| Comment | Response |
|---|---|
| One commentator suggested adding “the actuary should consider discussing these differences with management” in the last paragraph of section 3.4. | The reviewers added clarifying language to section 3.4. |
| One commentator questioned using the word “relationship” in (b) and (f). | The reviewers clarified the language in sections 3.4(b) and (f) in response to this comment. |
| One commentator suggested combining sections 3.2 and 3.4. | The reviewers disagree with combining sections 3.2 and 3.4 but clarified the language in section 3.4 to reference section 3.2 in its entirety. |
| One commentator suggested that sections 3.4(f), 3.2.2(c), and 3.2.1(e) are inconsistent. | The reviewers clarified the language in these sections to improve consistency. |
| Comment | Response |
|---|---|
| Two commentators suggested adding “if applicable” after “following.” | The reviewers disagree and made no change in response to this comment. |
| One commentator questioned whether the section works for rates based on the market or based on an index. | The reviewers added clarifying language to the definition of Nonguaranteed Element (NGE) in section 2.4 in response to this comment. |
| One commentator suggested that there is a bias in this section toward negative NGE changes and toward changes that are made infrequently, such as COI. | The reviewers disagree that the language is biased toward negative NGE changes. The reviewers added an example of a change that could be made more frequently. |
| Comment | Response |
|---|---|
| One commentator suggested (d) was redundant with (f) and suggested deleting (d). | The reviewers disagree and made no change. |
| Comment | Response |
|---|---|
| One commentator found the reference to section 3.4.2.4, which then refers to section 3.2, circular and confusing and suggested deleting (g). | The reviewers deleted the reference to section 3.4.2.4 and clarified the language in response to this comment. |
| Comment | Response |
|---|---|
| One commentator said that it is unclear whether the anticipated experience factors being referenced are those that were identified in the past, those that are currently experienced, or those that are expected in the future. | The reviewers believe the language of this section, as well as the definition of anticipated experience factor in section 2.1, is clear and made no change. |
| Comment | Response |
|---|---|
| One commentator suggested adding “may” in the second sentence of the first paragraph. | The reviewers agree and made the change. |
| Comment | Response |
|---|---|
| One commentator said that this section could be interpreted as saying that favorable past experience must be reflected in future anticipated experience factors and asked for clarification. | The reviewers disagree and made no change. |
| One commentator noted that experience can come from a variety of sources. | The reviewers added item (b) to the list of examples in section 3.1 in response to this comment. |
| One commentator said this section should not be limited to the determination of in-force policies. | The reviewers note section 3.4.1(a) addresses consideration of how experience factors were developed for future sales of a new or existing product and therefore made no change in response to this comment. |
Section 3.4.2.3, Considering Whether to Recommend a Revision to NGE Scales
| Comment | Response |
|---|---|
| One commentator suggested replacing “at issue” and “in force” with “determination” and “redetermination,” respectively. | The reviewers disagreed with the suggestion but clarified the use of the term “determination” in section 1.2 in response to this comment. |
| Comment | Response |
|---|---|
| One commentator suggested replacing “policyholder” with “policyholder behavior.” | The reviewers clarified the language. |
| Comment | Response |
|---|---|
| One commentator questioned whether the reference to section 3.2 in this section conflicts with the reference to section 3.2 in the last paragraph of section 3.4. | The reviewers clarified the language in the last paragraph of section 3.4. |
| One commentator suggested replacing “appropriate level of analysis” with language more similar to 3.4.2.3(g). | The reviewers believe the guidance is appropriate and made no change. |
| One commentator suggested combining sections 3.4.2.4 and 3.4.2.3. | The reviewers believe the guidance is appropriate and made no change. |
| Comment | Response |
|---|---|
| Two commentators suggested deleting section 3.4.2.4(a) because “the reference to ‘under the terms of the policy and applicable law’ makes this a legal question, not an actuarial one.” | The reviewers clarified the language. |
| Comment | Response |
|---|---|
| Two commentators suggested deleting the “prospective pattern of profits by duration” from the example because it was too prescriptive. | The reviewers clarified the language. |
| One commentator suggested deleting the entire example because this method may not be required by regulation. | The reviewers kept the example but clarified the language. |
| Comment | Response |
|---|---|
| One commentator suggested adding an example. | The reviewers added an example. |
