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Risk Management and Financial Reporting Council

The Risk Management and Financial Reporting Council oversees the Academy’s work on domestic and international financial reporting and risk management issues. It also coordinates Academy work affecting multiple areas of actuarial practice and serves as a liaison to public policy-makers, the financial community, and insurance industry representatives on these issues.

Staff liaison:

Chairperson: Steve Malerich
Dorothy Andrews
Michael Angelina
Rowen Bell
Elizabeth Brill
Matthew Daitch
Charles Ford
Robert Frasca
David Heppen
Jeffrey Johnson
Novian Junus
Kenneth Kasner
Laurel Kastrup
Gareth Kennedy
Darrell Knapp
Warren Manners
Patricia Matson
David Neve
Marc Oberholtzer
Peter Ott
Jason Pessel
Randall Stevenson
Kyle Stolarz
Sheldon Summers
Douglas Van Dam
Jeremy Williams
Michelle Young

Related Publications

Committees Release White Paper on Hedging & Risk Management

The Risk Management and Financial Reporting Council’s (RMFRC) Financial Reporting Committee, ERM/ORSA Committee, and the Life Practice Council’s Life GAAP Reporting Committee released a white paper, Hedging and Risk Management. The paper examines how insurance companies—life, health, or property and casualty—employ similar techniques to manage insurance risk. It uses life insurance management of mortality risk to illustrate examples and describes capital markets’ risks and how companies have adopted hedging as a risk management tool.

(November 18, 2024 )

DSAC Releases Issue Paper on Big Data Terminology

The Data Science and Analytics Committee released an issue paper, Defining Big Data. The paper is intended to build a shared language and concepts of big data and associated themes for the actuarial community, regulators, and other interested parties. (September 25, 2024 )

DSAC Present to CASTF on Data Bias

Members of the Data Science and Analytics Committee presented at the NAIC CASTF (Casualty Actuarial Statistical Task Force) "Book Club". The presentation explored key types of data bias that actuaries may encounter and focuses on the kinds of biases found in modeling data and the implications for algorithmic outcomes. The same group previously published an issue brief, An Actuarial View of Data Bias: Definitions, Impacts and Considerations.

(August 28, 2024 )

Committee Comments on AI Use in the Financial Services Sector

The Data Science and Analytics Committee commented to the U.S. Department of the Treasury on the Request for Information (RFI) on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector.

(August 12, 2024 )

New Paper Examines Climate Events and Their Effects on Various Populations

The Climate Change Joint Committee released an issue paper, Climatic Events, Inequities, and Risk Mitigation. The paper focuses on the cause-and-effect relationship that different climatic events have on different U.S. populations and communities that disproportionately experience the effects of climate change.

(July 26, 2024 )

Climate Change Joint Committee Present at SOA Health Conference

Members of the Climate Change Joint Committee presented at the SOA Health Conference. The session explored various climate equity-related considerations for actuaries, including an introduction to the range of equity issues that climate change and the increasing frequency of climatic events may pose to actuaries.

(June 26, 2024 )

Prudential Regulation Committee Comments to IAIS on a Public Consultation on Climate Risk

The Prudential Regulation Committee submitted comments to the International Association of Insurance Supervisors (IAIS) on its public consultation on climate risk supervisory guidance – ICP guidance and supporting material.

(June 19, 2024 )

ERM/ORSA Committee Comments on ASOP No. 7 Exposure Draft

The ERM/ORSA Committee submitted comments to the Actuarial Standards Board regarding the proposed revision of Actuarial Standard of Practice (ASOP) No. 7, Analysis of Life, Health, or Property/Casualty Insurance Cash Flow Risk.

(May 31, 2024 )

Committee Comments on Risk Based Capital Preamble Exposure

The Prudential Regulation Committee sent a comment letter to the National Association of Insurance Commissioners (NAIC) Capital Adequacy (E) Task Force on the exposure draft of Risk-Based Capital Preamble, 2024-16-CA.

(May 31, 2024 )

ERM/ORSA Committee Comments on ASOP No. 12 Exposure Draft

The ERM/ORSA Committee submitted comments to the Actuarial Standards Board regarding the proposed revision of Actuarial Standard of Practice (ASOP) No. 12, Risk Classification (for All Practice Areas).

(May 01, 2024 )

Committees Comment to FASB on Financial Reporting Draft

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.

(March 21, 2024 )

Issue Brief Examines Bermuda-Ceded Reinsurance Considerations

A new issue brief from the Asset Adequacy and Reinsurance Task Force, Asset-Intensive Reinsurance Ceded Offshore From U.S. Life Insurers (With Focus on Bermuda), offers a summary of motivations, common practices, and relevant actuarial guidance for U.S.-based actuaries involved in reinsurance transactions based offshore, particularly in Bermuda. Read the Academy press release.

(February 15, 2024 )

Work Group Releases Liquidity Risk Practice Note

The Liquidity Work Group of the Academy’s Risk Management and Financial Reporting Council released the practice note Liquidity Risk, a revision to a previous practice note published in 2000. The 2024 version broadens the scope by incorporating perspectives from the health and property/casualty practice areas as well as introducing practice-area-specific appendices.

(February 14, 2024 )

Committee Releases Issue Brief on Group Capital Requirements

The Prudential Regulation Committee released an issue brief, Introduction to Insurance Group Capital Requirements, which focuses on U.S. application, including a discussion of the two primary approaches used to determine group capital.

(January 24, 2024 )

Climate Change Joint Committee Releases ESG Issue Brief

The Climate Change Joint Committee released an issue brief, ESG and the Actuary, which is intended to present some of the basics of environmental, social, and governance (ESG) considerations as actuaries contemplate how ESG may impact their work.

(January 24, 2024 )

Application of ASU 2018-12 to the Accounting for Long-Duration Contracts under U.S. GAAP

The Long-Duration Contracts Work Group of the Academy’s Risk Management and Financial Reporting Council released the practice note Application of ASU 2018-12 to the Accounting for Long-Duration Contracts under U.S. GAAP, which covers aspects of the application of Accounting Standards Update 2018-12, published in 2018 by the Financial Accounting Standards Board.

(December 27, 2023 )

Issue Brief Examines Dividend Limitations

The ERM/ORSA Committee released an issue brief, Dividend Limitations—Affiliated Transactions. The issue brief focuses on two issues: 1) review of the existing dividend limitation—which is the maximum dividend that an owner may collect from the insurance company unilaterally without requiring approval by an insurance regulator—and 2) review of the effects of affiliated transactions as they relate to the dividend limitation. The purpose of this issue brief is to discuss the two issues and describe potential actions that could be taken by regulators, whose objective is capital preservation and policyholder protection, to address the issues.

(September 27, 2023 )

Climate Risk Webinar Presentation

The Climate Change Joint Committee (CCJC) presentation on How Climate Risk Applies to All Actuaries.

(September 19, 2023 )

ERM/ORSA Committee Comments to ASB on ERM ASOP Exposure Draft

The ERM/ORSA Committee's comments submitted to the Actuarial Standards Board (ASB) in response to the request of the ASB’s Enterprise Risk Management Committee to provide written comments on the Proposed Actuarial Standard of Practice: Enterprise Risk Management exposure draft.

