AAA - American Academy of Actuaries - Documents

  • 1987-1, NAIC Proceedings - .....a regular basis on these activities to Academy members through such Academy publications as the Government Relations Watch, the Issues Digest and Actuarial Update.

1970s

  • 1977-1, NAIC Proceedings - Initial Expense Allowance - ATTACHMENT D - Linkage of Nonforfeiture Values With Valuation Reserves - Prepared By The Society of Actuaries Special Committee on Nonforfeiture Values
  • 19xx - Report - AAA - Historical Notes For The Period Prior To October 25, 1965, American Academy of Actuaries, by Walter L. Rugland - 128p
  • 1979 1127 - Letter - AAA to Wesley J. Kinder, California Commissioner of Insurance - Statement 1979-27 (p329 - Journal of the American Academy of Actuaries)  actuary.org/sites/default/files/files/publications/journal_1979.pdf
    • re: 1979 - GAO - Issues and Needed Improvements in State Regulation of the Insurance Business, Government Accountability Office - 298p
    • I am certain that you are keenly aware of the major report of the General Accounting Office (GAO) concerning state regulation of the insurance industry dated October 9, 1979.
      • There are a number of items discussed in the report which, I am sure, are of great interest to the NAIC and to state regulators in general.
    • One matter dealt with at some length in Chapter 3 of the report is the role of actuaries in the state regulatory mechanism.
      • The report indicates that "actuarial science is perhaps the most relevant professional background for an insurance department" but goes on to discuss a shortage of professionals with specialized training relevant to the insurance business and notes that "in particular, there are few certified actuaries" .

1980s

  • 1981 0602 - Letter - AAA to NAIC (Manipulation) - Journal, American Academy of Actuaries -Statement 1981-12 - p144-155 - 12p
    • Investment Generation Method, New Money, Portfolio Method, Illustrations
  • 1982 07 - AAA - (EAR) - Enrolled Actuaries Report - <Actuarial – WishList>
    • Future developments are foreseen to include a switching from traditional life insurance to universal life...  (p5)
  • 1984 - Letter - AAA - Journal - American Academy of Actuaries - Statement 1984-32
    • (p217) - The "unbundling" of services and other product differences  between Universal Life and Ordinary Life cause current literature to be inapplicable, as well as insufficient, for Universal Life.
  • 1985-1B, NAIC Proceedings - Letter - 1984 1212 - AAA - The NAIC And The Actuarial Profession - Attachment Three - American Academy of Actuaries
    • Statement of Stephen G. Kellison, Executive Director Of The American Academy Of Actuaries To The NAIC Technical Services Ex5 Subcommittee
      • The purpose of this statement is to speak in favor of establishment of a more organized coordination between the NAIC and the actuarial profession.
      • The American Academy of Actuaries is the public interface organization for the actuarial profession in the U.S. and includes actuaries in all areas of specialization within its membership.
      • The balance of this statement discusses ways of achieving stronger liaison.
  • 1985 11 - Report -  AAA - The Academy report, Dividend Recommendations and Interpretations (November 1985), describes this principle as the distribution of the aggregate divisible surplus among policies in the same proportion as the policies are considered to have contributed to divisible surplus.
    • In a broad sense, the Contribution Principle underlies the essential equity implied by participating business.
  • 1986 1030 - Report - AAA to NAIC (Blanks Task Force) - RE: Life Insurance Non-Guarantee Elements - Attachment Three, American Academy of Actuaries - 1987-1, NAIC Proceedings - (p276B-276C) - 2p
    • Products that contain non-guarantee charges, benefits or premiums have become a very significant portion of today's life insurance market.
    • Universal life insurance is only one example of such a product.
    • Various insurance departments have expressed concern that adequate information on these new products is not being provided in the annual report to the insurance departments.
    • As a result, the Academy appointed a task force on non-guarantee elements.
  • 1987-2, NAIC Proceedings - 
    • Attachment Four - Comments Received from Industry Regarding Proposed Amendments to NAIC Model Rules Governing the Advertising of Life Insurance
    • AAA - American Academy of Actuaries, William T. Tozer, Chairman of the Task Force on Non-Guaranteed elements.
      • Recommended modifications specific to definitions and sales illustrations directly related to life insurance products which contain "non-guaranteed elements;" e.g. values, premiums or benefits whose amount is not guaranteed by the term of the contract.
      • Response: The suggested changes were consistent with the intent of the proposal; and were incorporated into the draft of the rule.

