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.Back to All Industry Updates