(September 13, 2023 )

Presentation on Cyber Risk at CREAR Cyber Conference

Director of Research Steve Jackson presented on cyber risk at an International Workshop on Cyber Risk and Security during the Center of Research in Econo-finance and Actuarial sciences on Risk (CREAR) Cyber Conference in Paris, France. This is a continuation of the Academy’s ongoing Cyber Risk initiative, overseen by the Risk Management and Financial Reporting Council and the Casualty Practice Council.

(September 12, 2023 )

Risk Management and Financial Reporting Committee Submits Comments to the National Association of Insurance Commissioners on AI

The Risk Management and Financial Reporting Committee submitted comments on Sept. 1 to the NAIC on their Draft Model Bulletin Use of Algorithms, Predictive Models, and Artificial Intelligence Systems by Insurers. The comments, crafted in collaboration with the Academy’s Casualty, Life and Health Practice Councils, laud the framework’s focus on decisions as the key point of interest, and note the model will serve as a guide in assessing the depth and breadth of any necessary documentation and governance. The written comments compliment verbal comments given during the NAIC Summer Meeting last month.

(September 07, 2023 )

Discrimination: Considerations for Machine Learning, AI Models, and Underlying Data

This issue brief defines discrimination (including distinguishing between discrimination, unfair discrimination, and unjust discrimination); presents practical methods for testing and monitoring algorithms; provides a regulatory overview of the issue; and identifies considerations for actuaries, algorithm creators, and regulators.

(August 07, 2023 )

Climate Risks Pose Broad Impacts on Financial Security Systems

A public policy paper released by the Academy’s Climate Change Joint Committee, Climate Risks Pose Broad Impacts on Financial Security Systems, looks at the effects of a changing climate across all practice areas. The paper provides actuaries with a practical guide for considering a broad range of impacts that climate change may have on their work.

(June 07, 2023 )

Glossary Covers Climate-Related Terms

This glossary provides an explanation of various terms relating to climate change appearing in publications and presentations published by American Academy of Actuaries committees, subcommittees and task forces.

(May 25, 2023 )

DSAC Releases Issue Brief on Big Data in Actuarial Modeling

The Data Science and Analytics Committee (DSAC) released an issue brief, Big Data and Algorithms in Actuarial Modeling and Consumer Impacts. It outlines big data issues confronting actuaries and initiates discussion on how big data and artificial intelligence impact the consumer insurance experience, and covers how insurers and regulators can collaborate to resolve potential issues. (October 14, 2022 )

Climate Change Joint Task Force Submits Comments to International Sustainability Standards Board

The Academy’s Climate Change Joint Task Force (CCJTF) submitted comments to the International Sustainability Standards Board (ISSB) on their Exposure Draft IFRS S2 Climate-related Disclosures. The draft builds upon the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD).

(July 28, 2022 )

DSAC & RETF Release Major Issue Brief on Correlation and Causation

The Data Science and Analytics Committee, in partnership with the Racial Equity Task Force, released a major issue brief, An Actuarial View of Correlation and Causation - From Interpretation to Practice to Implications. The issue brief provides a discussion of key questions that actuaries may encounter as they work in the risk classification domain; actuarial practices surrounding data, predictive modeling, and risk classification that are also key considerations for public policymaking and regulatory efforts aimed at ensuring that insurance practices are not “unfairly discriminatory.”

(July 06, 2022 )

Climate Change Joint Task Force Submits Comments to the Securities and Exchange Commission

The Academy’s Climate Change Joint Task Force (CCJTF) submitted comments to the Securities and Exchange Commission (SEC) on their request for public input on the proposed rule, the “Enhancement and Standardization of Climate-Related Disclosures for Investors.”

(June 17, 2022 )

IFRS 17 Work Group submits comments on IFRS Foundation’s tentative agenda decision "Transfer of Insurance Coverage under a Group of Annuity Contracts (IFRS 17)."

The IFRS 17 Work Group of the Financial Reporting Committee submitted comments to International Financial Reporting Standards (IFRS) Foundation Interpretations Committee Chairperson Bruce Mackenzie on the foundation’s tentative agenda decision Transfer of Insurance Coverage under a Group of Annuity Contracts (IFRS 17).

(May 23, 2022 )

IFRS 17 Work Group submits comments on IFRS Foundation’s tentative agenda decision Transfer of Insurance Coverage under a Group of Annuity Contracts (IFRS 17).

(May 23, 2022 )

Climate Change Joint Task Force Submits Comments to Employee Benefits Security Administration

The Academy’s Climate Change Joint Task Force (CCJTF) submitted comments to the Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) on their Request for Information on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate Related Financial Risk.

(May 16, 2022 )

DSAC Presents to NAIC CASTF Book Club on Big Data and Algorithms Issue Paper

The Academy’s Data Science and Analytics Committee (DSAC) presented to the National Association of Insurance Commissioners’ (NAIC) Casualty Actuarial and Statistical (C) Task Force (CASTF) Book Club on their recent major issue paper, Big Data and Algorithms in Actuarial Modeling and Consumer Impacts.

(January 26, 2022 )

ERM/ORSA Committee Submits Comments to the IAIS on the Development of Liquidity Metrics: Phase 2

The ERM/ORSA Committee's comments submitted to the IAIS as part of the association's Public Consultation on the Development of Liquidity Metrics: Phase 2.

(January 24, 2022 )

Climate Related Financial Disclosures Work Group report submitted to the NAIC’s Climate and Resiliency (EX) Task Force. This accompanies a comment letter from the Academy’s Climate Change Joint Task Force that addresses an exposed proposal by the NAIC for a new climate disclosure, based on the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) guideline and includes a series of observations and three specific suggestions. The report and associated comment letter to the NAIC are based upon research conducted by the Academy’s Climate-related Financial Disclosures Work Group.

(January 13, 2022 )

Climate Change Joint Task Force Comment Letter on NAIC Climate Risk Disclosures Survey Exposure Draft (January 10, 2022)

Comment letter submitted to NAIC’s Climate and Resiliency (EX) Task Force. The comment letter from the Academy’s Climate Change Joint Task Force addresses an exposed proposal by the NAIC for a new climate disclosure, based on the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) guideline and includes a series of observations and three specific suggestions. The comments are based on research conducted by the Academy’s Climate-related Financial Disclosures Work Group.

(January 13, 2022 )

Comment Letter to RFI from the Treasury Department and FIO on Climate-Related Financial Risk and the Insurance Sector

Climate Change Joint Task Force comments to the U.S. Department of the Treasury and Federal Insurance Office (FIO) request for information (RFI) relating to regarding FIO's future work relating to the insurance sector and climate-related financial risks.

(November 15, 2021 )

Academy Releases Major Issue Paper on Big Data and Consumer Impacts

The Data Science and Analytics Committee released a major issue paper, Big Data and Algorithms in Actuarial Modeling and Consumer Impacts. (November 08, 2021 )

Financial Reporting Committee First Exposure Draft of a Public Policy Practice Note on Application of ASU 2018-12

Exposure draft of a public policy practice note of the Long-Duration Contracts Work Group of the Financial Reporting Committee on the Application of Accounting Standards Update 2018-12, Targeted Improvements to the Accounting for Long-Duration Contracts. The exposure draft is Part I: Traditional and Limited-Payment Contracts – Basic Considerations Related to the Liability for Future Policy Benefits. Due to the number of areas of practice impacted by this accounting standard, the white paper is being exposed for comment in sections, of which this is the first. Please send comments to rmfrcanalyst@actuary.org by September 30.

