From: Gozzo Andrews, Susan [mailto:
Sent: Monday, September 18, 2017 7:05 PM
To: Lederer, Julie <
Subject: Proposed Revisions to Regulatory Guidance Draft

Julie:

We would all like to thank you for all the tremendous effort you put it on reworking the Regulatory Guidance.

I would like to propose some minor changes to assist in readability and completeness. What I’ve done is accepted Julies changes in the version that was sent out on 9_5_17, and then I started a Tracked changes version from that.

I added words to spell out that Regulatory Guidance is not binding in the Intro.

I’d like to split out the Actuarial Report section as it’s a lot of information and would be easier to quickly find in the new RG. While it could also be discussed what order we’d like it to go as Opinion, AOS, Report may seem more logical to some, right now the Opinion Instructions include the Report as well so that’s why I left the Report part next with AOS last.

I added some words about the UPR tests in SSAP65.

LTC – I added minor changes to the Item 13 disclosure. For the LTC paragraph, I understand that discussion is on-going with ILL inthe lead. CT would like to keep the LTC part in as a suggestion for 2017, but say anticipate that we will make changes for 2018 Instructions. CT would like to encourage that a separate opinion by an actuary qualified to opine on LTC be attached to the Actuarial Opinion and that Appointed Actuary make the necessary references in the Opinion. This would be consistent with how other life insurers handle similar situations. My life actuaries tell me there is a difference with the LTC reserves needing to follow the formulas, whereas the asset adequacy for the LTC block would be done by either the Gross Premium Valuation Method or Cash Flow testing which is discussed in AG LI. In any case the reserves and asset adequacy are different and we need to be careful with the wording. My proposed wording has passed muster with our life actuaries.

I made some revisions to the Data Reconciliation primarily to add words about the Data Attribute Testing that needs to be done with the Appointed Actuary’s involvement. I made a separate part to this under the Schedule P. In so doing I noted that the COPLFR practice note in 2016 didn’t include the Attachment with Frequently Asked Questions which is pretty important. I contacted COPLFR so hoping they can fix this for the 2017 Practice Note.

Finally, I’ve made some minor changes in wording for the group to consider throughout the document.

Page Breaks- These can only be deleted outside of Tracked Changes mode.

I would propose this document be sent out to the group for review, and I would be happy to walk through the proposed changes on our next call.

Again, thank you Julie and we all look forward to bringing this forward for completion for this year.

Best regards,

Sue Gozzo Andrews