Work Group Provides Update to NAIC on Fixed Annuity PBR Framework Elements
The Annuity Reserves Work Group gave an update to the NAIC VM-22 (A) Subgroup on the preliminary framework elements for fixed annuity PBR.
The Annuity Reserves Work Group gave an update to the NAIC VM-22 (A) Subgroup on the preliminary framework elements for fixed annuity PBR.
The Committee on Property and Liability Financial Reporting has issued a set of questions and answers regarding the impact of the coronavirus pandemic on P/C financial reporting.(Note: This document has been superceded by a second edition, published in January 2021.)
The Academy published an issue brief examining the potential impact of the SECURE Act on retirement security, which was developed by Senior Pension Fellow Linda K. Stone in conjunction with the chairperson and members of the Retirement System Assessment and Policy Committee and the co-chairpersons of the Lifetime Income Risk Joint Committee.
In general, we believe that it is conceivable that the conclusion with respect to the reasonableness of loss and LAE reserves could be different on a GAAP versus SAP basis. We expect that this would result in considerations as to the need for restatement on a GAAP basis.
Based on a strict reading of the NAIC Instructions for P&C Statements of Actuarial Opinion, the answer seems to be “no.” Amendments to the Actuarial Opinion generally occur when the opinion was in error as a result of reliance on data or other information (other than assumptions) that, as of the balance sheet date, was factually incorrect and the opinion would not have been issued or would have been materially altered had correct data/information been used.
There are several considerations in response to this question.
First, if an Actuarial Report has not been issued, the National Association of Insurance Commissioners (NAIC) Instructions to the P&C Statement of Actuarial Opinion say, “The Actuarial Report should be consistent with the documentation and disclosure requirements of ASOP No. 41, Actuarial Communications. Section 3.4.6 of ASOP No. 41 requires the Actuary to “disclose any relevant event that meets the following conditions:
The short answer is yes. There are many issues arising from COVID-19 that could impact the duration and severity of claims incurred by a P&C insurer on or before December 31, 2019. These include:
Individual and Small Group Markets Committee issue brief outlining the major factors driving premium changes for the next plan year. This year’s issue brief focuses primarily on the impact of COVID-19 on the 2021 premium rate filings.