1990s

  • 1995 0822 - Report - AAA - Report to the NAIC - State Variations and Their Impact on Valuation, Report of American Academy of Actuaries Task Force on State Variations in Valuation Laws

  • 1995 1121 - Report - AAA - Report to the NAIC - State Variations and Their Impact on Valuation: Follow-Up Report, Report of American Academy of Actuaries Task Force on State Variations to NAIC

  • 1996 0510 - Report - AAA -Report to the NAIC -  State Variations in Valuation Laws, Report of American Academy of Actuaries Task Force on State Variations in Valuation Laws
  • 1996-1, NAIC Proceedings - Report - AAA - ATTACHMENT ONE-A - SNFL - Proposed New Standard Nonforfeiture Law For Life Insurance (Preliminary Work By American Academy of Actuaries Committee on Life Insurance and Other Professional / Regulatory Bodies) - From Randy Mire
  • 1997-1, NAIC Proceedings - Report - AAA - 1997 0311 - Attachment Two-D - American Academy of Actuaries - Task Force on Equity-Indexed Products, chaired by Donna R. Claire - 
  • 1998 06 - Report - AAA to NAIC (Life Disclosure Working Group) - Survey of First-Year Company Experience Under Life Illustration Regulations Based on the New NAIC Model, Report of the Disclosure Working Group Committee on State Life Insurance Issues, American Academy of Actuaries - 33p
  • 1999 07 - Report - AAA - Special Issues for Equity Indexed Products, American Academy of Actuaries - 25p
    • Committee on State Life Insurance Issues of the American Academy of Actuaries
  • 1999 10 - Report - AAA to NAIC (Life and Health Actuarial Task Force) - Report of the American Academy of Actuaries Variable Life Reserving Guideline Work Group To the NAIC’s, American Academy of Actuaries - 12p
  • 1999 10 - Report - AAA to NAIC (Life and Health Actuarial Task Force) - Report of the American Academy of Actuaries' Equity Indexed Universal Life Work Group, American Academy of Actuaries - 19p