(July 27, 2021 )

Data Science and Analytics Committee Comments to Federal Agencies on AI

The Data Science and Analytics Committee submitted comments in response to a joint request for information and comment from several federal agencies regarding financial institutions’ use of artificial intelligence (AI) and machine learning.

(June 30, 2021 )

RMFRC and CPC Climate Work Groups Comments to New York on Climate Related Risks

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.

(June 23, 2021 )

RMFRC and CPC Climate Work Groups Comments to SEC on Climate Disclosures

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.

(June 11, 2021 )

Climate Work Group Comments to NAIC Climate and Resilience Task Force

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

(March 02, 2021 )

ERM/ORSA Climate Work Group Presentation to NAIC on Survey Analysis

ERM/ORSA Climate Related Financial Disclosures (CRFD) Work Group update to the NAIC Climate Risk and Resiliency (EX) Task Force on the Climate Risk Disclosures Survey Analysis project.

(January 27, 2021 )

ERM/ORSA Climate Work Group Presentation to NAIC

ERM/ORSA Climate Related Financial Disclosures Work Group presentation to the National Association of Insurance Commissioners (NAIC) Climate and Resiliency (EX) Task Force.

(December 04, 2020 )

Presentation on Scalar Project Update to NAIC G Committee

Presentation by Steve Jackson on Scalars Project Update to the National Association of Insurance Commissioners (NAIC) International Insurance Relations (G) Committee.

(August 12, 2020 )

Solvency Committee Comments to FIO on ICS Study

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

(January 15, 2021 )

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.

(January 11, 2021 )

DSAC Update to NCOIL Special Committee on Race In Insurance Underwriting

Data Science and Analytics Committee (DSAC) Chair, Dorothy Andrews, addressed the issue of Race in Insurance Underwriting in a meeting convened by the National Council of Insurance Legislators and shared an update on the DSAC's work on the topic.

(December 09, 2020 )

Dorothy Andrews Comments to NCOIL Special Committee on Race In Insurance Underwriting

(December 09, 2020 )

Financial Reporting Committee and Life Financial Reporting Committee Comments to FASB

The Financial Reporting Committee and Life Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) regarding indexing and modco embedded derivatives.

(November 23, 2020 )

Financial Reporting Committee Comments to AICPA

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.

(September 23, 2020 )

Financial Reporting Committee Comments to AICPA

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.

(March 25, 2020 )

ERM/ORSA Committee Submits Comments to IAIS on Climate-Related Disclosures

ERM/ORSA Committee comments on the International Association of Insurance Supervisors' (IAIS) Issues Paper on the Implementation of the Recommendations of the Task Force on Climate-Related Financial Disclosures ("TCFD Recommendations").

(February 05, 2020 )

Solvency Committee Submits Comments to IAIS

The Solvency Committee comments on the International Association of Insurance Supervisors (IAIS) Draft Application Paper on Liquidity Risk Management.

(January 23, 2020 )

Big Data And The Role Of The Actuary

(October 17, 2019 )

Financial Reporting Committee Letter to IASB

Financial Reporting letter on IASB exposure draft.

(September 25, 2019 )

Work Group White Paper on Estimating the Uncollectible Reinsurance Reserve for P/C Companies

Current Estimate Credit Losses Work Group white paper on the new FASB accounting requirement regarding uncollectible reinsurance.

(July 02, 2019 )

Task Force Letter on FSOC Regulation of Nonbank Financial Companies

Financial Regulatory Reform Task Force comment letter to the Financial Stability Oversight Council regarding the Council’s proposed guidance on nonbank financial company determinations.

(May 13, 2019 )

Predictive Modeling Presentation at Insurance Summit

Seminar on Predictive Modeling at the NAIC's Insurance Summit in Kansas City, Mo

(June 07, 2019 )

ERM/ORSA Committee Comment Letter on ASOP No. 22 Exposure

The ERM/ORSA Committee comment letter to Actuarial Standards Board on December 2018 exposure draft of ASOP No. 22, Statements of Actuarial Opinion Based on Asset Adequacy Analysis for Life or Health Liabilities.

(May 29, 2019 )

Work Group Practice Note on Model Risk Management

Model Risk Management Work Group practice note on model risk management.

(May 17, 2019 )

Committee Comment Letter on Proposed Modeling ASOP

ERM/ORSA Committee letter to the Actuarial Standards Board on the fourth exposure draft of a proposed new actuarial standard of practice for modeling.

(May 10, 2019 )

Work Group Comments on Exposure Draft of IAN 100 on Application of IFRS 17 Insurance Contracts

IFRS 17 Work Group comments to the IAA on the exposure draft of IAN 100 on Application of IFRS 17 Insurance Contracts.

(April 30, 2019 )

Comments to IAIS on Risk-based Global Insurance Capital Standard Version 2.0 (ICS 2.0) Consultation Paper

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Risk-based Global Insurance Capital Standard Version 2.0 (ICS 2.0) public consultation document dated July 31, 2018. (October 29, 2018 )

Comments to IAIS on Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) Consultation Paper

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) regarding the Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) public consultation document dated July 31, 2018. (October 18, 2018 )

Comments on NAIC Exposure on Group Capital Calculation

Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on its Scope and Non-Insurance Testing Exposed with Questions document. (September 19, 2018 )

Task Force Comments to U.S. Senate Committee on Banking, Housing, and Urban Affairs on FinTech Hearing

Big Data Task Force comments to the U.S. Senate Committee on Banking, Housing, and Urban Affairs on their hearing, Fintech: Examining Digitization, Data, and Technology. (September 16, 2018 )

Comments on NAIC ORSA Review Timelines Exposure

ERM/ORSA Committee comments to the NAIC’s Financial Regulation Standards and Accreditation (F) Committee on the ORSA Review Timelines exposure. (September 04, 2018 )

Presentation to NAIC on Big Data Monograph

Presentation to the NAIC Casualty Actuarial and Statistical Task Force (CASTF) Predictive Analytics Book Club on the Big Data and the Role of the Actuary monograph. (June 25, 2018 )

Big Data and The Role of The Actuary

The Academy released the monograph, Big Data and the Role of the Actuary, at the International Congress of Actuaries meeting in Berlin on June 5. The monograph examines how Big Data is providing actuaries in more practice areas with powerful new analytical tools and opportunities to lead Big Data projects, Academy Immediate Past President and Big Data Task Force Chairperson Bob Beuerlein told ICA attendees. (June 04, 2018 )

Comments to ASB on IAA International Standard of Actuarial Practice 4—IFRS 17 Insurance Contracts

Financial Reporting Committee comments to the Actuarial Standards Board for consideration on the International Actuarial Association's International Standard of Actuarial Practice 4—IFRS 17 Insurance Contracts exposure draft.
(May 24, 2018 )

Comments to U.S. House of Representatives on Economic Growth, Regulatory Relief, and Consumer Protection Act

Financial Regulatory Task Force comments to the U.S. House of Representatives on S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act. (May 20, 2018 )

Questions for Consideration by IFRS Transition Resource Group for IFRS 17 Insurance Contracts

Financial Reporting Committee questions for consideration by the IFRS Transition Resource Group on IFRS 17 Insurance Contracts. (March 22, 2018 )

Comments to ASB on Capital Adequacy Assessment Exposure Draft

ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers second exposure draft. (March 01, 2018 )

