Recent Comment Letters


Below are the comment letters submitted by the CRO Council over the past year in support of the Council's goals of developing and promoting leading practices in risk management throughout the insurance industry, and providing thought leadership and direction on the advancement of risk-based solvency and liquidity assessments. Comment letters represent the collective opinion of the Council at the time of submission, and may evolve over time as the market and environment develop.
Risk-based Global Insurance Capital Standard Version 1.0 for Extended Field Testing (Phase II)
January 11, 2018

Risk-based Global Insurance Capital Standard Version 1.0 for Extended Field Testing

July 31, 2017
American Academy of Actuaries Recommendation of Corporate Bond Risk-Based Capital (RBC) Factors
July 24, 2017
NAIC Enterprise Risk Report (Form F) Implementation Guide - February 13, 2017 Exposure Draft
March 20, 2017
Advanced Notice of Propose Rulemaking on Enhanced Cyber Risk Management Standards
January 17, 2017

Proposed 23 NYCRR 500 - Cybersecurity Requirements for Financial Services Companies

November 11, 2016

Advanced Notice of Proposed Rulemaking on Approaches to Regulatory Capital Standards for Supervised Insurers

 September 16, 2016