Authored by: Tricia Matson
Published to: Actuarial Standards Board
RRC appreciates the opportunity to offer our comments. Should you have any questions, we would be glad to discuss our comments with you.
Overall, we agree with the revisions made to ASOP 22 and believe they will be helpful to actuaries as they prepare actuarial opinions based on asset adequacy analysis regarding life and health liabilities.
We suggest including an explicit requirement for the actuary to consider the impact of mortality improvement in the testing of annuities, and disclose the mortality improvement assumption, for consistency with the standards for pension actuaries. ASOP No. 35 requires that “the actuary should reflect the effect of mortality improvement both before and after the measurement date.” ASOP No. 35 also requires disclosure of the mortality improvement assumption and makes it clear that if appropriate to the measurement, an assumption of zero may be acceptable. This was an excellent enhancement to the pension standards and we see no reason why the same bar should not apply to life & annuity actuarial practice.