Comment Letters
March 12, 2026
RRC Comments Regarding Request for Comments on RBC Gaps
Authored by: Dave Heppen, Partner, Lynn Manchester, Director, Veronika Cooper, Senior Associate, Becky Sheppard, Senior Manager The Risk-Based Capital Model Governance (EX) Task Force exposed a new document on February 10, 2026, requesting comments “…from interested parties to identify gaps and inconsistencies across the RBC framework”. Risk & Regulatory Consulting, LLC (“RRC”) regularly supports regulators...
September 5, 2025
RRC Comments Regarding the AI Systems Evaluation Tool to Identify and Assess the AI Related Risks of Insurers
Authored by: Lauren Cavanaugh, FCAS, MAAA, Partner, Liz Wortman, ACAS, MAAA, Scott Merkord, FCAS, MAAA, CPCU and Sandeep Patil, FSA, CERA, MAAA The Big Data and Artificial Intelligence (H) Working Group has released a draft version of an AI Systems Evaluation Tool to identify and assess the AI-related risks of insurers. The Working Group has...
July 24, 2025
RRC Comments Regarding Request for Comments on Proposed Preliminary Risk-Based Capital (“RBC”) Principles and Questions
Authored by: Patricia Matson, FSA, MAAA, Partner, Lynn Manchester, FSA, MAAA, Director and Janine Bender, ASA, MAAA, Supervisor The Risk-Based Capital Model Governance (EX) Task Force is requesting comments on the proposed preliminary Risk-Based Capital (“RBC”) principles and questions (“the Exposure”). Risk & Regulatory Consulting, LLC (“RRC”) appreciates the opportunity to offer our comments on...
December 6, 2024
RRC Comments Regarding GOES (E/A) Subgroup’s GOES Model Governance Framework Draft Exposure
Authored by: Tricia Matson, Partner and Lynn Manchester, Director and Janine Bender, Supervisor The Generator of Economic Scenarios (“GOES”) (E/A) Subgroup (“Subgroup”) is requesting comments on the GOES Model Governance Framework Draft (“the Exposure”). RRC appreciates the opportunity to offer our comments on the Exposure. Should you have any questions, we would be glad to...
October 11, 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 (AG) Draft (“the Exposure”). Per LATF’s request for earlier comments regarding the Scope and Aggregation sections of the Exposure, RRC provided prior comment letters on September 19th.and October 3rd. For...
October 3, 2024
RRC Comments Regarding LATF’s Reinsurance AAT Actuarial Guideline Draft Exposure and Aggregation
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 and Aggregation sections of the Exposure be provided by October 3rd. Originally, comments on the Scope section were due...
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...
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RRC Comments Regarding GIC Funding Agreements and Stable Value Contracts in Scope of VM-22