The Life Practice Council's ASOP No. 2 Practice Note Task Force's comments to the Actuarial Standards Board on the proposed revision of Actuarial Standard of Practice (ASOP) No. 2, Nonguaranteed Elements for Life Insurance and Annuity Products (the "Second Exposure Draft"). 

Comments from the Individual and Small Group Markets Committee to the Center for Consumer Information & Insurance Oversight (CCIIO) expressing concerns on the claims data updates finalized in the 2021 Actuarial Value (AV) Calculator. These comments are for consideration in preparing the draft 2022 AV Calculator.

The Financial Reporting Committee comments to the American Institute of Certified Public Accountants (AICPA) regarding Targeted Improvements to Long-Duration Contracts Implementation Issue 11AC (ceded reinsurance), to be included in the Audit and Accounting Guide: Life and Health Insurance Entities.

The Committee on Property and Liability Financial Reporting has submitted comments to the NAIC's Actuarial Opinion Working Group, suggesting some changes to the wording the Financial Examiners Handbook. 

Multiemployer Plans Committee letter to Internal Revenue Service commenting on a proposed form for reporting the annual actuarial certification for multiemployer defined benefit plans.

Senior Casualty Fellow Rich Gibson submitted comments on the latest draft of the National Association of Insurance Commissioners' proposed white paper on Regulatory Review of Predictive Models. 

Life Underwriting and Risk Classification Work Group follow-up letter to the NAIC Accelerated Underwriting (A) Working Group after June 18, 2020 presentation. 

Comments from the Pension Committee, Multiemployer Plans Committee, and Public Plans Committee to the Actuarial Standards Board regarding the second exposure draft of Actuarial Standard of Practice No. 4, Measuring Pension Obligations and Determining Pension Costs or Contributions.

The Risk Sharing Subcommittee filed comments with the Department of Health and Human Services and the Centers for Medicare and Medicaid Services on exposed Amendments to the HHS-Operated Risk Adjustment Data Validation Under the Patient Protection and Affordable Care Act’s HHS-Operated Risk Adjustment Program. 

The Health Practice Council and its Task Force to Review Actuarial Standard of Practice (ASOP) 11 filed a comment on the Actuarial Standards Board exposure draft, Reinsurance Involving Life Insurance, Annuities, or Health Benefit Plans in Financial Reports.

The Casualty Practice Council commented on H.R. 7011, a proposal to facilitate expansion of Business Interruption coverage to include future pandemic events. 

Life Illustrations Work Group comment letter to NAIC Life Actuarial (A) Task Force on the ACLI redline of AG 49A. 

The Academy's Cyber Risk Task Force commented to the Government Accountability Office on the question of how cyber-attacks may be addressed under the Terrorism Risk Insurance Act. 

C-2 Longevity Risk Work Group (formerly Longevity Risk Task Force) comment letter to the NAIC Life Risk-Based Capital Working Group on the exposed alternative factors for longevity. 

Tax Work Group comment letter to the Internal Revenue Service on proposed regulation on changes to the computation of life insurance reserves for income tax reporting. 

Life Illustrations Work Group letter to NAIC Life Actuarial (A) Task Force on the "Independent Proposal". 

Comment letter submitted to House leadership regarding pension provisions of H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions Act (“HEROES Act”).

The Committee on Property and Liability Financial Reporting submitted comments to the National Association of Insurance Commissioners, regarding proposed instructions for the 2020 Statement of Actuarial Opinion for P&C companies. 

Life Illustrations Work Group letter to NAIC IUL (A) Illustration Subgroup on American Council of Life Insurers (ACLI) proposal for AG 49-A

The American Academy of Actuaries submitted a letter to members of the Blanks Working Group regarding their proposal on the certification of continuing education (“CE”) compliance by “Appointed Actuaries” who sign statements of actuarial opinion for property and casualty insurers.

Life Practice Council comment letter to the Actuarial Standards Board on the proposed revision of Actuarial Standard of Practice (ASOP) No. 11, Reinsurance Involving Life Insurance, Annuities, or Health Benefit Plans in Financial Reports. 

The Financial Reporting Committee comments to the American Institute of Certified Public Accountants (AICPA) regarding draft revisions to the Audit and Accounting Guide: Life and Health Insurance Entities.

Multiemployer Plans Committee letter to Internal Revenue Service requesting leniency on March 30th deadline for multiemployer pension plan certifications.

The Health Solvency Subcommittee submitted a response letter to the NAIC Health Risk-Based Capital (HRBC) Working Group for their request to provide the health bond factors over a range of additional time horizons - spanning one to five years. 

The Committee on Property and Casualty Liability Financial Reporting filed comments on the CAS/SOA proposed new form for P/C Appointed Actuaries to report their continuing education activities

Pension Committee comment letter to the Internal Revenue Service on updated mortality improvement rates and static mortality tables for defined benefit pension plans for 2021.

Comments of the Individual and Small Group Markets Committee and Risk Sharing Subcommittee on the proposed rule for the 2020 Notice of Benefit and Payment Parameters (NBPP).

The Committee on Property and Liability Financial Reporting sent a comment letter to the NAIC's Statutory Accounting Principles Working Group, continuing a dialogue about financial reporting of certain retroactive reinsurance transactions. 

Life Reinsurance Work Group comment letter to the NAIC Reinsurance (E) Task Force on the model #787 exposure memorandum on whether Actuarial Guideline XLVIII (AG 48) should be considered to be "substantially similar" to Model #787 under the NAIC Financial Standards of Accreditation Program. 

The Casualty Practice Council's comments to the Actuarial Standards Board regarding a proposed new ASOP on rate-filings by property/casualty insurers.