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  #11  
Old 02-14-2018, 03:23 PM
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Originally Posted by Take 2 View Post
VM-30 is a prospective part of PBR. It is not a regulation or current requirement where PBR is not yet effective.

The AOM requirements are in a model reg, which has been the law in every state for many years.
That doesn't sound right.

From the Valuation Manual:

Quote:
III. ACTUARIAL OPINION AND REPORT REQUIREMENTS

Requirements regarding the annual actuarial opinion and memorandum pursuant to Section 3 of the NAIC Model Standard Valuation Law (VM-05) are provided in VM-30. The requirements in VM-30 are applicable to all annual statements with a year-ending date on or after the operative date of the Valuation Manual. Existing actuarial opinion and memorandum requirements continue to apply to all annual statements with a year-ending date before the operative date of the Valuation Manual.
And from the Background of the VM:

Quote:
The goals of the NAIC in developing the Valuation Manual are:
1. To consolidate into one document the minimum reserve requirements for life insurance, accident and health insurance, and deposit-type contracts pursuant to the SVL, including those products subject to principle-based valuation requirements and those not subject to principle-based valuation requirements.

...

5. To enhance industry compliance with the 2009 SVL and subsequent revisions, as adopted in various states.
While it is true that the minimum requirements for PBR is for business issued 1/1/2017 or later, VM-30 does not appear to differentiate between PBR or non-PBR business. Though, to be fair, Section 3 of the SVL (VM-05) is supposed to cover the Actuarial Opinion before and after the operative date of the manual, and currently, it's blank.

Finally, the differences between AOMR and VM-30 are not overly onerous, but there is a table of key indicators that is provided in the opinion that was not a part of AOMR that indicates whether you used the prescribed wording or not.

You could make the case that the AOMR is still in effect, but my understanding was that VM-30 was applicable for the AOM for 2017 onwards, regardless of whether you were doing PBR or not.
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Last edited by wat?; 02-14-2018 at 03:30 PM..
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  #12  
Old 02-15-2018, 02:14 PM
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VM-30 applies, but VM-05 is blank. So do we revert to the AOMR?

What about states that haven't authorized the VM, i.e., NY, AK, MA, DC?

Which leaves open the issue of what to do with AG38 and its effective dates.
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Old 02-15-2018, 03:30 PM
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VM-30 applies, but VM-05 is blank. So do we revert to the AOMR?
I think you'd be able to make the case that since VM-30 is substantially similar to the AOMR, that an opinion that satisfies AOMR should be in keeping with VM-30, except for the additional table and the slight change to the RAAIS. But if there are significant deviations from the prescribed wording, you might have to talk to your regulator/auditor/audience of the opinion about it.

Quote:
What about states that haven't authorized the VM, i.e., NY, AK, MA, DC?
Well, for NY, we know that they've been holding out on PBR because they wanted their own alternative. (Not sure if that's still the case.) There is a mention in the introduction that the VM applies in jurisdictions that have adopted the SVL or regulation that is substantially similar.

Quote:
Which leaves open the issue of what to do with AG38 and its effective dates.
I think OP's question was whether VM-30 applied to AG38, which I think it does, but maybe not in the way that OP thought.
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