Comments to IAIS on Activities Based Approach to Systemic Risk Interim Consultation Paper

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Interim Consultation Paper on Activities-Based Approach (ABA) to Systemic Risk dated December 8, 2017. (February 13, 2018 )

Credit for Life Reinsurance in U.S. Statutory Financial Statements

Credit for Reinsurance Subgroup practice note, Credit for Life Reinsurance in U.S. Statutory Financial Statements. (February 02, 2018 )

Comments to IAIS on Revised Insurance Core Principle 16 Enterprise Risk Management for Solvency Purposes

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the revised Insurance Core Principle (ICP) Enterprise Risk Management (ERM) for Solvency Purposes and ComFrame material integrated with ICP 16 consultation package dated November 8, 2017. (January 30, 2018 )

Comments to U.S. Senate on Economic Growth, Regulatory Relief, and Consumer Protection Act

Financial Regulatory Task Force comments to the U.S. Senate on S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act. (January 17, 2018 )

Task Force Comments to NAIC on Big Data Exposures

Big Data Task Force comments to the NAIC's Big Data (EX) Working Group on recent exposures. (January 12, 2018 )

Comments to FASB on Proposed Updates to Market Risk Benefits in the Accounting for Long-Duration Contracts

Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed updates to market risk benefits in the accounting for long-duration contracts. (December 18, 2017 )

Comments to FASB on Proposed Updates to the Accounting for Long-Duration Contracts

Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed updates to the accounting for long-duration contracts. (December 15, 2017 )

Comments on NAIC Staff Memo on Group Capital Calculation

Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on its NAIC Staff Memo - Treatment of Captives in the Group Capital Calculation exposure draft. (September 05, 2017 )

Comments to U.S. Senate Committee on Banking, Housing, and Urban Affairs on the International Insurance Capital Standards Accountability Act of 2017

Financial Regulatory Task Force comments to the U.S. Senate Committee on Banking, Housing, and Urban Affairs on S. (August 31, 2017 )

Comments to U.S. Senate Committee on Banking, Housing, and Urban Affairs on the Financial Stability Oversight Council Insurance Member Continuity Act

Financial Regulatory Task Force comments to the U.S. Senate Committee on Banking, Housing, and Urban Affairs on S. (August 31, 2017 )

Comments to PCAOB on Proposed Amendments to Auditor’s Use of the Work of Specialists

Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) proposed amendments to auditor’s use of the work of specialists. (August 29, 2017 )

Comments to U.S. House Financial Services Committee on the Financial Stability Oversight Council Insurance Member Continuity Act

Financial Regulatory Task Force comments to the U.S. House Financial Services Committee on H.R. 3110, Financial Stability Oversight Council Insurance Member Continuity Act. (July 14, 2017 )

Committee Comments to NAIC on Group Capital Calculation Adjustments

Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on the group capital calculation and the proposed adjustments for comparability and consistency. (May 26, 2017 )

Task Force Comments to U.S. House Leadership on the Financial CHOICE Act of 2017

Financial Regulatory Task Force comments to U.S. House leadership on H.R. 10, the Financial CHOICE Act of 2017, noting that if Congress chooses to establish an Office of the Independent Insurance Advocate, that office should include an Office of the Actuary. (May 19, 2017 )

Comments to IAIS on Revised Insurance Core Principles and ComFrame Material

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the revised Insurance Core Principles (ICPs) and ComFrame material integrated with ICPs’ public consultation package dated March 3, 2017. (May 08, 2017 )

Credit for Life Reinsurance in U.S. Statutory Financial Statements Exposure Draft

Credit for Reinsurance Subgroup exposure draft of a new practice note, Credit for Life Reinsurance in U.S. Statutory Financial Statements. (May 05, 2017 )

Comments to ASB on Setting Assumptions Exposure Draft

ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Setting Assumptions exposure draft. (April 27, 2017 )

Quantifying Risk Exposures for ORSA Reports

ERM/ORSA Committee presentation at the ERM Symposium in New Orleans on the committee’s 2016 practice note, Quantifying Risk Exposures for Own Risk and Solvency Assessment Reports. (April 21, 2017 )

Comments to IAA on Risk Adjustment Educational Monograph Exposure Draft

Financial Reporting Committee comments to the International Actuarial Association (IAA) on the exposure draft of its “Risk Adjustments for Financial Reporting of Insurance Contracts under International Financial Reporting Standards No. X” monograph. (February 28, 2017 )

Comments to ASB on Capital Adequacy Assessment Exposure Draft

ERM/ORSA Committee comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers exposure draft. (January 31, 2017 )

Comments to FASB on Targeted Improvements to the Accounting for Long-Duration Contracts

Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed accounting standards update, Targeted Improvements to the Accounting for Long-Duration Contracts. (December 14, 2016 )

White Paper on Considerations in Implementing the FASB Short-Duration Contract Disclosures

Financial Reporting Committee white paper on Considerations in Implementing the FASB Short-Duration Contract Disclosures. (December 09, 2016 )

Committee Comments on NAIC Form F Guidance Manual Exposure Draft

ERM/ORSA Committee comments to the NAIC’s Group Solvency Issues (E) Working Group on the Form F Guidance Manual exposure draft.
(December 05, 2016 )

Comments on NAIC Staff Memo on Group Capital Calculation

Solvency Committee comments to the NAIC's Group Capital Calculation (E) Working Group on its NAIC Staff Memo - Inventory Method Items with Questions exposure draft.
(October 24, 2016 )

Comments to IAIS on Risk-Based Global ICS Consultation Document

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Risk-based Global Insurance Capital Standard Version 1.0 public consultation document dated July 19, 2016.

(October 19, 2016 )

Task Force Comments on Fed's Proposed Rule on Capital Requirements

Financial Regulatory Task Force comments to the Federal Reserve Board (Fed) on its proposed rule on Capital Requirements for Supervised Institutions Significantly Engaged in Insurance Activities.
(September 16, 2016 )

Task Force Comments on Fed's Proposed Rule on Enhanced Prudential Standards

Financial Regulatory Task Force comments to the Federal Reserve Board (Fed) on its proposed rule on Enhanced Prudential Standards for Systemically Important Insurance Companies. (August 17, 2016 )

ERM/ORSA Committee Comments on NAIC’s “Draft Form A Review Best Practices” Exposure

ERM/ORSA Committee comments to the NAIC’s National Treatment and Coordination (E) Working Group on its “Draft Form A Review Best Practices” exposure document. (August 17, 2016 )

Presentation on ORSA Policy Paper and Practice Note to NAIC

ERM/ORSA Committee presentation to the National Association of Insurance Commissioners' (NAIC) ORSA Implementation (E) Subgroup on the committee's recently released policy paper and practice note. (August 10, 2016 )

Joint FRC/COPLFR Letter on SEC S-K Disclosure Requirement

Financial Reporting Committee (FRC) and Committee on Property and Liability Financial Reporting (COPLFR) comments to the SEC on its concept release on the modernization of certain disclosure requirements in Regulation S-K. (July 21, 2016 )

Quantifying Risk Exposures for ORSA Reports

Risk Exposures Subgroup practice note on quantifying risk Exposures for Own Risk and Solvency Assessment (ORSA) reports. (June 27, 2016 )

Solvency Committee Comments on "Operational Risk 2016 Factors"

Solvency Committee comments to the NAIC's Operational Risk (E) Subgroup on its "Operational Risk 2016 Factors" exposure document. (June 06, 2016 )