2000s

  • 2000 - Report - AAA to NAIC (LHATF) - Interim Report of the EMO Work Group To the Innovative Products Working Group Life and Health Actuarial (Technical) Task Force, American Academy of Actuaries - 18p
  • 2000 09 - Report - AAA to NAIC (Life Liquidity Risk Working Group) - Life Liquidity Work Group of the American Academy of Actuaries - 24p
    • Donna R. Claire, Chair
  • 2000 1202 - Report - AAA to NAIC (Life Liquidity Working Group) - Life Liquidity Work Group of the American Academy of Actuaries, Donna R. Claire, Chair - 26p
  • 2001 02 - Report - AAA - XXX Practice Note - NAIC Model Regulation XXX, American Academy of Actuaries - 17p
  • 2001 05 - Report - AAA - Practice Note: Selecting and Documenting Investment Return Assumptions, American Academy of Actuaries - 22p
    • On September 12, 2012, the Pension Practice Council withdrew the May 2001 practice note, Selecting and Documenting Investment Return Assumptions.
  • 2002 09 - Report - A Public Policy Monograph - Fair Valuation of Insurance Liabilities, American Academy of Actuaries - 48p
  • 2003 - Report - AAA - Role of the Actuary Under Federal Insurance Regulation, Public Policy Monograph, American Academy of Actuaries - 20p
  • 2005 03 - Report - AAA to NAIC (LATF) - Progress Report of the American Academy of Actuaries’ - Universal Life Work Group - 5p
  • 2005-2, NAIC Proc. - AAA to NAIC - Report of the American Academy of Actuaries - Executive Summary - (p1687)
    • SNFL - Historical Developments
  • 2005 06 - Letter - AAA to GAO - Questions from Phone Conference with GAO On March 31, 2005, American Academy of Actuaries - 5p
    • 1. A brief background on broad categories of actuarial activities.
    • 2. Also please briefly highlight the differences in actuarial activities between life, health and property casualty insurance.
    • 3. Please briefly describe the role actuaries of an insurance company have on the product development (form) side.
    • 4. Please describe the role actuaries have in the insurance regulatory process
    • 5. Are there elements that make a line of insurance a commercial product instead of a personal product, other than that the coverage is for a place of business?
    • 6. With respect to the three financial service areas of insurance, banking and securities, we would like to have a more inclusive list of competing and hybrid products:
    • 7. In general, when is pricing more a function of a state’s public policy/regulatory philosophy than a function of actuarial activities?
    • 8. What are some of the academic definitions of “insurance” (We are aware of NAIC’s White Paper, Gramm-Leach-Bliley, Internal Revenue Code, Terri Vaughan’s textbook), and what would you describe as the major or necessary elements?
  • 2005 09 - Report - AAA to NAIC (LATF) - Conceptual Framework of a Principle-based Approach for Life Insurance Products from the American Academy of Actuaries’ Universal Life Work Group - 43p
  • 2006 04 - Report - AAA to NAIC (LATF) - Principles-Based Reserves for Universal Life with a Secondary Guarantee based on a Shadow Fund from the American Academy of Actuaries’ Life Reserves Work Group - 20p
  • 2006 06 - Report - AAA to NAIC - Report on PBA Review and Other Governance Issues of Principles-Based Valuation From the American Academy of Actuaries Principle-Based Review and Governance Work Group
    Presented to the National Association of Insurance Commissioners Life and Health Actuarial Task Force - 69p
  • 2006 12 - Report - AAA to NAIC - Report on Valuation Effects of a Principle Based Approach (“PBA”) For Accumulation Type Universal Life, American Academy of Actuaries’ Life Reserves Work Group Modeling Subgroup - 15p
    • The following items are typically considered Non-Guaranteed Elements in a flexible premium UL contract:
      • Monthly contract charges and policy loads
      • COI charges
      • Spreads on credited interest rates vs. the actual investment earned rate
  • 2007 03 - Report - AAA to NAIC - Report the American Academy of Actuaries’ Valuation and Law Manual Team
    Presented to the National Association of Insurance Commissioners’ Life and Health Actuarial Task Force - 4p
  • 2008 0910 - AAA to SEC - Initial Comments on Release Nos. 33-8933 & 34-58022 (File No. S7-14-08): Proposed Rule 151A, American Academy of Actuaries - 67p
    • The charges which are characteristic of a universal life contract are ...
      • Premium Loads are assessed on premiums paid to cover state premium tax, DAC tax and sales related expenses. They are expressed as a percent of premiums and are deducted from premiums upon receipt.
      • Monthly Loads can be on a per policy and a per unit basis. They are deducted from the daily interest account or the equity indexed bucket(s) on monthiversaries.
      • Cost of Insurance charges are deducted from the daily interest account or the equity indexed bucket(s) on monthiversaries.
  • 2009 0123 - Testimony to NCOIL - AAA - Actuarial Principles, Risk Management Principles, and Insurance Principles for the Solvency & Risk Management of Credit Default Swaps (CDS) - Why and How? - 3p
  • 2009 0305 - Testimony to GOV (Senate) - AAA - James Rech, Vice President, Risk Management and Financial Reporting Council of the American Academy of Actuaries - 5p
    • Systemic risk is an issue within the insurance industry.
    • The viability of the insurance sector rests on the perception that insurers can and will meet their promises
    • 2009 0305 - GOV (Senate) - American International Group: Examining What Went Wrong, Government Intervention, And Implications for Future Regulation, (CSPAN) Government Intervention and Regulation of AIG, Chris Dodd (D-CT)  ---  [BonkNote]
  • 2009 0514 - Testimony to GOV (House) - AAA - James Rech, Vice President, Risk Management and Financial Reporting Council of the American Academy of Actuaries - 12p
    • 2009 0514 - GOV (House) - How Should the Federal Government Oversee Insurance?, Paul Kanjorski (D-PA)  ---  [BonkNote]
    • Actuarial input is fundamental to achieving any regulator’s objective of protecting insurance consumers and preserving the financial integrity of the marketplace.
      • In fact, the core expertise of actuarial work is the management and assessment of the risks that result when financial promises are made.
    • Report - Concepts for Successful Regulation of Systemic Risk
      • Management of systemic risk is a process of creating accountability and transparency through the identification, measurement and management of risk.
        • It is now widely understood that our current financial crisis, with all its various contributing factors, represents a massive failure of systemic risk management.
          • Our nation’s regulatory framework requires fundamental change in order to better anticipate and contain future systemic failures.
        • In this paper, we elaborate on what we consider to be the key requirements for effective regulation of systemic risks:
          • Identification of systemic risk
          • Measurement and monitoring of risk
          • Management of systemic risk
        • Section 1: Identification of Systemic Risk
          • 1.1 Definition of Systemic Risk
            • As a working premise, we define systemic risk to be the risk of a failure in a transaction or series of transactions extending beyond the parties directly involved, impacting many or most participants in the marketplace.
            • And the public gains awareness of these systemic effects on the larger group only after the breakdown has occurred.
            • The successful identification of systemic risk needs to include the consideration of the impact of risks that are currently considered highly improbable or not measurable.
  • 2008 0729 - Letter - AAA to GOV (Senate) - American Academy of Actuaries - re HR 5840 - 2p
    • On behalf of the Financial Regulatory Reform Task Force of the American Academy of Actuaries1, I strongly encourage you to explicitly define the role of the actuary in this legislation.
      • Ensuring that the actuary maintains a key role in any potential federal regulatory structure for insurance is fundamental to the objective of protecting insurance consumers and preserving the financial integrity of the industry.
    • 2003 - Report - AAA - Role of the Actuary Under Federal Insurance Regulation, Public Policy Monograph, American Academy of Actuaries - 20p
  • 2009 1124 - AAA to GOV (House) (Barney Frank (D-MA) / Spencer Bachus (R-AL)) - Financial Regulatory Reform Task Force of the American Academy of Actuaries - 3p
    • Product designs can be complex, with benefits contingent on a range of potential risks that may vary over time, as well as with certain guarantees made by the insurer.

