-Copy - ACLI - Documents

1970s

  • 1976 0909 - Letter - ACLI to NAIC - RE: Proposed Changes to the NAIC Model Variable Life Insurance Regulation - 1976-1 - NAIC Proceedings - p623-
    • p41 - The most obvious, though not necessarily accurate, basis of comparison of policies of the same initial or minimum face value is the premium. 
  • [  ] -- 1976 1129 - 1977-1, NAIC Proc. - Letter - ACLI to NAIC - re: Proposed Changes to NAIC Model Variable Life Insurance Regulation - p620-623  - Variable Life and Variable Annuities- () - NAIC -  
    • [  ]  --p623- - 1976 0909 -  Richard Hemmings' September 9, 1976 memorandum entitled "Recommendations on the Industry Proposed Changes of the NAIC Model Variable Life Insurance Regulation."
      • This memorandum is a review of the American Council of Life Insurance (formerly ALIA hereafter referred to as "Council.") recommended changes to the NAIC Model Variable Life Insurance Regulation which were first submitted to the (C4) Subcommittee at the NAIC December, 1975 meeting. 
    • [  ]  -- "Recommended Changes to NAIC Model Variable Life Insurance Regulation" dated April 30 and submitted to the NAIC (C4) Subcommittee by the ACLI on May 3, 1976.
  • 1978 1002 - Letter - ACLI to NAIC - ACLI Draft Proposed Minimum Nonforfeiture Guideline Requirements for Approval of Partial-Endowment-Type Products (Deposit Term) - 1979-1, NAIC Proceedings - xp
  • 1979 0525 - Letter - ACLI to NAIC Life Insurance (C3) Cost Disclosure Task Force - Re: The Report of the Industry Advisory Committee on Policy Lapsation - 1979-2, NAIC Proceedings

1980s

  • 1980 0130 - Letter - ACLI to GOV (Senator Howard Cannon (D-NV), The FTC Staff's Responses to Criticisms of the Report on Life Insurance Cost Disclosure - (p130-136)
    • (p130) - DEAR SENATOR CANNON: Enclosed is a copy of the response of the American Council of Life Insurance to the comments by the Federal Trade Commission on the Council's testimony on the Commission's life insurance cost disclosure report which was issued on July 10, 1979.
    • 1979 0710 and 1017 - GOV (Senate) - FTC Study of Life Insurance Cost Disclosure, Howard Cannon (D-NV)   ---  [BonkNote]  ---  [PDF-592p] 
  • x - 1980 0902 - Report - ACLI to NAIC - To: NAIC (A) Committee's Task Force on Life Insurance Cost Disclosure - Task Force Report of the Subcommittee on Cost Comparisons, Attachment Four-A - 1982-1, NAIC Proc. - 4p
    • An additional item of information that is recommended to be required in the policy summary is the point at which the policy will expire based on the policy guarantees and the anticipated premiums shown in the summary.
  • 1980 0915 - Letter - ACLI to NAIC - To: Task Force on Subsidiaries and MSVR Rules of the the NAIC Valuation of Securities Subcommittee, Re: Mandatory Securities Valuation Reserve Requirements for Controlled Subsidiaries - 1981-1, NAIC Proc. - xp
    • (p181) - Until fairly recently, subsidiaries were not an important aspect of the life insurance business.
      • In the 1960's, however, there was a strong movement toward diversification via subsidiaries to enable life insurance companies to market other products and skills to meet all of an individual's needs for financial security, and also to move into other enterprises which may be financially advantageous. (p181)
  • x - 1981 0831 - Letter - ACLI to NASAA / NAIC - To: The NASAA / NAIC Joint Regulatory Insurance Products Study Committee - 1982-1, NAIC Proc. - 10p
    • [Universal Life Policy] ...merely afford purchasers greater flexibility in designing their contracts so as to meet their individual needs.
  • x - 1981 1215 - Letter - ACLI to NAIC - To: The NAIC (A) Committee's Task Force on Life Insurance Cost Disclosure - 1982-1, NAIC Proc. - 1p
  • 1981 1215 - Report - ACLI to NAIC - Paper on Cost Disclosure for Universal Life, by the Special Task Force of the ACLI Cost Disclosure Subcommittee to NAIC Task Force on Life Insurance Cost Disclosure - 1982-1, NAIC Proc. - 4p
  • 1982 0608 - Letter - ACLI to NAIC - To: the NAIC (A) Committee's Manipulation, Lapsation, Dividend Practices and Annuity Disclosure Task Force - (p524-526) - 1982-2, NAIC Proc. - xp
  • 1982 1129 - Letter - ACLI to NAIC - To: The NAIC (A) Committee's Life Cost Disclosure Task Force - p523-? - 1983-1, NAIC Proc. - 27p 
    • [Bonk:  Also Found in NAIC Life Insurance Buyer's Guide editions until the 1996 Proc. 3rd Quarter 9, 40, 907, 918, 931-936 (amended Buyer’s Guide)]
  • 1988 0613 - Letter - ACLI to NAIC - To: the NAIC Market Conduct Surveillance (EX3) Task Force, Subgroup on Life Advertising Issues - 1988-2, NAIC Proc. - 3p

