Froogled By:: Elias Makere, FSA, MAAA
Last Updated:: 8/17/2025

ASOP 1
(INTRODUCTORY ACTUARIAL STANDARD OF PRACTICE)
COMMENTS & RESPONSES ON SECTION 1 OF THE EXPOSURE DRAFT

Comments & Responses on Section 1 of the Exposure Draft

ASOP 1 | Commentary Section | INTRO TO THE ASOP COMMENTARY

The exposure draft of the Introductory ASOP was issued in December 2011 with a comment deadline of May 31, 2012. Thirteen comment letters were received, some of which were submitted on behalf of multiple commentators, such as by firms or committees. For purposes of this appendix, the term “commentator” may refer to more than one person associated with a particular comment letter. The General Committee of the Actuarial Standards Board carefully considered all comments received, and the ASB reviewed (and modified, where appropriate) the changes proposed by the General Committee.

Summarized below are the significant issues and questions contained in the comment letters and the responses.

The term “reviewers” in appendix 2 includes the General Committee and the ASB. Also, unless otherwise noted, the section numbers and titles used in appendix 2 refer to those in the exposure draft.

GENERAL COMMENTS

Comment	Response
A number of commentators indicated that the Introductory ASOP needs a number (for example, ASOP No. 0 or ASOP No. 1) so that actuaries understand that it is an ASOP that contains guidance.	The reviewers agree and numbered the Introductory ASOP as ASOP No. 1. The previous ASOP No. 1, Nonguaranteed Charges or Benefits for Life Insurance Policies and Annuity Contracts, has been renumbered as No. 2, since ASOP No. 2, Recommendations for Actuarial Communications Related to Statements of Financial Accounting Standards Nos. 87 and 88, was repealed in March 2011.
One commentator suggested moving the general deviation language from ASOP No. 41, Actuarial Communications, to the Introductory ASOP, and having ASOP No. 41 deal only with deviations related to communication of results.	The reviewers believe ASOP No. 41 is an appropriate vehicle for guidance on communicating deviation from any ASOP, because ASOP No. 41 applies to actuaries issuing actuarial communications within any practice area. As a result, no change was made.

ASOP 1 | Commentary Section | COMMENT ON SECTION 1.1

Comment	Response
Some commentators believed that the sentence “Each of these organizations requires its members, through its Code of Professional Conduct⁴ (Code), to observe ASOPs when rendering actuarial services in the United States,” contradicts the Code because it is incomplete (i.e. the sentence doesn’t mention that actuaries must also under the Code satisfy standards of practice in a non-U.S. jurisdiction where they render services).	The reviewers disagree and made no change. The reviewers believe the statement is accurate as written, and is not inaccurate merely because it does not also describe Code requirements that relate to actuarial standards of practice that exist in other jurisdictions in which the actuary may render actuarial services.
One commentator suggested revising the sentence “Each of these organizations requires its members, through its Code⁵, to observe ASOPs when rendering actuarial services in the United States,” to match the wording in the Code by replacing “observe” with “satisfy applicable.”	The reviewers made the suggested change but note that the Code uses both terms in the discussion of this topic.
One commentator indicated that the sentence “The ASOPs provide a basic framework that will typically accommodate these additional considerations.” should be revised to read “The ASOPs provide a basic framework that should accommodate these additional considerations.”	The reviewers agree and made the following change: “The ASOPs provide a basic framework that is intended to accommodate these additional considerations.”

Comment

Response

Some commentators believed that the sentence

“Each of these organizations requires its members, through its Code of Professional Conduct⁴ (Code), to observe ASOPs when rendering actuarial services in the United States,”

contradicts the Code because it is incomplete (i.e. the sentence doesn’t mention that actuaries must also under the Code satisfy standards of practice in a non-U.S. jurisdiction where they render services).

The reviewers disagree and made no change.

The reviewers believe the statement is accurate as written, and is not inaccurate merely because it does not also describe Code requirements that relate to actuarial standards of practice that exist in other jurisdictions in which the actuary may render actuarial services.

One commentator suggested revising the sentence

“Each of these organizations requires its members, through its Code⁵, to observe ASOPs when rendering actuarial services in the United States,”

to match the wording in the Code by replacing “observe” with “satisfy applicable.”

The reviewers made the suggested change but note that the Code uses both terms in the discussion of this topic.

One commentator indicated that the sentence

“The ASOPs provide a basic framework that will typically accommodate these additional considerations.”

should be revised to read

“The ASOPs provide a basic framework that should accommodate these additional considerations.”

The reviewers agree and made the following change:

“The ASOPs provide a basic framework that is intended to accommodate these additional considerations.”

Notes

⁴ These organizations adopted the Code of Professional Conduct effective January 1, 2001.

⁵ These organizations adopted the Code of Professional Conduct effective January 1, 2001.

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