Comment letter to NAIC on proposed changes to the Accounting Practices and Procedures Manual (May 18,

May 18, 2001Ms. Jane KipperSenior Life Insurance Accounting SpecialistNational Association of Insurance Commissioners2301 McGee Street, Suite 800Kansas City MO 64108Re: Attached Forms A and B of Proposed Changes to "Accounting Practices andProcedures Manual"Dear Ms. Kipper:This submission is being made by the American Academy of Actuaries' (Academy)Committee on Life Insurance Financial Reporting (COLIFR). I am the chairperson forCOLIFR.After the release of the first edition of the "Accounting Practices and Procedures Manual"(Manual), Mr. R. Thomas Herget (a member of the Academy) of PolySystems, Inc. helda series of focus group meetings regarding actuarial content in the Manual. Thesemeetings resulted in a list of 49 questions being submitted to Brady Kelly, FinancialServices Program Manager of the NAIC, on April 7, 2000. Since that time, it wasdecided that the questions should be submitted to the Academy for a more thoroughreview, with any resulting response to follow the formal process outlined by the NationalAssociation of Insurance Commissioners (NAIC) for proposed changes to the Manual.The Academy assigned this task to COLIFR. Mr. David Rockwell, a member ofCOLIFR, assumed responsibility for completing the research prior to the NAIC's summer2001 meetings. Attached to this letter is the result of COLIFR's efforts. We were able toreduce the original list of questions to 17 issues. These are summarized in the Appendix.There are 16 Form A ...