Solvency Committee Comments on Investment RBC on NAIC's 'Way Forward'

Solvency Committee comments to the NAIC's Investment Risk-Based Capital (E) Working Group on its "Way Forward" exposure document. (May 19, 2016 )

Exposure Draft: Quantifying Risk Exposures for ORSA Reports

ERM/ORSA Committee exposure draft of a new practice note, Quantifying Risk Exposures for Own Risk and Solvency Assessment Reports. (March 07, 2016 )

Comments to FASB on Fair Value Measurement Disclosure Framework

Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposed accounting standards update, Fair Value Measurement (Topic 820): Disclosure Framework. (February 18, 2016 )

White Paper Exposure Draft on Issues in Implementing FASB Short-Duration Contract Disclosures

Financial Reporting Committee exposure draft of a new white paper on Challenges and Issues Implementing the FASB Short-Duration Contract Disclosures. Comments on the exposure draft are due Mar. 15. (February 17, 2016 )

ERM/ORSA Committee Overview on ORSA Reports

ERM/ORSA Committee overview on the role of regulatory actuaries in reviewing Own Risk and Solvency Assessment (ORSA) reports. (February 01, 2016 )

Comments to IAIS on NTNI Consultation Document

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Non-traditional Non-insurance Activities and Products public consultation document dated November 25, 2015. (January 25, 2016 )

Presentation to FSOC on Actuaries and Financial Stability

ERM/ORSA Committee presentation to the Financial Stability Oversight Council on the role actuaries play in promoting financial stability. (December 11, 2015 )

Comments to IAA on ERM White Paper

ERM/ORSA Committee comments to the International Actuarial Association (IAA) on its white paper "Actuarial Aspects of ERM for Insurance Companies." (November 20, 2015 )

Comments to NAIC on Group Capital Calculation Recommendation

Solvency Committee comments to the National Association of Insurance Commissioners on the Group Capital Calculation Recommendation exposure draft. (October 27, 2015 )

Solvency Committee Congressional Testimony on Domestic Insurance Regulations

Solvency Committee written testimony for the U.S. House Financial Services Subcommittee on Housing and Insurance's hearing on "The Impact of Domestic Regulatory Standards on the U.S. Insurance Market." (September 29, 2015 )

Comments to FASB on Limiting Unlocking Assumptions on Insurance Contracts

Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on its proposal to limit unlocking the assumptions and discount rates for long-duration insurance contracts to only the fourth quarter. (September 16, 2015 )

Comments to NAIC on Reinsurer Passporting

Reinsurance Committee comments to the National Association of Insurance Commissioners (NAIC) on the draft Certified Reinsurers and Passporting Public Document. (September 11, 2015 )

Presentation on 99.5 Percent VaR Over One Year to NAIC

Solvency Committee presentation to the National Association of Insurance Commissioners (NAIC) on the practical implications of using a 99.5 percent Value at Risk (VaR) over a one-year time horizon for valuation purposes. (August 15, 2015 )

Comments to NAIC on Group Capital Standards

Solvency Committee comments to the National Association of Insurance Commissioners (NAIC) on the Discussion Draft on Approaches to a Group Capital Calculation dated July 23, 2015. (August 07, 2015 )

Comments to IAIS on Higher Loss Absorbency Proposal

Solvency Committee comments to the International Association of Insurance Supervisors (IAIS) on the Higher Loss Absorbency Capacity for Global Systemically Important Insurers (G-SIIs) public consultation document dated June 25, 2015. (August 06, 2015 )

Academy Committees Comment on PCAOB Auditor and Specialist Paper

The Financial Reporting Committee, Pension Accounting Committee, Casualty Committee on Property and Liability Financial Reporting, Health Financial Reporting and Solvency Committee, and Life Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) “The Auditor's Use of the Work of Specialists” consultation paper. (July 15, 2015 )

Academy Councils Comments on NAIC E Committee Questionnaire

The Casualty Practice Council, Health Practice Council, Life Practice Council, and Risk Management and Financial Reporting Council comments to the National Association of Insurance Commissioners (NAIC) on its Financial Condition (E) Committee questionnaire that examines the reasons for single-state solutions to help regulators develop a process for creating a uniform framework for state-based regulation. (July 27, 2015 )

Comments to FASB on Retrospective Unlocking in Long-Duration Contracts

Financial Reporting Committee comments to the Financial Accounting Standards Board (FASB) on issues raised during the May 21, 2015 educational session related to retrospective unlocking in long-duration contracts. (July 22, 2015 )

Comments to ASB on Capital Adequacy Assessment Discussion Draft

Risk Management and Financial Reporting Council (RMFRC) comments to the Actuarial Standards Board (ASB) on its Capital Adequacy Assessment for Insurers discussion draft. (July 21, 2015 )

Letter to Federal Reserve on MOCE

Risk Management and Financial Reporting Council letter to the Federal Reserve Board on issues related to a “margin over current estimate” (MOCE) for international insurance capital standards. (July 14, 2015 )

FinReg Letter to Congress on FSOC Annual Report

Financial Regulatory Task Force (FinReg) letter to the U.S. House Financial Services Committee (HFSC) on the Financial Stability Oversight Council (FSOC) 2015 annual report. (June 17, 2015 )

GAAP Accounting for Profits Followed by Losses in Long-Duration Contracts

Profits Followed by Losses Subgroup practice note on accounting for profits followed by losses in long-duration contracts. (June 10, 2015 )

Comments to IAIS on Insurance Core Principle 8

Risk Management and Financial Reporting Council comments to the International Association of Insurance Supervisors (IAIS) on Insurance Core Principle (ICP) 8: Risk Management and Internal Controls. (May 12, 2015 )

Presentation on Insurance Capital Standards Modeling to IAIS

Risk Management and Financial Reporting Council and Solvency Committee presentation to the International Association of Insurance Supervisors (IAIS) on modeling for insurance capital standards (ICS). (May 06, 2015 )

Committee Comments to IAIS on Conduct of Business Risk Draft Paper

ERM/ORSA Committee comments to the International Association of Insurance Supervisors (IAIS) on its draft issues paper Conduct of Business Risk and its Management. (May 01, 2015 )

Comments to FASB on Bifurcated Embedded Derivatives

Financial Reporting Committee comments on the Financial Accounting Standards Board's (FASB) proposed accounting standards update-Derivatives and Hedging (Topic 815): Disclosures about Hybrid Financial Instruments with Bifurcated Embedded Derivatives. (April 30, 2015 )

Solvency Committee Congressional Testimony on International Insurance Regulations

Solvency Committee written testimony for the U.S. House Financial Services Subcommittee on Housing and Insurance's hearing on "The Impact of International Regulatory Standards on the Competitiveness of U.S. Insurers." (April 29, 2015 )

Solvency Committee Testimony to Senate on Insurance Capital Proposals

Solvency Committee written testimony for the U.S. Senate Banking Subcommittee on Securities, Insurance, and Investment hearing on “Examining Insurance Capital Rules and FSOC Process.”
(April 30, 2015 )

Comments to FIO on U.S. GAAP Loss Recognition Testing and ICP 14

Risk Management and Financial Reporting Council and Financial Reporting Committee comments to the Federal Insurance Office (FIO) on U.S. GAAP loss recognition testing and Insurance Core Principle (ICP) 14 current estimates. (April 27, 2015 )

