ASOP 3
(CONTINUING CARE RETIREMENT COMMUNITIES AND AT HOME PROGRAMS)
Commentary to Section 2
(COMMENTS & RESPONSES ON SECTION 2 OF THE EXPOSURE DRAFT)

Commentary on Section 2

ASOP 3 | Commentary Section 2.4 | COMMENT ON SECTION 2.4

Section 2.4, Advance Fee

Comment	Response
One commentator felt the definition in section 2.4 departs from the terms that are commonly used for single-premium-life-annuity-type prepayments of fees that would otherwise be paid on a recurrent basis over the insured’s (“resident” or “member” in the terminology of the ASOP) lifetime.	The reviewers disagree and made no change in response to this comment.

ASOP 3 | Commentary Section 2.11 | COMMENT ON SECTION 2.11

Section 2.11, Health Center (now section 2.12)

Comment	Response
One commentator felt that the definition of “non-resident” (a term used in section 2.11) was confusing. Furthermore, the commentator felt clarity was needed regarding the difference between “residents” and “non-residents.”	The reviewers agree and modified the terms “resident” to “contractual resident” and “nonresident” to “non-contractual resident.”

ASOP 3 | Commentary Section 2.24 | COMMENT ON SECTION 2.24

Section 2.24, Residency Agreement (now section 2.26)

Comment	Response
One commentator felt the sentence in section 2.24 reading, “The contract is usually of long duration and may be for the life of each resident,” is at odds with the AICPA Guidance that CCRC contracts are month-to-month because the resident may cease paying.	The reviewers disagree and do not believe AICPA Guidance is relevant to this definition, and made no change in response to this comment.