1990s

  • 1990 09 - Report - ACLI - re: Solvency Concerns - p313-x
    • 1990 1210 - GOV (Senate) - Insurance Company Solvency: Insurance Company Solvency and Reporting Methods, Howard Metzenbaum (D-OH)  ---  [BonkNote]
  • 1990 1207 - Letter - ACLI to GOV - from Richard S. Schweiker, president, American Council of Life Insurance, re: Accounting Practices of the Life Insurance Industry - 433
    • 1990 1210 - GOV (Senate) - Insurance Company Solvency: Insurance Company Solvency and Reporting Methods, Howard Metzenbaum (D-OH)  ---  [BonkNote]
  • 1995 0911 - Letter - ACLI to NAIC - Before The Guaranty Fund Issues (EX5) Working Group B - Policyholder Protection In Insurance Company Failures - ATTACHMENT FOUR-C -  
    • --  1995-3, NAIC Proceedings
  • 1996 0530 - Letter - ACLI to SEC - re: 12-b1 / Variable Life - 3p
  • 1999 1221 - Letter - ACLI to SEC - re: Supplemental Submission on Proposed Registration Form N-6 for Insurance Company Separate Accounts Organized as Unit Investment Trusts that Fund Variable Life Insurance Contracts; File No, S7-9-98 - 27p
    • Disclosure, Focus Groups
    • (p9-) - Testing SEC Versus ACLI Versions of Cost and Fee Disclosure Information for Variable Life Insurance: A Report on Four Focus Groups, by Mathew Greenwald & Associates

2000s

  • 2003 0215 - The National Journal - Pumping New Life Into the ACLI  - SECTION: LOBBYING; Vol. 35, No. 7 - georgewbushlibrary.gov/s3fs-public/2019-02/t081-026af-554859-20180011p.pdf
    • When Frank Keating, a self-described "unabashed conservative Republican" and loyal supporter of George W. Bush, started his new job on January 14 as president of the American Council of Life Insurers, he got a rude surprise from the Bush administration. 
    • On top of that, the president's new retirement and lifetime savings plan would further devastate the annuity business. If adopted, the plan would allow an individual to invest up to $7,500 a year in tax-exempt accounts. One advantage of an annuity is that it allows tax-deferred growth of assets, but the tax advantage of an annuity would be unattractive compared to those of tax-free dividends and unrestricted tax-exempt withdrawals from a retirement account.. 
    • Recently, Sy Sternberg, chairman and CEO of New York Life Insurance Company, reinforced just how much the ACLI's 400 member companies are counting on the former governor. "He said, 'Frank, you're our guy in Washington. We don't have anyone else,'
      • "Keating said in an interview from an office that enjoys a postcard view of the Capitol. Unlike banks, which rely on the Office of the Comptroller of the Currency and the Federal Reserve Board to look after their interests as well as to regulate, and securities firms, which enjoy a similar relationship with the Securities and Exchange Commission, insurance companies have no federal agency.
      • Insurance is state-regulated, which heightens the role of trade groups like the ACLI.
    • Keating says he and his staff have just started talking to the administration and to the new Congress about the problems in the tax plan. "We are at the table, and we intend to continue to argue our interests," he said. "There is a big difference between the tobacco lobby and the insurance lobby. We wear a white hat always. We provide an opportunity for a good tomorrow and comfort, security, and pride in one's old age. So, we don't .back up to the pay window with our message. It should be heard, because it's a good message.''
  • 2004 - Report - ACLI / IAA - Renewal Premiums and Discretionary Participation Features of a Life Insurance, A Joint Research Project - 52p
  • 2006 1017 - Letter - ACLI to Antitrust Modernization Commission - Re: Comments regarding October 18, 2006 public hearing on the McCarran-Ferguson Act, Gary Hughes - 3p
    • As you are aware, the insurance industry is undergoing the most significant debate regarding its regulatory future since the Armstrong Committee Report of 1906,3  which ushered in the modern state of insurance regulation that has persisted for the past one-hundred years.
  • 2007 1213 - Letter - ACLI to RAND - Re: Submission of Life Insurance Industry Views on RAND Study - 7p
    • The Relationship Between Investment Advice and “Incidental” Activities
  • 2008 0919 - Letter - ACLI to SEC - re: Proposed Rule 151A and Proposed Rule 12h-7 - s71408 - 112p
  • 2008 1006 - Letter - ACLI to DOL - ERISA - 9p
  • SEC - REG BI - 
    • Year-? - ACLI - Analysis of ACLI Board Principles Against the SEC Best Interest Standard of Care Proposals - 5p
    • 2007 1213 - Letter - ACLI - Submission in response to the RAND Study on Broker Dealer and Investment Advisory Issues - 13p
    • 2010 0830 - Letter - ACLI to SEC - Submission in response to the SEC’s request for information on its Study on the Responsibilities of Brokers, Dealers, and Investment Advisers in fulfillment of Section 913 of the Dodd-Frank Act
    • 2013 0705 - Letter - ACLI to SEC - Submission in response to the SEC’s Request for Data and Information on Brokers, Dealers and Investment Advisers - 172p
    • 2017 1003 - Letter - ACLI to SEC - Submission in response to SEC Chairman’s Request for Information on Standards of Conduct for Investment Advisers and Broker-Dealers - 90p
    • 2019 0924 - Seminar - ACLI to ALIC - Association of Life Insurance Counsel - Regional Meeting, Carl B. Wilkerson  - 14p