Comments to FSOC on Insurance Asset Management Products

Financial Regulatory Task Force comments to the Financial Stability Oversight Council (FSOC) on the impact of insurance asset management products and activities to U.S. financial stability. (March 23, 2015 )

Comments to IAIS on Global Insurance Capital Standard

Solvency Committee comments to the International Association of Insurance Supervisors on the Risk-based Global Insurance Capital Standard public consultation document dated Dec. 17, 2014. (February 06, 2015 )

Comments to IASB on Participating Contracts

Financial Reporting Committee comments to the International Accounting Standards Board (IASB) on its treatment of participating contracts in its insurance contracts project in follow-up to a November conference call. (December 23, 2014 )

Comments to GAO on Global Capital Standards

Financial Regulatory Task Force comments to the Government Accountability Office (GAO) on its global capital standards report. (December 16, 2014 )

Council Comments to FSB on Insurer Recovery and Resolution Proposal

Risk Management and Financial Reporting Council comments to the Financial Stability Board (FSB) on the consultative document: Recovery and Resolution Planning for Systemically Important Insurers: Guidance on Identification of Critical Functions and Critical Shared Services. (December 15, 2014 )

Committee Comments on Group Capital Methodologies

Solvency Committee comments to the National Association of Insurance Commissioners on the U.S. Group Capital Methodology Concepts Discussion Paper. (December 05, 2014 )

Committee Comments to Congress on Insurance Capital Standards Bill

Solvency Committee comments to members of the U.S. House of Representatives and the U.S. Senate in support of passage of the Insurance Capital Standards Clarification Act of 2014, which clarifies that the Federal Reserve has the authority to differentiate between banks and insurers in terms of capital requirements. (December 02, 2014 )

FRC Comments on Short Duration Contracts Disclosures

Financial Reporting Committee comments to the Financial Accounting Standards Board on its disclosure requirements for short duration contracts. (November 21, 2014 )

Committee Comments on Reinsurance and Ceding Commissions Proposal

Reinsurance Committee comments to the International Accounting Standards Board on the Insurance Contracts Project's reinsurance and ceding commissions proposal. (November 20, 2014 )

Solvency Committee Congressional Testimony on International Capital Regulations

Solvency Committee written testimony to the U.S. House Financial Services Subcommittee on Housing and Insurance hearing on "The Impact of International Regulatory Standards on the Competitiveness of U.S. Insurers, Part II." (November 18, 2014 )

Comments on Uniform Application Checklist for Certified Reinsurers

Reinsurance Committee comments to the National Association of Insurance Commissioners on the Uniform Application Checklist for Certified Reinsurers exposure draft. (November 11, 2014 )

Comments on Importance of Actuaries in Protecting Solvency

Financial Regulatory Task Force comment letter to the Financial Stability and Oversight Council on the importance of actuaries in financial and insurance systems, and its perspective on updates to actuarial standards and guidance. (November 03, 2014 )

Comments on Auditing Accounting Estimates and Fair Value Measurements Paper

Financial Reporting Committee comments to the Public Company Accounting Oversight Board on the draft Auditing Accounting Estimates and Fair Value Measurements staff consultation paper. (October 31, 2014 )

Comments to IASB on Macro Hedging Discussion Paper

Financial Reporting Committee comments to the International Accounting Standards Board (IASB) and Financial Accounting Standards Board (FASB) on the IASB's Accounting for Dynamic Risk Management: a Portfolio Revaluation Approach to Macro Hedging discussion paper. (October 17, 2014 )

Comments on Insurance Group Solvency and Capital Standards

Solvency Committee comments to the National Conference of Insurance Legislators on the key priorities and principles that should be considered when developing insurance group solvency and capital standards. (October 10, 2014 )

Exposure Draft: Profits Followed by Losses

Financial Reporting Committee exposure draft of a new practice note on profits followed by losses in long-duration contracts. Comments on the exposure draft are due Nov. 10. (October 10, 2014 )

ERM/ORSA Committee Actuaries and ORSA Overview

ERM/ORSA Committee overview of the key content of an Own Risk and Solvency Assessment (ORSA) and the components of an ORSA for which actuarial input may be useful. (September 26, 2014 )

Comments on Principles for Insurance Group Solvency and Capital Standards

Solvency Committee comments to the National Association of Insurance Commissioners on the key priorities and principles that should be considered when developing insurance group solvency and capital standards. (September 18, 2014 )

Comments to NAIC on Securities Listed by the Securities Valuation Office

Reinsurance Committee comments to the NAIC's Reinsurance (E) Task Force on the exposure draft, Securities Listed by the Securities Valuation Office, that specifically address the security provided for the purpose of collateralizing reinsurance obligations. (September 05, 2014 )

Committee Letter to IASB on Treatment of Participating Contracts

Financial Reporting Committee letter to the International Accounting Standards Board on the treatment of participating contracts within the IFRS Foundation's insurance contracts project that includes discussions on book-yield and effective-yield approaches. (September 02, 2014 )

Solvency Committee Comments to IAA on Revised BCR Proposal

Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors' revised proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (August 04, 2014 )

Solvency Committee Comments to NAIC on Revised BCR Proposal

Solvency Committee comments to the National Association of Insurance Commissioners on the International Association of Insurance Supervisors' revised proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (August 04, 2014 )

Comments to NAIC on Second ORSA Exam Guidance Draft

ORSA Subgroup comments to the NAIC's Risk-Focused Surveillance Working Group on the second exposure draft of ORSA guidance, which will be included in the Financial Analysis Handbook and the Financial Condition Examiners Handbook. (July 22, 2014 )

Committee Letter to FASB on Targeted Improvements

Financial Reporting Committee letter to the Financial Accounting Standards Board on its insurance contracts project, encouraging convergence for long-duration contracts but also highlighting issues that may need to be addressed if targeted improvements instead of the building block approach are pursued. (June 30, 2014 )

Committee Letter to FASB on Targeted Improvements

Comments to IAA on IAIS Insurance Capital Standard Memo

Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisors' (IAIS) Memo on a proposed approach for a global insurance capital standard. (June 06, 2014 )

Letter to Congress on Insurance Capital Standards Clarification Act of 2014

Solvency Committee comments to members of the U.S. House of Representatives supporting passage of the Insurance Capital Standards Clarification Act of 2014 (S.2270/H.R.4510), which clarifies that the Fed has the authority to differentiate between banks and insurers in terms of capital requirements. (June 05, 2014 )

Comments to NCOIL on International Priorities

Risk Management and Financial Reporting Council comments to NCOIL's International Issues Task Force with recommendations on three international priorities that NCOIL should address in 2014. (June 02, 2014 )

Comments to NAIC on ORSA Exam Guidance

ORSA Subgroup comments to the NAIC's Risk-Focused Surveillance Working Group on draft ORSA guidance that will be included in the Financial Analysis Handbook and the Financial Condition Examiners Handbook. (May 16, 2014 )

Actuary Serving Congress: A Conversation with GAO’s Chief Actuary

Presentation by Frank Todisco, chief actuary of the Government Accountability Office, at an Academy Capitol Forum webinar on the GAO’s mission, the role of the actuary at the agency, and some of its selected work areas. (March 20, 2014 )

