirements.
(June 14, 2021)The Climate-Related Financial Disclosures Work Group and the Actuaries Climate Index/Actuaries Climate Risk Index Work Group comments to the U.S. Securities and Exchange Commission on climate disclosures.
(June 11, 2021)The C-2 Longevity Risk Work Group’s comment letter to the National Association of Insurance Commissioners’ (NAIC) Life Risk-Based Capital Working Group (LRBCWG) on the exposure (2021-13-L), Longevity Factors and Instructions.
(May 27, 2021)The C1 Work Group’s comment letter to the National Association of Insurance Commissioners’ (NAIC) Life Risk-Based Capital Working Group (LRBCWG) on its exposures of proposed bond factors and instructions.
(May 27, 2021)The Life Reserves Work Group’s comment letter to the National Association of Insurance Commissioners’ (NAIC) Life Actuarial Task Force (LATF) on an amendment proposal form (APF 2020-10), which addresses inclusion of future mortality improvement (FMI) into principle-based reserving (PBR) valuation.
(May 25, 2021)Long-term Care Reform Subcommittee comment letter to the National Association of Insurance Commissioners (NAIC) Long-Term Care (EX) Task Force regarding the April 9, 2021 exposure draft of the Long-Term Care Insurance Multi-State Rate Review Framework.
(May 24, 2021)The Financial Reporting and Solvency Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Health Actuarial (B) Task Force regarding the definition of “actuarial assets” in the revised proposed instructions for the Health Statement of Actuarial Opinion.
(May 07, 2021)Health Practice Council comment letter on a revised draft of Colorado Senate Bill 21-169, dated April 21, 2021, aimed to protect consumers from unfair discrimination in insurance practices. This letter follows up on previous Health Practice Council comments on the introduced version of the bill, submitted on March 29, 2021, and again focuses on the potential impact to health insurance.
(April 30, 2021)Financial Reporting and Solvency Committee comment letter to the National Association of Insurance Commissioners (NAIC) Health Actuarial (B) Task Force regarding the proposal to modify the definition of “actuarial assets” as used in the instructions for the Health Statement of Actuarial Opinion.
(April 19, 2021)
