Industry Updates

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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