Froogle | ASOP 2 | Commentary 1.2

Section 1.2, Scope
Comment	Response
One commentator suggested adding language to clarify that the ASOP is not retroactively applicable to prior determinations before the effective date of the ASOP.	The reviewers clarified the language.
One commentator suggested moving the sentence “Throughout this standard, the term determination includes both initial determination and subsequent redeterminations” to section 1.1.	The reviewers disagree and made no change in response to this comment.
One commentator suggested adding “to the extent possible” when referring to future determinations of in-force products after the effective date to provide sufficient flexibility.	The reviewers believe the guidance is appropriate and made no change in response to this comment.
One commentator noted that ASOP No. 15, Dividends for Individual Participating Life Insurance, Annuities, and Disability Insurance, does not appear to define “dividend” and suggested adding a definition to ASOP No. 2.	The reviewers disagree with the suggestion and made no change in response to this comment. The reviewers note that section 2.4 states “For the purpose of this ASOP, an NGE reflects expectations of future experience as opposed to, for example, a dividend, which reflects participation in past experience.”

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