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Froogle 1.1.1.7
Froogled By:
Elias Makere, FSA, MAAA
Last Froogled:

ASOP 2 | §3.2 | COMMENT ON SECTION 3.2

Section 3.2, Providing Advice on the Actuarial Aspects of the Determination Policy
CommentResponse
One commentator suggested combining sections 3.2 and 3.4.The reviewers believe the guidance is appropriate and made no change.
Section 3.2(a)
CommentResponse
Several commentators suggested deleting or modifying sections 3.2(a), 3.4.1(c), and 3.4.2.4 because the language is too prescriptive and best left to regulation.The reviewers believe the guidance is appropriate and made no change in response to these comments.
Section 3.2(b)
CommentResponse
Several commentators expressed concern about the phrase “recouping past losses or distributing past gains” being too prescriptive or ambiguous and suggested either deleting that language or inserting “if required by statute or regulation” as a condition.The reviewers disagree but added clarifying language to section 3.4.2.5 to address this comment.
One commentator suggested adding back the guidance from the first exposure draft regarding prospective pattern of profits by duration in sections 3.2(b), 3.4.1(g), and 3.4.2.4(c).The reviewers believe the guidance is appropriate and therefore made no change.
Section 3.2.1, Providing Advice on Developing or Modifying the Determination Policy
CommentResponse
One commentator suggested replacing the list (a)-(f) with a reference to section 3.1.The reviewers clarified the language in section 3.1 and the definition of NGE framework in section 2.5, but made no change to this section in response to this comment.
Section 3.2.2, Providing Advice on Applying the Determination Policy
CommentResponse
One commentator suggested combining this section with section 3.2.1.The reviewers disagree and made no change.
Section 3.2.2(b)
CommentResponse
One commentator suggested coordinating the reference to options with language in ASOP No. 7, Analysis of Life, Health, or Property/Casualty Insurer Cash Flows, on materiality, likelihood of antiselection, and impact on profitability metrics (“cash flows”).The reviewers added clarifying language to section 3.2.2(b).
Section 3.2.2(d)
CommentResponse
One commentator stated that the reference to reinsurance may be misconstrued as a requirement for post-reinsurance pricing.The reviewers disagree and made no change.
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