ASOP 1
(INTRODUCTORY ACTUARIAL STANDARD OF PRACTICE)
SECTION to Section 4
COMMENTS & RESPONSES ON SECTION 4 OF THE EXPOSURE DRAFT

Comments & Responses on Section 4 of the Exposure Draft

ASOP 1 | Commentary Section | COMMENT ON SECTION 4.1

Comment	Response
A commentator found this confusing, saying that you can deviate from an ASOP if you disclose the deviation, so failure to comply with an ASOP is not a breach of the Code. Another commentator suggested adding information to further clarify that deviations, with appropriate disclosures, are permitted.	The reviewers note that the deviation from the guidance in an ASOP and disclosing the deviation is not a failure to comply with the ASOP, as discussed in section 4.5. Accordingly, no substantive changes were made in response to these comments, although the second sentence in this section was simplified.
Some commentators believe this section belongs in the appendix, not the body of the ASOP, because it doesn’t tell the actuary to do anything.	Failure to comply with the ASOPs results in a breach of the Code. The reviewers believe this is an important point that belongs in the body of the Introductory ASOP. Therefore, no change was made.
A commentator suggested adding “may” before “subject the actuary” in the sentence “Such breaches subject the actuary to the profession’s counseling and discipline processes.”	The reviewers note that a breach subjects the actuary to ABCD processes, even though it may not result in ABCD action. Therefore, no changes were made.

ASOP 1 | Commentary Section | COMMENT ON SECTION 4.2

Comment	Response
A commentator believes that the sentence “It is not appropriate for users of ASOPs to make a strained interpretation of the provisions of an ASOP “ is not needed because the point is covered by the first sentence, and also indicated that an undefined term like “strained” should not be used.	The reviewers believe the second sentence differs from the first and decided against deleting it.

ASOP 1 | Commentary Section | COMMENT ON SECTION 4.3

Comment	Response
A commentator questioned whether the actuary has unfettered discretion to come to a conclusion about which ASOPs apply, even though the ASOPs may seem to suggest otherwise, and whether the actuary’s determination was open to challenge.	The reviewers do not agree that the section suggests that the actuary has unfettered discretion and, therefore, made no change.
A commentator suggested that the following sentence be deleted: “An ASOP should not be interpreted as having applicability beyond its stated scope and purpose” because the commentator believes it discourages an actuary from looking at ASOPs applicable to similar issues when there is no ASOP directly applicable, which the commentator believes to be a good practice that should not be discouraged.	The reviewers believe that clearly defined applicability is important and does not discourage other uses. Therefore, the sentence was not deleted.
A commentator suggested that the word “relevant” be replaced with “applicable” in the sentence “Actuaries should comply with those ASOPs that are relevant to the task at hand; not all ASOPs will apply.” because the Code doesn’t use the word “relevant,” it uses “applicable.”	The reviewers agree with replacing “relevant” with “applicable” and made that change.