Comment Letters
September 19, 2024
RRC Comments Regarding LATF’s Reinsurance AAT Actuarial Guideline Draft Exposure
Authored by: Tricia Matson, Partner and Ben Leiser, Director The Life Actuarial Task Force (LATF) is requesting comments on the AAT for Reinsurance Actuarial Guideline Draft (“the Exposure”). LATF has asked that comments regarding the Scope section of the Exposure be provided by September 19th, and we have included in this comment letter some general...
March 28, 2024
RRC Comments Regarding the Framework for Regulation of Insurers Investments
Authored by: Tricia Matson, Partner and Edward Toy, Director The Financial Condition (E) Committee (“E Committee”) exposed a document on August 15, 2023, for comment entitled “Framework for Regulation of Insurer Investments – A Holistic Review”. RRC submitted a comment letter dated September 15, 2023. RRC also made oral comments in Orlando at the NAIC’s...
September 15, 2023
RRC Comments Regarding the Framework for Regulation of Insurers Investments
Authored by: Tricia Matson, Partner and Edward Toy, Director The Financial Condition (E) Committee exposed a document on August 15 for comment entitled “Framework for Regulation of Insurer Investments – A Holistic Review”. RRC appreciates the opportunity to offer our comments. Should you have any questions, we would be glad to discuss our comments with...
April 11, 2023
RRC Comments Regarding the Proposal for Valuation Manual Revised Hedge Modeling Language in VM-21
Authored by: Ben Leiser The Life Actuarial Task Force exposed for comment a proposal to revise the hedge modeling language in the Valuation Manual to address index credit hedging. RRC appreciates the opportunity to offer our comments. Should you have any questions, we would be glad to discuss our comments with you and the LATF...
January 3, 2022
RRC Comments Regarding Regulatory Considerations Applicable (But Not Exclusive) to PE Owned Insurers
Authored by: Tricia Matson & Ed Toy The Macroprudential (E) Working Group (MWG) and Financial Stability (E) Task Force (FSTF) exposed for comment a set of Regulatory Considerations Applicable (But Not Exclusive) to Private Equity (PE) Owned Insurers (Considerations). RRC appreciates the opportunity to offer our comments. Should you have any questions, we would be...
December 6, 2021
RRC Comments on Long Term Care Insurance Multistate Rate Review Framework
Authored by: Tricia Matson The Long Term Care Insurance Multistate Rate Review Subgroup (“the Subgroup”) exposed a Long Term Care Insurance (LTCI) Multistate Rate Review Framework (“the Framework”) which covers a potential approach to increase consistency of LTCI rate review actions across states and improve efficiency of LTCI rate reviews for insurers. RRC appreciates the...
November 18, 2021
RRC Comments Regarding AG on Complex Assets
Authored by: Tricia Matson & Ed Toy The Life Actuarial Task Force (LATF) issued a request for feedback related to the concept of an actuarial guideline (AG) focusing on modeling of complex or high-yielding assets in asset adequacy testing (AAT). This request relates to the increasing use of complex investments to back reserves, and the...
March 31, 2021
2020 NAIC Liquidity Stress Test Framework for Life Insurers Meeting the Scope Criteria
Dear Commissioner Caride and Mr. Schrader: Risk & Regulatory Consulting, LLC (“RRC” or “we”) supports the efforts of the Financial Stability (EX) Task Force and the Liquidity Assessment (EX) Subgroup (“Subgroup”) to provide additional tools to enable an assessment of macroprudential impacts on the broader financial markets of a liquidity stress impacting a number of...
May 22, 2020
RRC’s Comments Regarding the Draft Template that State DOIs may use to Assist in Assessing the Impact of COVID-19 on 2021 ACA Rates
The April 23 rd , 2020 Health Actuarial (B) Task Force (HATF) meeting included multiple presentations regarding the potential impact of the ongoing COVID-19 pandemic on the health insurance marketplace. The meeting provided an opportunity for members of HATF, interested regulators, and Interested Parties to gain perspective on considerations that may impact the 2021 Patient...
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RRC Comments Regarding LATF’s Reinsurance AAT Actuarial Guideline Draft Exposure and Aggregation