Comments to NAIC on the ORSA Guidance Manual

ORSA Subgroup comments to the NAIC on its Guidance Manual for the Own Risk and Solvency Assessment (ORSA), noting that revisions made in the March 2014 draft provides clarity for those developing ORSA reports. (March 05, 2014 )

Academy Congressional Testimony on Capital Regulation for Insurers

Risk Management and Financial Reporting Council written testimony to the U.S. Senate Banking, Housing, and Urban Affairs Subcommittee on Financial Institutions and Consumer Protection for its hearing on capital regulation for insurers. (March 11, 2014 )

Committee Letter to FASB on Discount Rate

Financial Reporting Committee letter to the Financial Accounting Standards Board on proposed wording to clarify the methodology used in determining the "top down" discount rate. (February 12, 2014 )

Academy Congressional Testimony on Insurance Modernization

Financial Regulatory Reform Task Force written testimony to the U.S. House Financial Services Subcommittee on Housing and Insurance hearing, “The Federal Insurance Office’s Report on Modernizing Insurance Regulation”. (February 04, 2014 )

ERM Committee Comments to FSB on Risk Culture Guidance

ERM Committee comments to the Financial Stability Board on its proposal, Guidance on Supervisory Interaction with Financial Institutions on Risk Culture.
(January 30, 2014 )

Solvency Committee Comments to NAIC on BCR paper

Solvency Committee comments to the National Association of Insurance Commissioners on the International Association of Insurance Supervisors’ proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs). (January 28, 2014 )

Academy Letter to FIO Urging Inclusion of Actuaries on Federal Advisory Committee

Academy President Tom Terry’s letter to the Federal Insurance Office urging it to include actuaries on the expanded Federal Advisory Committee on Insurance. (January 28, 2014 )

Committee Comments to FASB and IASB on Financial Instruments

Financial Reporting Committee comments to the Financial Accounting Standards Board and International Accounting Standards Board regarding their joint project on classification and measurement of financial instruments.

(January 16, 2014 )

Committee Comments to IAA on BCR paper

Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors’ proposal, Basic Capital Requirements for Global Systemically Important Insurers (G-SIIs).
(January 16, 2014 )

IFRS Update: Where in the World Are We Going with Insurance Contracts?

Presentation Slides from the January 2, 2014 Webinar: IFRS Update: Where in the World Are We Going with Insurance Contracts? (January 02, 2014 )

Committee Comments to NAIC on ComFrame Paper

Solvency Committee comments to the National Association of Insurance Commissioners on the International Association of Insurance Supervisors’ paper, Common Framework for the Supervision of Internationally Active Insurance Groups. (December 04, 2013 )

Committee Comments to IAA on ComFrame Paper

Solvency Committee comments to the International Actuarial Association on the International Association of Insurance Supervisors’ paper, Common Framework for the Supervision of Internationally Active Insurance Groups.
(November 22, 2013 )

Task Force Comments on FASB Insurance Contracts

International Accounting Standards Task Force comment letter to the Financial Accounting Standards Board on its revised exposure draft, Insurance Contracts.
(October 24, 2013 )

Task Force Comments on IASB Insurance Contracts

International Accounting Standards Task Force comment letter to the International Accounting Standards Board on its revised exposure draft, Insurance Contracts. (October 24, 2013 )

Task Force Comments on Paper on Key Attributes of Regulating Non-Banks

The Financial Regulatory Reform Task Force comments to the Financial Stability Board on its paper, “Comments on Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions.” (October 18, 2013 )

Task Force Comments on Paper on Key Attributes of Regulating Non-Banks

ERM Committee Comments on Risk Appetite Paper

The Enterprise Risk Management Committee comments to the Financial Stability Board on its paper, “Principles For an Effective Risk Appetite Framework.” (September 30, 2013 )

Insurance Enterprise Risk Management

Enterprise Risk Management Committee’s practice note, “Insurance Enterprise Risk Management Practice,” which discusses ERM practices within the insurance industry and concepts such as risk culture, risk organization, and risk governance. (July 25, 2013 )

Solvency Committee Comments on NAIC SMI White Paper

The Solvency Committee submitted comments to the NAIC on its revised version of a draft white paper on the Solvency Modernization Initiative and insurance regulation. (June 06, 2013 )

Insurance Enterprise Risk Management Practices

Enterprise Risk Management Committee’s practice note exposure draft, Insurance Enterprise Risk Management Practices, for public comment. The practice note discusses ERM practices within the insurance industry and concepts such as risk culture, risk organization, and risk governance. (March 07, 2013 )

Discussion Papers to FASB on Insurance Contracts Issues

International Accounting Standards Task Force papers on issues related to the Insurance Contracts project discussed at a November 2012 meeting with FASB staff. (March 05, 2013 )

Comments to NAIC on December Draft of ORSA Guidance Manual

ORSA Subgroup comments to the NAIC on its December 2012 draft, Guidance Manual for the Own Risk and Solvency Assessment, including information on actuaries involved in Enterprise Risk Management. (January 31, 2013 )

Comments on Proposed Assessment Methodology for Global Systemically Important Insurers

Financial Regulatory Reform Task Force comments to the IAIS on its proposed policy measures that would be applied to insurers whose failure would cause major disruption to the global financial system. (December 14, 2012 )

Comments on Measuring Regulatory Financial Success

Solvency Committee response to an NAIC Solvency Modernization Initiative Task Force request to outline methods of measuring regulatory financial success in the U.S. insurance financial regulatory system. (November 16, 2012 )

Comments on IASB Insurance Accounting Standard Working Drafts

International Accounting Standards Task Force comments to the International Accounting Standards Board on its working drafts, feedback on the premium-allocation approach decisions, feedback on the Non-Insurance Components and on measuring earned premium under the building block approach. (October 09, 2012 )

Comments on Liquidity and Interest Rate Risk Disclosures

Financial Reporting Committee comments to the Financial Accounting Standards Board on its exposure draft regarding liquidity risk and interest rate risk disclosures and how the proposed amendments would affect insurance companies. (September 26, 2012 )

Comments to FIO on U.S. and Global Reinsurance Market

Reinsurance Committee comments to the Federal Insurance Office on topics relating to reinsurance, including: the purpose of reinsurance, the effect of domestic and international regulation on reinsurance in the U.S., and the coordination of reinsurance supervision nationally and internationally. (August 27, 2012 )

Comments on Draft of ComFrame for Supervision of Internationally Active Insurance Groups

Solvency Committee comments to the IAIS on its Common Framework (ComFrame) paper concerning the relationship between IAIGs and supervisors, and the framework for supervisors to address group-wide activities and risks. (August 16, 2012 )

Comments on Proposed Assessment Methodology for Global Systemically Important Insurers

Financial Regulatory Reform Task Force comments to the IAIS on its proposed method to identify insurers whose distress or disorderly failure would cause significant disruption to the global financial system and economic activity. (July 31, 2012 )

Comments on ComFrame Draft for Supervision of Internationally Active Insurance Groups

Solvency Committee comments to the NAIC and IAA on the IAIS ComFrame paper concerning the relationship beween IAIGs and supervisors and the framework for supervisors to address group-wide activities and risks. (July 27, 2012 )

Presentation on FIO to NCOIL

Senior Life Fellow Nancy Bennett’s presentation to the National Conference of Insurance Legislators (NCOIL) on modernizing insurance regulation. (July 12, 2012 )

Comments on 'Own Risk and Solvency Assessment Model Act'

