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 Life Actuarial (A) Task Force on the Optional AOM and PBR Actuarial Reporting Template for Interest Maintenance Reserve.

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 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.

The Index-Linked Variable Annuity 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 Index-Linked Variable Annuity Products.

The Variable Annuity Reserve and Capital Work Group (VARCWG) submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force (LATF) on APF 2023-05; specifically, hedging language to address index credit hedging in VM-21.

The Life Reserves Work Group (LRWG) submitted a comment letter to the NAIC’s Life Actuarial (A) Task Force (LATF) on proposed changes to VM-20 outlined in APF 2023-03 (Part 1).

The Life Valuation Committee submitted a comment letter to the National Association of Insurance Commissioners' Life Actuarial (A) Task Force (LATF) on the Valuation of Securities (VOSTF) Task Force’s referral to LATF on Bond Risk Measures.

The Life Practice Council, Health Practice Council, and Casualty Practice Council submitted a joint comment letter to the Colorado Division of Insurance on its recent exposure of a draft regulation on Governance and Risk Management Framework Requirements for Life Insurance Carriers’ Use of External Consumer Data and Information Sources, Algorithms, and Predictive Models: the first exposed implementation regulation for Colorado Revised Statute (C.R.S.) § 10-3-1104.9, signed into law on July 6, 2021.

The Life Reserves Work Group submitted a comment letter to the National Association of Insurance Commissioners (NAIC) LATF on the proposed changes to VM-20 outlined in APF 2023-03.

The C1 Work Group submitted a comment letter to the National Association of Insurance Commissioners (NAIC) VOS on the proposed methodology for collateralized loan obligations (CLOs).

The Life Practice Council and the Casualty Practice Council submitted a joint comment letter to the National Association of Insurance Commissioner’s Big Data and Artificial Intelligence (H) Working Group on its Artificial Intelligence/Machine Learning Model and Data Regulatory Questions Exposure.

Work Group Submits Comment Letter to the NAIC’s Risk-Based Capital Investment Risk and Evaluation (E) Working Group (RBCIRE WG).

Work Group Submits Presentation to the NAIC’s Life Risk-Based Capital (E) Working Group (LRBCWG)