Comment letter from the Committee on Property and Liability Financial Reporting, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP 36, Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves.

Work Groups Submit LIBOR/SOFR Comment Letter to NAIC Life Actuarial (A) Task Force

Index-Linked Variable Annuity Work Group Submits Comments on Proposed Actuarial Guideline ILVA

The Individual and Small Group Markets Committee and its Risk Sharing Subcommittee submitted a letter to the CCIIO on cost-sharing reduction (CSR) premium load factors. The letter was also submitted to state regulators and legislators. The letter first discusses using actual experience data/issuer pricing models to develop the load factor. It then discusses a method using federal actuarial value (AV) levels to develop the load and potential drawbacks of this approach.

IWG Comment Letter on IUL Exposure 

The Health Equity Committee sent comments responding to the Centers for Medicare & Medicaid Services’ (CMS) request for information (RFI) that was seeking public comment on the Medicare Advantage program. The committee specifically focused on the health equity aspects of the questions posed within the RFI.

Academy’s Index-Linked Variable Annuity Work Group comment letter

The Casualty Practice Council submitted written comments to the Washington, D.C. Department of Insurance, Securities and Banking's (DISB) Request for Comments on evaluating unintentional bias in private passenger automobile insurance. The letter expanded on the Academy's previous comments to the DISB on recommended actuarial considerations for determining unintentional bias in auto insurance. 

Annuity Reserves and Capital Work Group Submits Comments on VM-22 Longevity Reinsurance Proposal

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).

Life Illustrations Work Group Comment Letter

The Casualty Practice Council submitted written comments following the Washington, D.C. Department of Insurance, Securities and Banking (DISB) on their hearing, "Initiative to Evaluate Unintentional Bias in Private Passenger Automobile Insurance." The letter expanded on the Academy's verbal presentation on the recommended actuarial considerations for determining unintentional bias in auto insurance. 

Comment Letter on Exposure 3.1 of the Proposed Actuarial Guideline ILVA

Academy Comment Letter on APF 2022-04 Swap Spreads 

Comment Letter to the Senate Banking, Housing and Urban Affairs on NFIP

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.”

The Health Practice Council’s Individual and Small Group Markets Committee and Active Benefits Subcommittee submitted comments to the Internal Revenue Service (IRS) on the proposed rule for “Affordability of Employer Coverage for Family Members of Employees.” The comments relate to provisions addressing the so-called “family glitch,” revisions to the employer coverage affordability test, and the Minimum Value (MV) Calculator.

Comment letter from the Casualty Practice Council, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP No. 29, Expense Provisions.

Extreme Events Committee comments to the House Financial Services Subcommittee on Housing, Community Development, and Insurance on the committee's proposed reauthorization and reforms of the National Flood Insurance Program, in advance of the congressional hearing. 

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).

Cyber Risk Task Force comments to the U.S. Department of the Treasury and Federal Insurance Office (FIO) request for comment (RFC) on the effectiveness of the cyber considerations of the Terrorism Risk Insurance Program, originating from the Terrorism Risk Insurance Act of 2002.

Academy Comment Letter on Exposure of Proposed Actuarial Guideline related to Asset Adequacy Testing 

Academy Comment Letter to the Colorado Division of Insurance on SB21-169 on Life Insurance Underwriting 

Academy Comment Letter on Exposure of Proposed Actuarial Guideline on Nonforfeiture Requirements for Index Linked Variable Annuity Products Supported by Non-Unitized Accounts.

The Asset Modeling and Reporting Task Force submitted comments on the draft Actuarial Guideline (AG) on Asset Adequacy Testing (AAT) which was exposed during the NAIC’s Life Actuarial Task Force’s February 10 meeting.

The Life Valuation Committee submitted comments on APF 2020-12 regarding hedging in VM-20 and VM-21 to the NAIC’s Life Actuarial Task Force.

The Life Underwriting and Risk Classification Work Group submitted comments to the NAIC’s Accelerated Underwriting (A) Working Group Ad Hoc Drafting Subgroup’s Educational Report exposure draft of March 4, 2022.

The Life Reserves Work Group, Annuity Reserves and Capital Work Group, and Variable Annuity Reserves and Capital Work Group submit an amendment proposal and presentation to the NAIC’s Life Actuarial Task Force on Swap Spreads and the London Inter-bank Offered Rate Transition to the Secured Overnight Financing Rate.

The Long-Term Care Medicaid Subcommittee submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on the proposed rule, “Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs.” The comments focused on dual-eligible special needs plans (D-SNP’s) and separate medical loss ratio (MLR) requirements.

The Annuity Reserves and Capital Work Group Submitted Recommendations of Aggregation Principles as outlined in the Academy’s Preliminary Framework Elements for Fixed Annuity Principle-Based Reserving to the National Association of Insurance Commissioners’ Life Actuarial Task Force’s VM-22 Subgroup.