 2010s

  • 2011 0913 - Testimony - ACLI to GOV (House) - Ensuring Appropriate Regulatory Oversight of Broker-Dealers and Legislative Proposals to Improve Investment Adviser Oversight - 29p
    • House - Financial Services Committee Subcommittee on Capital Markets and Government Sponsored Enterprises
  • 2011 0926 - Letter- ACLI to SEC-CFTC - Submission on SEC-CFTC Stable Value Contract Study - 7p
  • 2012 02 - Report - ACLI - VM-20 Impact Study Compendium, prepared by Milliman - 148p
  • 2012 0323 - Letter - ACLI to SEC - re: Dodd-Frank Act Study on Financial Literacy among Investors - 150p
    • The following guidelines were developed by Brenda J. Cude, Ph.D., Professor of Housing and Consumer Economics, at the University of Georgia.
      • Dr. Cude is an expert on consumer protection and behavior whose interests focus on how consumers acquire and use information before making buying decisions.
      • She represents the consumer perspective in policy discussions at national meetings of insurance regulators.
  • 2012 0724 - Testimony - ACLI - 2012 0724 - GOV (House - Financial Services) - The Impact of Dodd-Frank's Insurance Regulations on Consumers, Job Creators, and the Economy - [PDF-110p , VIDEO-?] - 3p
  • 2013 0705 - Letter - ACLI to SEC - re Request for Information on the Duties of Brokers, Dealers, and Investment Advisers (Release No. 34-69013; IA - 3558; File No. 4-606) - 172p
  • 2013 0917- ThinkAdvisor - ACLI calls Lawsky's letter on reserves 'irresponsible', By Elizabeth D. Festa - [link]
    • In a letter to state insurance commissioners, the American Council of Life Insurers (ACLI) called the top New York insurance regulator’s remarks on life insurance reserving “irresponsible” and inaccurate, the former because they erode trust in the state regulatory system and the industry and the latter for actuarial reasons.
    •  Actuarial Guideline 38 (AG 38)
    • Lawsky Letter - Bad Link - https://www.dfs.ny.gov/about/press2013/pr1309111-link.pdf - <WishList>
    • ACLI Letter - <WishList>
  • 2015 1120 - (LIAC) - Life Insurance and Annuities (A) Committee National Harbor, Maryland - (6-3)
    • the Committee set a 30-day public comment period to receive comments from stakeholders on their issues and concerns with life insurance illustrations and the Life Insurance Illustrations Model Regulation (#582). In response, she said the Committee received comments from:
      • ACLI - American Council of Life Insurers - 2p
  • 2017 0313 - NAIC LIIIWG - Conference Call
    • 3-6-17 ACLI Letter
  • 2017 0713 - GOV (House) - Impact of the DOL Fiduciary Rule on the Capital Markets, Bill Huizenga (R-MI)
  • 2017 1003 - Letter - ACLI to SEC - Re: SEC Chairman’s Request for Information on Standards of Conduct for Investment Advisers and Broker-Dealers - 90p
  • 2017 1115 - Letter - ACLI to NAIC (LIBGWG-Life Insurance Buyer's Guide), Redlined Draft - 12p
    • Unlike a term policy, which can end after a specified number of years, permanent life insurance will continue to the policy’s maturity age so long as premiums are paid.
      • (Note that this isn’t exactly accurate for UL, where policies can continue as long as the cash value is sufficient to pay the policy charges. We may want to make that distinction. )  ---  [Bonk: ACLI Wording and Strikethrough]
    • [Bonk: Without Strikethrough]
      • (Note that this isn’t exactly accurate for UL, where policies can continue as long as the cash value is sufficient to pay the policy charges. We may want to make that distinction.)
  • 2018 - ACLI Annual Conference - Seizing Opportunities - 39p
  • 2018 0223 - Letter - ACLI to FSB - 5p
    •  (p4) - In the U.S., many states have laws that permit insurers to offset a portion of their future premium, income and/or franchise tax liabilities by the amount of the guaranty association assessments they have paid (e.g., 20% over 5 years).
      • This, in turn, reduces the tax bases of those states. 
  • 2018 0803 - Letter - ACLI to SEC - Re: Proposed Regulation Best Interest (“Reg. BI”) - 85p
  • 2019 1115 - NAIC LIIIWG -
    • Letter - ACLI to NAIC - RE: Revisions Considered for Life Insurance Policy & Narrative Summaries - 8p

