The Annuity Reserve and Capital Subcommittee commented to the NAIC's Valuation Manual (VM)-22 (A) Subgroup on their exposure of a longevity reinsurance reserving proposal. 

The Economic Scenario Generator Subcommittee commented to the NAIC Generator of Economic Scenarios (GOES) (E/A) Subgroup on their exposure of SERT scenarios. 

The Life Practice Council provided comments to the entirety of the NAIC Life Actuarial Task Force (LATF)'s exposure, AAT for Reinsurance Actuarial Guideline Draft.

The Life Practice Council provided comments to the Scope and Aggregation sections of the Life Actuarial Task Force (LATF)'s exposure, AAT for Reinsurance Actuarial Guideline Draft.

The Life Underwriting and Risk Classification Subcommittee submitted additional comments to the Colorado Division of Insurance on the ACLI draft proposed quantitative testing regulation, Concerning Quantitative Testing of External Consumer Data and Information Sources, Algorithms, and Predictive Models Used for Life Insurance Underwriting for Unfairly Discriminatory Outcomes.

The Life Underwriting and Risk Classification Subcommittee submitted comments to the NAIC's Special (EX) Committee on Race and Insurance Life Workstream on the July 17 Exposure of the Survey of Life Insurer Underwriting Guidelines as Applied to Justice Impacted Individuals. 

The Life Practice Council provided comments to the Life Actuarial Task Force (LATF) regarding LATF's “Reinsurance AAT Concepts" and "Reinsurance AAT Attribution Analysis" exposures. 

The Life Underwriting and Risk Classification Subcommittee commented to the Colorado Division of Insurance on the ACLI draft proposed quantitative testing regulation, Concerning Quantitative Testing of External Consumer Data and Information Sources, Algorithms, and Predictive Models Used for Life Insurance Underwriting for Unfairly Discriminatory Outcomes.

The Academy's C1 Subcommittee provided comments to the NAIC's Risk-Based Capital Investment Risk and Evaluation (E) Working Group on the exposed interim residual tranche proposal by Everlake Life Insurance Company.

The Asset Adequacy and Reinsurance Issues Task Force provided comments to the Life Actuarial Task Force (LATF) regarding LATF's “AAT Reinsurance Exposure 031724” document. 

The Variable Annuity Reserves and Capital Subcommittee sent comments to the NAIC’s Variable Annuities Capital and Reserve (E/A) Subgroup on the exposure draft of APF 2024-07 that proposes updates to the VM-21 Standard Projection Amount assumptions.

The C1 Subcommittee commented on the Oliver Wyman report on Asset-Backed Securities Residual Tranches that was exposed at the NAIC Spring National Meeting to the NAIC's Risk Based Capital Investment Risk and Evaluation (E) Working Group. 

The Financial Reporting Committee and the Life GAAP Reporting Committee sent a comment letter to the Financial Accounting Standards Board (FASB) on the exposure draft of Chapter 6: Measurement, of Concepts Statement No. 8, Conceptual Framework for Financial Reporting.

The Academy’s Health, Life, and Casualty practice councils submitted comments on New York State Department of Financial Services’ proposed insurance circular letter on the use of Artificial Intelligence Systems (AIS) and External Consumer Data and Information Sources (ECDIS) in insurance underwriting and pricing. The councils support efforts to curb underwriting and pricing methods that “reflect systemic biases and can reinforce and exacerbate inequality.”

The Variable Annuity Reserve and Capital Subcommittee commented to the NAIC’s Life Actuarial (A) Task Force on the order of operations between the interest maintenance reserve (IMR) and cash surrender value (CSV) floor in the VM-21 reserve calculation.

The Annuity Reserve and Capital Subcommittee commented to the NAIC’s Valuation Manual (VM)-22 (A) Subgroup of the Life Actuarial (A) Task Force on the Nov 2023 exposure of VM-31, VM-G, and the VM-22 PBR Supplement Blank.

The Economic Scenario Generator Subcommittee submitted comments to the Life Actuarial Task Force (LATF) on the Dec 12 exposure of the updated Generator of Economic Scenarios (GOES) Targeting Criteria and Evaluation Statistics.

The Life Valuation Committee submitted a comment letter to the Life Actuarial Task Force (LATF) on the re-exposure of APF 2023-12 concerning equity return volatility in VM-30 cash-flow testing.

The Life Experience Committee released an issue paper, Considerations Regarding Dynamic Lapses in Actuarial Modeling. The issue paper explores items that impact lapses and discusses the impact of dynamic lapses on various life and annuity products, offers sample formulas for use in modeling, discusses how predictive analytics could be an alternative approach to model lapse behaviors, and provides sources of information on lapses.

The Life Index-Linked Variable Annuity (ILVA) Subcommittee submitted a comment letter to the ILVA Subgroup of the Product Standard Committee (PSC) Interstate Insurance Product Regulation Commission (IIPRC) on the November 14 exposure of the Standards for Individual Deferred Index Linked Variable Annuity Contracts and the draft amendments to the Additional Standards to Market Value Adjustment.