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. 

The Economic Scenario Generator Subcommittee submitted comments to the Life Actuarial (A) Task Force on the October 18 exposure of the Generator of Economic Scenarios (GOES) corporate model decision. 

The Life Practice Council and Casualty Practice Council submitted comments to the Colorado Division of Insurance on its draft 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 comments reiterated support for Colorado’s initiative to prevent unfairly discriminatory practices in insurance and shared actuarial perspectives related to the design of the data testing requirement.   

The Annuity Reserve and Capital Subcommittee submitted comments to the NAIC's Valuation Manual (VM)-22 Subgroup on the July 2023 exposure draft of the VM-22 Standard Projection Amount (SPA), reiterating its recommendation that the regulation not include a binding SPA.

Academy Senior Life Fellow Nancy Bennett and Paul Navratil, chairperson of the Life Investment and Capital Adequacy Committee, presented to the U.S. Department of Labor’s ERISA Advisory Council public meeting on pension risk transfers on July 18. They gave an overview of life insurance regulations focused on the regulatory framework governing solvency requirements, including the establishment of liabilities and required capital for benefit obligations that are the result of a pension risk transfer. Additionally, the Academy submitted the Pension Committee’s recent issue brief, Buy-Out Group Annuity  Purchase Primer, for the meeting record as a resource on “buy-out” annuity contract transactions from a pension actuarial perspective.

The Life Index-Linked Variable Annuity (ILVA) Work Group submitted a comment letter to the ILVA Subgroup of the Product Standard Committee Interstate Insurance Product Regulation Commission on 2023 Compact Requirements for ILVA Products.

The Life Reserves Work Group submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force (LATF) on the extended April 20 exposure of APF 2023-06.

The Life Valuation Committee submitted a comment letter to the NAIC’s Statutory Accounting Principles Working Group on 2023 Net Negative (Disallowed) Interest Maintenance Reserve (INT 23-01T).

The Life Valuation Committee submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force on the Optional AOM and PBR Actuarial Reporting Template for Interest Maintenance Reserve.

The Tax Work Group released a white paper, 2017 and 2021 Legislative Changes to the Definition of Life Insurance, that focuses on summarizing changes to the relevant sections of sections 7702 and 7702A of the Internal Revenue Code.

The Life Reserves Work Group submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force (LATF) on the April 20 exposure of APF 2023-06.

The C1 Work Group submitted a comment letter to the NAIC’s Risk-Based Capital Investment Risk and Evaluation (E) Working Group on Exposure 2023-09-IRE – Interim Residual Tranche C1 Factor.