Industry Updates

Life A Illustration Update

August 13, 2021

August 9, 2021

Commissioner Marlene Caride
Chair, Life Insurance and Annuities (A) Committee
National Association of Insurance Commissioners
Kansas City, Missouri

Re: Life Insurance Illustrations Issues Working Group

Dear Commissioner Caride:

This letter is submitted on behalf of the National Alliance of Life Companies (the NALC), an association of more than fifty (50) life and health insurers and associates with a focus on the concerns of small and mid-sized life and health insurers and their policyholders. Many of our members play a significant role in the sale of pre-need and final expense insurance to address the needs of American families. The NALC appreciates the opportunity to respond to the Life Insurance and Annuities (A) Committee’s (the A Committee) request for comments on two questions concerning the work of the Life Illustrations Working Group (the Working Group).

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Life Risk-Based Capital – Update

May 28, 2021

Mr. Philip Barlow
Chair, Life Risk-Based Capital E Working Group
National Association of Insurance Commissioners
Kansas City, Missouri

Re: Bond Factors and Companion Portfolio Adjustment Factors

Dear Mr. Barlow:

I am the Executive Director of the National Alliance of Life Companies (the NALC), a trade group of more than fifty life insurance companies and associates that represents the interests of small and mid-sized insurers and their policyholders.

As noted in our prior letter of April 8, 2021, a copy of which is attached, we have very significant concerns about the American Academy of Actuaries’ proposed changes in the bond factors and portfolio adjustment factors under consideration by the Working Group. This letter updates our earlier comments based upon our subsequent review of information provided in the Moody’s Analytics report, and after further discussions with representatives of small and mid-sized life insurers from across the United States.

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Life Risk-Based Capital

April 12, 2021

Mr. Philip Barlow
Chair, Life Risked Based Capital E Working Group
National Association of Insurance Commissioners
Kansas City, Missouri

Re: Bond Factors and Companion Portfolio Adjustment Formulas

Dear Mr. Barlow:

I am the Executive Director of the National Alliance of Life Companies (the NALC), a trade group of more than fifty (50) members and associates that represents the interests of small life insurance companies in the United States. We have closely followed the work of the American Academy of Actuaries regarding proposed changes in the bond factors and the portfolio adjustment factors (herein new bond factors) for investments held by life insurance companies. We have also read the preliminary report of Moody’s Analytics commissioned by the American Council of Life Insurers (the ACLI) on the impact of such changes.

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NALC Comment Letter, Independent Contractor Status Under Fair Labor Standards Act

February 24, 2021

Submitted via Regulation.gov

RE: (RIN) 1235-AA34, Delay of Effective Date – Independent Contractor Status Under the Fair Labor Standards Act

Dear Sir or Madam,

The National Alliance of Life Companies (NALC) appreciates the opportunity to comment on the proposal to delay the Department of Labor’s Wage and Hour Division’s (WHD) Independent Contractor Rule. NALC opposes the proposed delay and urges the department to move forward with the March 8, 2021, effective date.

As NALC wrote in comments supporting the rule last year, we are a national trade association of small and mid-sized life and health insurance companies from across the United States. NALC members primarily serve middle- and low-income communities who may not otherwise receive insurance coverage because these markets are not served by the larger industry. Our members are able to serve these markets because they can rely on a number of distribution models, including the use of licensed financial professionals who operate their own businesses as independent contractors.

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NALC Support Letter, Regulatory Information Number 1235-AA34

October 26, 2020

Ms. Amy DeBisschop
Sent via email to: DeBisschop.Amy@dol.gov

Re: Regulatory Information Number 1235-AA34
Support for Rulemaking Regarding Independent Contractor Status Under the Fair Labor Standards Act

Dear Director DeBisschop:

The National Alliance of Life Companies (NALC) appreciates the opportunity to submit this letter in support of the proposed rulemaking on independent contractor status under the Fair Labor Standards Act (FLSA). We specifically want to thank the Department for working to streamline, simplify and sharpen the test for determining whether a person is an employee or independent contractor. With more attention provided to worker classification in the policy and legal arenas, the proposed changes bring much-needed certainty to our industry and the consumers we serve.

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NALC Comment Letter, Draft UTPA Amended Language Addressing Rebating

July 15, 2020

Re: Draft UTPA Amended Language Addressing Rebating 

Dear Commissioner Godfread: 

I am writing on behalf of the members of the National Alliance of Life Companies (the NALC), an association of more than 50 life and health insurance companies and associate members. Our members focus on addressing the life insurance needs of middle income and working class Americans. We appreciate the opportunity to comment on the draft changes to the NAIC Model Unfair Trade Practices Act (#880) (referred to as the Model, or UTPA). 

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NALC Comment Letter, Funeral Rule

June 1, 2020

The NALC recently submitted a comment letter to the Federal Trade Commission (FTC) on Funeral Rule Requirements. The FTC asked for public comment on whether to make changes to the rule as part of the agency’s systemic review of all current rules and guides.

The Funeral Rule protects consumers from unfair and deceptive practices in the sale of funeral products and services. The rule requires funeral providers to give consumers price information up front, and give consumers the right to buy only the funeral goods and services they want and need from the provider.

The NALC is a trade group of small and mid-sized life and health insurers, and many members write pre-need and final expenses insurance. All but two states allow the sale of life insurance to fund pre-arrangement final expense contracts. The states that allow it have strict guidelines to protect consumers, as well as ensure services are delivered as promised.

The NALC believes that insurance funded pre-arrangement contracts play an important role in providing needed protections to many families. The combination of state and federal laws and regulations is working well to protect consumers, and there is no need for the FTC to institute additional laws or regulations within the Funeral Rule.

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An interview by Michael A. Molony, Esq., Young, Clement, Rivers, LLP with incoming NAIC President Ray Farmer in the FORC Journal

December 20, 2019

The South Carolina Director of Insurance will assume the role of President of the National Association of Insurance Commissioners (“NAIC”) on January 1, 2020. This is a significant achievement as it has been almost 20 years since the last time a South Carolina Director, Ernie Csiszar, was elevated to the post. It is an especially impressive achievement given the fact that South Carolina has very few large domestic insurers and is a testament to Director Farmer’s unique talents and capabilities.

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Harry Lee Waterfield II Recognized With Lifetime Achievement Award

September 23, 2019

Resolution of the National Alliance of Life Companies

Whereas, Harry Lee Waterfield II, has served the life insurance industry with great distinction during a career of over fifty (50) years; and

Whereas, his professional service includes growing Investors Heritage Life Insurance Company into a nationally prominent life insurance company located in Frankfort, Kentucky; and

Whereas, he served as Chairman of the Board of Directors, President and Chief Executive Officer of Investors Heritage until his recent retirement; and

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