ERM Committee responds to the NAIC on its draft, Own Risk and Solvency Assessment (ORSA) Model Act regarding the ORSA requirements and exemptions from the requirements, specifically the treatment of captive insurers. (May 11, 2012 )

Comments on Proposed Rule, Enhanced Prudential Standards and Early Remediation Requirements for Covered Companies

Financial Regulatory Reform Task Force comments to the Federal Reserve on its proposed rule establishing additional prudential standards to apply to non-bank financial service companies identified by the Financial Stability Oversight Council as companies that could pose systemic risk. (April 30, 2012 )

Comments on White Paper, 'The U.S. National State-Based System of Insurance Financial Regulation and the Solvency Modernization Initiative'

Public policy practice groups comments to the NAIC on its draft white paper on the Solvency Modernization Initiative and insurance regulation offering suggestions encompassing RBC, ORSA, and NAIC model laws. (April 30, 2012 )

Letter to Treasury on Financial Research Advisory Committee

Risk Management and Financial Reporting Council letter to the Department of Treasury urging that actuarial science be one of the specific considerations for members of the proposed Financial Research Advisory Committee that will support the work of the Office of Financial Research. (April 13, 2012 )

Comments on Exposure Draft of Credit for Reinsurance Model Law

Reinsurance Subcommittee comments to the NAIC on the actuarial requirements stated in the "Exposure Draft of the Credit for Reinsurance Model Law and Regulation." (September 01, 2011 )

Comments on Revised IAIS ICP 14: Valuation for Solvency Purposes

Solvency Committee input to the NAIC on the recently revised International Association of Insurance Supervisors paper, Insurance Core Principle 14: Valuation for Solvency Purposes. (May 18, 2011 )

Comments on 'Common Framework for Supervision of Internationally Active Insurance Groups'

Solvency Committee comments to the International Actuarial Association (IAA) on the International Association of Insurance Supervisor (IAIS) concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. The committee addressed questions presented in the paper relating to Own Risk & Solvency Assessment (ORSA), corporate governance, and Enterprise Risk Management. (July 27, 2011 )

Comments on IAIS Concept Paper, 'Common Framework for the Supervision of Internationally Active Insurance Groups'

Solvency Committee comments to the NAIC on its ComFrame Concept Paper Draft US Responses and supports the position that the modules should be outcome-oriented rather than prescriptive. (August 15, 2011 )

Letter to Treasury on Metrics to Monitor Insurance Industry Systemic Risk

Financial Regulatory Reform Task Force letter to the Department of the Treasury outlining the metrics intended to aid in identifying systemic risk in the insurance sector. (June 24, 2011 )

Comments on Proposed Accounting Standards Update Revenue Recognition

Financial Reporting Committee responses to questions posed in FASB's Revenue Recognition paper. (March 13, 2012 )

Presentation on Insurance Modernization to NCOIL

Senior Life Fellow presentation regarding insurance modernization in the U.S. to the National Conference of Insurance Legislators (NCOIL). (February 24, 2012 )

On Risk Classification

The Risk Classification Work Group published “On Risk Classification” an update to the 1980 “Risk Classification Statement of Principles”. This monograph is intended to provide actuaries and other interested parties with an in-depth but accessible discussion of the concepts underlying risk classification as it is applied in all actuarial practice areas. (November 15, 2011 )

Comments on Proposed Rule on Systemically Important Financial Institutions

Financial Regulatory Reform Task Force comments to the FSOC on proposed rule relating to systemically important financial institutions. (December 19, 2011 )

Comments to FIO on Modernizing and Improving U.S. System of Insurance Regulation

Financial Regulatory Reform Task Force comments to the FIO on how to modernize and improve the U.S. system of insurance regulation. (December 16, 2011 )

Approaches to Setting the Discount Rate for Valuation of Insurance Contracts: A Discussion Paper

International Accounting Standards Task Force discussion paper on approaches to setting the discount rate for valuation of insurance contracts drafted by December 2011. (December 19, 2011 )

White Paper on Other Comprehensive Income

International Accounting Standards Task Force’s white paper on the topic “What Belongs in Other Comprehensive Income” and “How Would You Calculate It?” with respect to insurance contracts. (December 06, 2011 )

Comments on Defining Contract Boundary for Insurance Contracts

International Accounting Standards Task Force comments on the topic of defining the contract boundary for insurance contracts. (December 21, 2011 )

Comments on NAIC ORSA Guidance Manual

ERM Committee comments on wording suggestions to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual recognizing the model risk for insurers. (October 28, 2011 )

Comments on NAIC Own Risk and Solvency Assessment (ORSA) Guidance Manual

(November 01, 2011 )

Response to IASB on Agenda Consultation 2011 paper

Financial Reporting Committee and International Accounting Standards Task Force response to the International Accounting Standards Board (IASB) on its Agenda Consultation 2011 paper. (October 27, 2011 )

Financial Reporting Committee Letter to PCAOB on Auditor's Report

Financial Reporting Committee letter to the Public Company Accounting Oversight Board (PCAOB) on the issues surrounding the auditor’s report based on recent investor feedback. The committee’s comments included a recommendation to increase disclosure and provide more detail to the auditor's reporting model. (September 30, 2011 )

Comments to IAIS on ComFrame paper

Solvency Committee's comments to the International Association of Insurance Supervisor (IAIS) on its concept paper, Common Framework for the Supervision of Internationally Active Insurance Groups. These comments further address the methods of operating group-wide supervision of internationally active insurance groups. (August 25, 2011 )

Comments on NAIC ORSA Guidance Manual

ERM Committee comments to the NAIC on its Own Risk and Solvency Assessment (ORSA) Guidance Manual supporting its view that the manual offers ORSA guidance which focuses on the most fundamental components of a strong ERM framework. (August 25, 2011 )

Discount Rates: Reconciling the Top Top-Down and Bottom-Up views

Financial Reporting Committee presentation on the discount rate for insurance contracts to FASB and IASB. (February 03, 2011 )

Comments on IAIS Paper ICP14: 'Valuation for Solvency Purposes'

Solvency Committee comments on the IAIS paper, ICP14: 'Valuation for Solvency Purposes.' (March 24, 2011 )

Comments on Principles for Reducing Reliance on CRA Ratings

Solvency Committee comments to the IAIS on the Financial Stability Board's (FSB) Principles for Reducing Reliance on Credit Rating Agencies (CRA) Ratings document. (February 03, 2011 )

Comments on CRA Ratings document

(March 24, 2011 )

Comments on Systemic Risk of Non-Bank Financial Companies

Financial Regulatory Reform Task Force comments to the Financial Stability Oversight Council on its proposed rule, "Authority to Require Supervision and Regulation of Certain Non-Bank Financial Companies." (February 25, 2011 )

Comments on NAIC ORSA Proposal

ERM Committee comments to the NAIC on its U.S. Own Risk and Solvency Assessment (ORSA) Proposal. (March 18, 2011 )

Reinsurance Subcommittee Comments on Insurance Contracts

Reinsurance Subcommittee letter to the IASB on its Insurance Contracts Exposure Draft regarding recognition of gains and losses on reinsurance ceded for long duration contracts. (April 11, 2011 )

Comments on Valuation for Solvency Purposes

Solvency Committee comments to the IAA and additional comments to the NAIC on the IAIS paper, ICP 14: "Valuation for Solvency Purposes." (March 24, 2011 )