Life Perspectives, Spring 2020
Vol 3 | No. 2
New PBR Practice Note Released
The Life Valuation Committee’s Principle-Based Reserve Review (PBR) Procedures Work Group released a public policy practice note in mid-April, Common Practices of Examining Actuaries Involved in Statutory Financial Solvency Examinations of Life and Health Insurers, Including Considerations for PBR.
The document is intended primarily to assist examining actuaries in coordinating with examiners in charge and in effectively conducting risk-focused examinations. The approach is based on an examining actuary being an integral member of the examination team.
The practice note “will help examining actuaries bring more value to the risk-focused examination approach and be more integrated in the risk identification, risk assessment, and risk mitigation aspects of the financial examination process,” said work group Chairperson Randall Stevenson. “There is so much more to a risk-focused examination than validating the correctness of reserves. It is more about the processes used to ensure the reserves are and will continue to be correct. As an analogy, a broken clock is right twice a day, instead of verifying it has the correct time when checked, the risk-focused approach is intended to make sure it is running properly.
“The practice note is not only for examining actuaries, but for actuaries whose work is subject to statutory examinations. It is intended to provide them with an idea of how to better prepare for an examination, respond to requests for information, and understand what examiners are likely to ask—and why,” Stevenson said.
“The work group was comprised of nearly equal representations of actuaries employed as regulators, consulting actuaries who perform examinations for regulators, and actuaries whose work is subject to examination,” he said. “This blended representation was intended to help produce a practice note understandable by and beneficial to all of the actuaries who are stakeholders in financial examinations.”
PBR Practice Note Updated
The Life Principle-Based Approach Practice Note Work Group updated the practice note,
Task Force Comments on ASOP No. 11 Exposure Draft; ASB Extends Comment Deadline
The Actuarial Standards Board (ASB) has extended the comment deadline for the exposure draft of Actuarial Standard of Practice (ASOP) No. 11, Reinsurance Involving Life Insurance, Annuities, or Health Benefit Plans in Financial Reports.
comment letter to the ASB on the exposure draft. The letter addresses issues including whether the scope description relating to the inclusion of self-insurance was clear; whether the guidance is sufficient given current laws, regulations, and accounting rules; whether there were any areas where the guidance is inconsistent with current practice; whether there are areas where the guidance creates issues with reinsurance regulatory requirements; and whether there are areas where the guidance creates conflict or introduces ambiguity with reinsurance-related guidance in other ASOPs.
The ASB’s comment extension is due to the coronavirus pandemic and its worldwide impact on normal business operations, which may have impeded individuals or organizations from submitting comments. The ASB received requests to extend the deadlines from several committees and task forces of the Life Practice Council, as well as the Pension Practice Council for a separate ASOP comment deadline extension. The new comment deadline for ASOP No. 11 is June 30. The ASB exposure draft can be viewed here.
Capitol Forum Cross-Practice Webinar Will Cover COVID-19 Issues
The Academy will host a cross-practice webinar on April 28, covering the COVID-19 pandemic. To be moderated by Academy President D. Joeff Williams, the Capitol Forum webinar will feature the Academy’s practice-area senior fellows, including Senior Life Fellow Nancy Bennett. The webinar will be held from noon to 1:30 p.m. EDT, and continuing education credit will be available. Register today.
NAIC Releases RBC Calculations Guidance
The National Association of Insurance Commissioners (NAIC) has released guidance for 2020 Life Risk-Based Capital calculations for debt restructuring and has released proposed modifications for the methodology used in reporting losses.
The NAIC Financial Condition (E) Committee released guidance to U.S. insurers in an effort to encourage them to work with borrowers who are unable to or may become unable to meet their contractual payment obligations because of the effects of COVID-19. The guidance applies to a troubled debt restructuring issued as a result of COVID-19 and is applicable to the term of the loan modification, but solely with respect to a modification, including a forbearance arrangement, an interest rate modification, a repayment plan, and any other similar arrangement that defers or delays the payment of principal or interest, which occurs during the applicable reporting period for a loan that was not more than 30 days past due as of Dec. 31, 2019.
Public Policy Outreach
Principle-Based Reserve (PBR) Analysis Templates Task Force member Rachel Hochberg and Academy member Shari Brockett were among three sets of Academy presenters at the Feb. 25 meeting of the Actuaries Club of Philadelphia. They presented a “PBR Assumptions Resource Manual Introduction,” discussing how the manual published in January 2019 provides a potential framework for updating valuation assumptions and walking through a term lapse margin case study.
Life Groups Comment to NAIC
Life groups commented to the NAIC on several issues in the past several months.
