ASOP 1
(INTRODUCTORY ACTUARIAL STANDARD OF PRACTICE)
SECTION to Section 3
COMMENTS & RESPONSES ON SECTION 3 OF THE EXPOSURE DRAFT

Comments & Responses on Section 3 of the Exposure Draft

ASOP 1 | Commentary Section | GENERAL COMMENT ON SECTION 3

Comment	Response
A commentator indicated that the placement of this section within the body of the Introductory ASOP is inconsistent with the Introductory ASOP itself being an ASOP, because there is nothing in this section that an actuary must understand or do. The commentator suggested moving this section to the appendix or another document.	The reviewers note that the Introductory ASOP is unique and can have a different structure from the other ASOPs. The reviewers decided to leave this within the body of the Introductory ASOP to ensure it received appropriate visibility.

ASOP 1 | Commentary Section | COMMENT ON SECTION 3.1

Section 3.1.2

Comment	Response
A commentator believed the term “production in litigation” should have been “results in litigation” in the sentence “ASOPs are not intended to shift the burden of proof or production in litigation, and failure to satisfy one or more provisions of an ASOP should not, in and of itself, be presumed to be malpractice.”	The reviewers changed the wording to clarify that a deviation from a standard should not result in the presumption of malpractice.
A commentator believed that the sentence “Other individuals should consider obtaining the advice of a qualified actuary before making use of, or otherwise relying upon, ASOPs” should be replaced with “ASOPs should not be used or relied upon by those who are not actuaries.”	The reviewers disagree and made no change.

Section 3.1.4

Comment	Response
A commentator wanted to add “generally” before “not narrowly prescriptive,” and “typically” before “neither dictate” in the following sentence “The ASOPs are not narrowly prescriptive and neither dictate a single approach nor mandate a particular outcome.” Another commentator noted that some sections of ASOPs are prescriptive.	The reviewers agree that adding “generally” to the sentence is appropriate and made the change but do not believe the addition of “typically” would enhance the understanding.
A commentator suggested that the sentence “For example, because actuarial practice commonly involves the measurement of uncertain events, there will often be a range of reasonable assumptions, and two actuaries could follow a particular ASOP, both using reasonable methods and assumptions, and reach different but reasonable results” be moved into the discussion of reasonable.	The reviewers agree and moved the sentence (with minor wording changes).

Section 3.1.5

Comment	Response
A commentator thought that this point (that an actuary may deviate from an ASOP to comply with applicable statutes, regulations or other binding authority) was better explained in other ASOPs and that the language should be modified.	The reviewers believe the language is clear and consistent with the Code, and therefore made no change.

Section 3.1.6

Comment	Response
A commentator suggested that the word “might” be changed to “may” in the sentence “Unlike the ASOPs, which are binding upon actuaries, other actuarial literature provides information that an actuary might choose, but is not required, to consider when rendering actuarial services.”	The reviewers agree and made the change.

Section 3.1.7

Comment	Response
A commentator suggested this section be revised to indicate that early adoption of the revised Introductory ASOP is permitted.	The reviewers believe that there is nothing in this revised Introductory ASOP that would result in noncompliance with the current Introduction to the ASOPs. Therefore, no change was made.