Comment Letters
October 31, 2018
Request for Comments on Receivership Model Law – Working Group’s Draft Proposed revisions to the Life and Health Insurance Guaranty Association Model Act (#520)
From: Wayne Johnson, Jan Moenck and Eric Scott To: Bill Rivers, NAIC On behalf of the Risk & Regulatory Consulting, LLC (“RRC”), this letter responds to your request for input and perspective on the Receivership Model Law (E) Working Group’s Draft Revisions to the Life and Health Insurance Guaranty Association Model Act. RRC appreciates the...
May 8, 2018
RRC Response to the Questions in the NAIC Group Capital Calculation Working Group
From: Tricia Matson & LeeAnne Creevy To: David Altmaier, Chair At the Spring National Meeting, the National Association of Insurance Commissioners (“NAIC”) Group Capital Calculation Working Group (“GCCWG”) exposed a memo from NAIC staff dated February 28th (updated for comments from the March 24th meeting) that included a proposed approach to determining the scope of...
January 12, 2018
RRC Response to the NAIC Big Data (EX) Working Group regarding the Regulatory Framework – Proposed Structure and Issues for Discussion
From: John Humphries, Dave Heppen, and Debbie Rosenberg - Risk & Regulatory Consulting, LLC To: Tim Mullen, NAIC Director of Market Regulation Risk & Regulatory Consulting, LLC (“RRC” or “we”) supports the efforts of the Big Data (EX) Working Group (“Working Group”) to outline a process for determining whether changes to the current regulatory framework...
September 29, 2017
RRC Response to the revision of the NAIC Own Risk and Solvency Assessment (ORSA) Guidance Manual to be published in December 2017
From: Tricia Matson, LeeAnne Creevy, and Nan Nguyen To: Christy Neighbors, Chair (Nebraska), Group Solvency Issues (E) Working Group The National Association of Insurance Commissioners (“NAIC”) Group Solvency Issues (E) Working Group (GSIWG) sent out a revision of the NAIC Own Risk and Solvency Assessment (ORSA) Guidance Manual (“the Guidance Manual”) and requested public comments....
July 28, 2017
RRC Response to the NAIC Big Data (EX) Working Group regarding the Shared Resource-Complex Models Proposal
From: Tricia Matson and Dave Heppen To: Commissioner Laura Cali Robison (OR), Chair, NAIC Big Data (EX) Working Group(E) Working Group Risk & Regulatory Consulting (“RRC” or “we”) supports the efforts of the Big Data (EX) Working Group (“BDWG”) to create a mechanism that increases the resources available to states for the review and collection...
May 16, 2016
RRC Response to the ACLI’s presentation on “An Aggregation & Calibration Approach to Insurer Group Capital”
From: Pat Tracy, LeeAnne Creevy, and Tricia Matson To: David Altamaier, Chair (Florida), and members of the group Capital Calculation (E) Working Group The National Association of Insurance Commissioners (“NAIC”) Group Capital Calculation Working Group (“GCCWG”) is evaluating potential approaches for aggregation of capital at the insurance group level (“RBC Aggregation Approach”), in particular for...
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RRC Comments on ASOP 22