In April 2019, the Principle-Based Reserve Review Procedures Work Group (the Work Group) issued an exposure of a Practice Note entitled “Common Practices of Examining Actuaries Involved in Statutory Financial Solvency Examinations of Life and Health Insurers Including Considerations for Principle-Based Reserves” (the Practice Note). The Work Group requested comments on the exposed Practice Note.
RRC appreciates the opportunity to offer our comments. We have a set of general comments that apply broadly to many sections of the Practice Note, as well as specific comments on certain sections. Should you have any questions, we would be glad to discuss our comments with you and the Work Group members.

General Comments

1. Providing guidance to actuaries on typical practices in risk-focused examinations (RFE) is helpful, and RRC appreciates the efforts of the Work Group. We believe that a Practice Note in this area will be helpful both to actuaries conducting such examinations and to actuaries at companies undergoing examination, as it provides education on the RFE process. It may also be helpful to non-actuaries, such as examiners and company representatives that are coordinating examination efforts, to gain an understanding of the typical work performed by examining actuaries.