2020s

  • 2020 0204 - ACLI - Life Insurance Protections Most People Don’t Know About, by Bruce Ferguson - [link]
  • ACLI Uniform Standard of Care
  • 2021?? Proceedings - Wicka Report - Should we move on?
    • 2021 0805 - Letter - ACLI to NAIC (LIAC) - RE: Life Insurance Illustrations Issues (A) Working Group - 3p
  • 2022 0204 - ACLI to NAIC (IULSG) - RE IUL Exposure - 4p
    • ACLI is committed to working with regulators to develop appropriate requirements that allow consumers to understand the value and risks of the policies they purchase.
    • If the level of illustrated values resulting from current practices for volatility-controlled funds and similar features is deemed reasonable, a disclosure-only approach that could apply to all new inforce illustrations issued since the effective date of AG 49-A. may provide better education to consumers about the risks associated with these features.
      • If regulators believe the level of the illustrated values is unreasonable, we would ask regulators to provide clear objectives for a revised guideline so industry can work with regulators to address their concerns.
  • 2022 0428 - Letter - ACLI / NAIFA  to NAIC (NAIC’s Producer Licensing (D) Task Force (PLTF) - 11p
  • 2022 0906 - Letter - ACLI to NAIC (IULSG) - Re: Exposed IUL Questions - 1p
    • With regard to the proposal “to address any broader issues with life illustrations,” ACLI believes that there should be a thorough analysis and evaluation process that is used to identify the underlying issues and drive the solutions, which may or may not include opening Model #582.
  • 2022 1102 - Letter - ACLI to NAIC (IULSG) - Actuarial Guideline ILVA, Annuity, Nonforfeiture - 5p
  • 2022 1201 - Letter - ACLI to NAIC (Macroprudential Surveillance) - 2p
    • The life insurance industry is currently facing significant headwinds, as the U.S. economy is entering a significant time of uncertainty and we are in the process of experiencing a severe interest rate spike situation.
    • We understand that regulators will want to re-examine the current interest rate spike scenario (which is based on historical experience from the 1970/80s) and refine the scenario based on current experiences. 
  • 2023 05 - Report - ACLI - Survey - Poll - Retirement Planning - 36p
  • 2023 1204 - Letter - ACLI to NASAA - Re: Proposed Revisions to NASAA’s Dishonest or Unethical Business Practices of Broker-Dealers and Agents Model Rule, North American Securities Administrators Association - 9p
    • The Report and Proposal do not adequately detail market failures from the current regulations applicable to the sale of variable insurance products necessitating a new model proposal additive to Reg BI principles.