Macroprudential Task Force on Liquidity Stress Testing
The Macroprudential Task Force sent a
Life Illustrations Comments on IUL Policies
The Life Illustrations Work Group sent a
Work Group Submits Comments on Model #787, AG 48
The Life Reinsurance Work Group sent a
Task Force Comments on Longevity Risk
The Longevity Risk Task Force sent a
Illustrations Work Group Comments to LATF
The Life Illustrations Work Group sent a comment letter to the NAIC’s Indexed Universal Life (IUL) Illustration (A) Subgroup addressing the subgroup’s questions on illustrations of Indexed Universal Life (IUL) insurance policies under Actuarial Guideline XLIX (AG 49). The work group suggested modification to Section 3.C.vi. to clarify that multipliers will not create additional benchmark index accounts (BIAs), though additional clarification might be needed if the intent is that additional BIAs are only for products with different levels of account charges that offer different levels of cap rates.
It also suggested that the definition of “Supplemental Option Budget” be modified to be “Supplemental Hedge Budget,” to allow for consistency of wording within AG 49 (Section 5, “companies engaging in a hedging program”) and to recognize the use of hedge instruments other than options.
Annual Meeting to Feature Historian Michael Beschloss, Political Analyst Charlie Cook
Registration is open for the Academy’s scheduled 2020 Annual Meeting and Public Policy Forum, which will feature two highly respected speakers who will weigh in on this year’s national election, just days after it occurs.


Noted presidential historian Michael Beschloss will be the keynote speaker. He will provide attendees with context and insights on the presidency and the presidents who have held the office—including the winner of the 2020 election, to be held just two days preceding the Annual Meeting. Charlie Cook, a highly respected impartial analyst of trends in American politics and elections, will break down the political reality of how the historic election played out, including an analysis of the congressional makeup.
The Annual Meeting and Public Policy Forum will be held Nov. 5–6 at the Fairmont Hotel in Washington, D.C. Continuing education credit will be available. Discounted early registration rates are now available—register today.
Registration Open for LHQ Seminar
Registration is open for the Academy’s 2020
Register With Confidence for Academy Events: New Cancellation Policy
The Academy is monitoring the ongoing coronavirus pandemic situation and adhering to the guidelines surrounding in-person events and large gatherings. While we are moving forward with our fall event schedule—including the marquee Annual Meeting and Public Policy Forum—we also want our members to be able to register with confidence knowing it’s important to you, and the Academy, to try to anticipate a return to normalcy. The Academy now has cancellation policies in place to accommodate any necessary change to your registration resulting from a continuation of the current pandemic situation.
So you can rest easy as you register for our fall events—we look forward to seeing you in person later this year. You can find the cancellation policy for the annual meeting registration page here and the LHQ Seminar here.
In This Issue
- New PBR Practice Note Released
- Task Force Comments on ASOP No. 11 Exposure Draft; ASB Extends Comment Deadline
- Cross-Practice Capitol Forum Webinar to Cover COVID-19
- NAIC RBC Calculations
- Public Policy Outreach
- Life Groups Comment to NAIC
- Register With Confidence for LHQ Seminar, Annual Meeting and Public Policy Forum
- Legislative/Regulatory Activity
- In the News
Following is a roundup of recent life-practice-related state legislative and regulatory activity.
The New York Department of Financial Services issued an executive order in response to the coronavirus pandemic requiring a 90-day grace period for individual and group life insurance and annuity contracts when the policyholder or contract holder demonstrates hardship as a direct result of the pandemic.
South Carolina Gov. Henry McMaster signed a bill into law into law March 26 making changes to the South Carolina Life and Accident and Health Insurance Guaranty Association, including mandating $300,000 as the amount of life insurance death benefits that the association may become obligated to cover.
Maine Gov. Janet Mills signed a bill into law March 17 that prohibits insurers from refusing to issue or renew coverage of an individual under a life, disability income, or long-term care insurance policy who has been prescribed preexposure prophylaxis medication to prevent HIV infection.
The Florida Senate passed a bill March 12 that would prohibit life insurance and long-term care insurers from canceling, limiting, or denying coverage to an individual based on genetic information, and would prohibit insurers from establishing differential premium rates.
South Dakota Gov. Kristi Noem signed a bill into law Feb. 13 establishing an association of member insurers to pay benefits, continue coverages, and protect against failure to perform contractual obligation under life, health, and annuity policies due to impairment or insolvency of the member insurer that issued the contracts.
Michigan Gov. Gretchen Whitmer signed a bill into law Jan. 28 to remove a provision that currently exempts certain insurers from the requirement to establish reserves using a principle-based valuation that meets certain conditions for policies or contracts as specified in the manual of valuation instructions (Valuation Manual) adopted by the NAIC. A bill was introduced in the Vermont Senate on Jan. 7 that would prohibit life insurers from denying coverage to an individual based on genetic information, as well as on the basis of social and medical services.
On April 4, radio station WMOV-AM (Ravenswood, W. Va.) aired an interview with Senior Life Fellow Nancy Bennett about whether the coronavirus pandemic is affecting life insurance rates or raising insurer solvency concerns.
MarketWatch and Financial Planning stories quoted Noel Abkemeier, co-chairperson of the Lifetime Income Risk Joint Committee, on the SECURE Act’s requirement to provide monthly income estimates based on 401(k) savings.
Cleveland radio station WTAM cited the Academy’s research on longevity risk for aging couples.