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.

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.

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.

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.

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.

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.

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.

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.

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.  

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.

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.

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.

Comments from the Academy’s Pension Committee to the Actuarial Standards Board regarding the third exposure draft of the proposed Actuarial Standard of Practice, Setting Assumptions.

The Casualty Practice Council submitted a comment letter on Colorado Senate Bill 21-169 which is aimed to protect consumers from unfair discrimination in insurance practices. The comments addressed potential concerns of the legislation’s impact on casualty insurance.

The Life Underwriting and Risk Classification Work Group’s letter on Colorado Senate Bill 21-169 aimed at unfair discrimination in insurance, addressing potential concerns of the legislation’s impact on life insurance.  

Health Practice Council comment letter on Colorado Senate Bill 21-169 which is aimed to protect consumers from unfair discrimination in insurance practices. The comments focus on potential impacts to health insurance.

The Academy’s Economic Scenario Generator Work Group’s (ESGWG) comment letter submitted to the National Association of Insurance Commissioners' Life Actuarial Task Force regarding its recent ESG exposures.

The Academy’s Annuity Reserves and Capital Work Group’s summary of the differences between the Academy fixed annuity principle-based reserving (PBR) framework proposal exposed by the National Association of Insurance Commissioners VM-22 Subgroup in October 2020 and the current framework for Valuation Manual (VM)-21 (variable annuity PBR).  

The Variable Annuity Reserves and Capital Work Group’s proposed amendment submitted to the NAIC’s Life Actuarial Task Force (LATF) to update the reference to the required minimum distribution (RMD) age in the VM-21 Standard Projection Amount pursuant to enactment of the federal Setting Every Community Up for Retirement Enhancement (SECURE) Act.

The C1 Work Group's letter to the NAIC's Life Risk-Based Capital (LRBC) Working Group, including an update to previously proposed base bond factors and companion portfolio adjustment formula to reflect corporate tax rates enacted by the Tax Cuts and Jobs Act of 2017 for the LRBC formula.

The C1 Work Group's comments to the NAIC's Life Risk-Based Capital (LRBC) Working Group on the exposed January 21, 2021 proposal to restate the capital requirements for real estate in the LRBC formula.

ERM/ORSA Climate-Related Financial Disclosures Work Group comments to the NAIC Climate and Resiliency (EX) Task Force's Climate Risk Disclosure Workstream. 

The Academy’s Cyber Risk Task Force sent a letter offering its assistance in relation to the challenges and opportunities present in the current system of regulating and overseeing responses to cyber breaches of personally identifiable information along with a copy of its report, Cyber Breach Reporting Requirements: An Analysis of Laws Across the United States, to Treasury Secretary Janet Yellen and the directors (or acting directors) of the Office of Terrorist Financing and Financial Crimes; the Federal Insurance Office; the Office of Domestic Finance; and the Consumer Financial Protection Bureau.

The Health Practice Council submitted a comment letter to the Department of the Treasury, the Department of Labor (DOL), and the Department of Health & Human Services (HHS), on review of agency actions related to the Affordable Care Act and Medicaid, as put forward in a recent presidential executive order. The letter provides references to previous Academy comment letters to agencies regarding relevant proposed rules.

The Individual and Small Group Markets Committee and the Active Benefits Subcommittee submitted comments to the Department of the Treasury, the Department of Labor (DOL), and the Department of Health & Human Services (HHS), on insurance and health plan coverage of COVID-19 testing, as put forward in a presidential executive order, Establishing the COVID-19 Pandemic Testing Board and Ensuring a Sustainable Public Health Workforce for COVID-19 and Other Biological Threats.

Academy President Thomas A. Campbell’s letter of recommendation for Annette V. James as a candidate for appointment to the COVID-19 Health Equity Task Force as put forward in a presidential executive order, Ensuring an Equitable Pandemic Response and Recovery.

Solvency Committee comments to the Federal Insurance Office on its Study on the Insurance Capital Standard (FIO ICS Study).

The Casualty Practice Council filed comments on the Actuarial Standards Board exposure draft, Using Models Outside the Actuary's Expertise (Property and Casualty).

ERM/ORSA Committee's Climate Related Financial Disclosures (CRFD) Work Group comments to International Association of Insurance Supervisors (IAIS) on its Application Paper on the Supervision of Climate-related Risks in the Insurance Sector. 

The Academy's Cyber Risk Task Force responded to the U.S. Treasury Department's questions about the applicability of the Terrorism Risk Insurance Act (TRIA) to cyber-attacks that aim at targets outside the U.S. but cause insured losses in the U.S. The task force also noted the potential difficulty of meeting TRIA's requirement for an official finding that the source of an attack was a non-governmental terrorist  organization.