2010s

  • 2010 - Report - AAA - Role of the Actuary Under Federal Risk and Insurance Oversight - Public Policy Monograph, Jesse M. Schwartz, Chair, Financial Regulatory Reform Task Force - American Academy of Actuaries - 22p
  • <WishList> - Report - AAA - Statutory Margins within a Principle-Based Valuation System - Part 1
  • 2010 03 - Report - AAA - Statutory Margins within a Principle-Based Valuation System – Part 2, From the American Academy of Actuaries’ Life Reserves Work Group Presented to the National Association of Insurance Commissioners’ Life and Health Actuarial Task Force - 6p
  • 2011 0225 - Letter - AAA - American Academy of Actuaries to FSOC - Re: Authority to Require Supervision and Regulation of Certain Non-Bank Financial Companies (12 CFR Part 1310) - Jesse M. Schwartz, Chair, Financial Regulatory Reform Task Force, American Academy of Actuaries - 8p
  • 2014 0311 - Letter - AAA - American Academy of Actuaries - GOV (Senate) - re Finding the Right Capital Regulation for Insurers - William C. Hines - 6p
  • 2014 0320 - AAA - Actuary Serving Congress: A Conversation with GAO’s Chief Actuary, American Academy of Actuaries - 35p
  • 2014 1205 - Letter - AAA to NAIC - Comments on Exposure Draft of Life Insurance and Annuity Pricing ASOP - Life Products Committee (LPrC) comment letter to Actuarial Standards Board on exposure draft of an Actuarial Standard of Practice (ASOP) on Life Insurance and Annuity Pricing - 6p
  • 2015 0501 - Letter - AAA to IAIS - Committee Comments To IAIS on Conduct of Business Risk Draft Paper, American Academy of Actuaries - 4p
    • ...customers may be satisfied with companies because they provide inexpensive products, but the customers may be misinformed about what is being sold. (p3)
  • 2017 1115 - Letter - AAA to NAIC (LIBWG), American Academy of Actuaries - 2p
    • Universal life also allows for flexibility in policy benefits, not just premium payments.
  • 2018 02 - Report - AAA - Life Insurance Illustrations: Application of the NAIC Life Insurance Illustrations Model Regulation and Actuarial Standard of Practice No. 24, A Public Policy Practice Note, American Academy of Actuaries - 113p
  • 2018 0831 - Letter - AAA, American Academy of Actuaries to NAIC (Liquidity Assessment (EX) Subgroup, Re: Scope of Insurers Subject to Liquidity Stress Test - The American Academy of Actuaries Life Practice Council’s Macroprudential Task Force (MPTF) - 4p
    • At times, liquidity risk arises because liquid markets become temporarily illiquid. Moreover, a liquidity event can be triggered by factors that are noneconomic, such as a loss of confidence related to a ratings downgrade.
    • It is somewhat less clear that the scope criteria are congruent with the microprudential objectives of the framework.
    • It may be useful to review historical significant liquidity-related events (above a certain size) to determine whether the scope criteria would have captured these entities within the exercise.
      • For example, neither cash-outs of life insurance policies nor contractual downgrade provisions are included within the proposed scope criteria.
  • 2019 0731 - Letter - AAA to ASB - Re: Proposed Actuarial Standard of Practice (ASOP), Setting Assumptions - 2p
    • Section 2.1 - Is an assumption always a value?
      • Aren’t there assumptions about how things work or formulas/methodologies for projections?

2020s

  • 2020 1117 - AAA to EBSA - RFC - Pension Benefit Statements—Lifetime Income Illustrations, RIN 1210-AB20, American Academy of Actuaries - 6p