Capital Adequacy Assessment
Third Exposure Draft
TO: Members of Actuarial Organizations Governed by the Standards of Practice of the Actuarial Standards Board and Other Persons Interested in Capital Adequacy Assessment
FROM: Actuarial Standards Board (ASB)
SUBJ: Proposed Actuarial Standard of Practice (ASOP), Capital Adequacy Assessment
This document contains the third exposure draft of a proposed ASOP, Capital Adequacy Assessment. Please review this exposure draft and give the ASB the benefit of your comments and suggestions. Each written comment letter or email received by the comment deadline will receive appropriate consideration by the drafting committee and the ASB.
The ASB accepts comments by either electronic or conventional mail. The preferred form is e-mail as it eases the task of grouping comments by section. However, please feel free to use either form. If you wish to use e-mail, please send a message to firstname.lastname@example.org. You may include your comments either in the body of the message or as an attachment prepared in any commonly used word processing format. Please do not embed your comments in the exposure draft and do not password-protect any attachments. If the attachment is in the form of a PDF, please do not “copy protect” the PDF. Include the phrase “ASB COMMENTS” in the subject line of your message. Please note: Any message not containing this exact phrase in the subject line will be deleted by our system’s spam filter. Also, please indicate in the body of the e-mail if your comments are being submitted on your own behalf or on behalf of a company or organization.
If you wish to use conventional mail, please send comments to the following address:
Capital Adequacy Assessment
Actuarial Standards Board
1850 M Street, NW, Suite 300
Washington, DC 20036
The ASB posts all signed comments received by the comment deadline to its website to encourage transparency and dialogue. Comments received after the deadline may not be considered. Anonymous comments will not be considered by the ASB nor posted to the website. Comments will be posted in the order that they are received. All posted comments will be available to the general public on the ASB website. The ASB disclaims any responsibility for the content of the comments, which are solely the responsibility of those who submit them.
For more information on the exposure process, please see the ASB Procedures Manual.
Deadline for receipt of responses in the ASB office: March 1, 2019
History of the Standard
When the ASB’s Enterprise Risk Management (ERM) Task Force (now Committee) started work on ASOP No. 46, Risk Evaluation in Enterprise Risk Management, and ASOP No. 47, Risk Treatment in Enterprise Risk Management, it was intended that those standards would, in addition to providing general guidance to actuaries performing ERM work, provide support as building blocks for a standard on actuarial opinions regarding the still-developing own risk and solvency assessment (ORSA) process.
Starting in 2012, insurance regulators began implementing the ORSA process throughout the world. Specifically, the ORSA process is a part of the Insurance Core Principles (ICP) set out by the International Association of Insurance Supervisors (IAIS) and is required by the NAIC accreditation standards. A key feature of ORSA is that it requires a formal assessment of capital adequacy be a part of an insurer’s ERM program. However, what is included in a capital adequacy assessment varies significantly across the industry. Given the disparity in current practices, the ASB determined that a separate ASOP covering capital adequacy assessments was needed to supplement ASOP Nos. 46 and 47.
In addition to satisfying regulatory requirements, risk-taking enterprises will, on occasion, want to assess their capital adequacy. The purpose of this proposed standard is to provide additional guidance to actuaries preparing an assessment of capital adequacy, whether for a specific regulatory requirement or for general management purposes.
First Exposure Draft
The ASB issued a first exposure draft of this ASOP in September 2016 with a comment deadline of January 31, 2017. Nine comment letters were received and considered in developing modifications that were reflected in the second exposure draft.
Second Exposure Draft
The ASB issued a second exposure draft in September 2017 with a comment deadline of March 1, 2018. Nine comment letters were received and considered in making changes that were reflected in this exposure draft. For a summary of the issues contained in these comment letters, please see appendix 2.
Notable Changes from the Second Exposure Draft
Changes made to the second exposure draft include the following:
1. The scope was modified as follows:
a. expanded the term “insurer” to include reinsurers and self-insurance plans;
b. clarified that groups that include at least one insurer are covered. As a result, several sections were modified to be consistent with this clarification;
c. excluded actuarial services within the scope of ASOP No. 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Program Periodic Costs or Actuarially Determined Contributions; and
d. clarified how reviewers of a capital adequacy assessment would satisfy the requirements of the ASOP.
2. A new section 3.1(k) was added under General Considerations.
3. Section 4.2 was expanded to include a new paragraph (b): “how the insurer’s risk management practices or processes, or the insurer’s risk profile, risk appetite, or risk tolerance were reflected in the assumptions or methodology underlying the capital adequacy assessment, if they were material to the capital adequacy assessment (see sections 3.2[a] and 3.2[b]).”
Request for Comments
The ASB appreciates comments and suggestions on all areas of this proposed standard. Rationale for any suggested changes would be helpful.
The ASB voted in November 2018 to approve this exposure draft.
|ERM Committee of the ASB|
|Frank D. Pierson, Chairperson|
|Anthony Dardis||Elisabetta Russo|
|Jamie B. Krieger||David K. Sandberg|
|David Paul||John W.C. Stark|
|Max J. Rudolph|
|Actuarial Standards Board|
|Beth E. Fitzgerald, Chairperson|
|Christopher S. Carlson||Darrell D. Knapp|
|Maryellen J. Coggins||Cande J. Olsen|
|Robert M. Damler||Kathleen A. Riley|
|Mita D. Drazilov||Barbara L. Snyder|
The Actuarial Standards Board (ASB) sets standards for appropriate actuarial practice
in the United States through the development and promulgation of Actuarial Standards of Practice (ASOPs). These ASOPs describe the procedures an actuary should follow when performing actuarial services and identify what the actuary should disclose when communicating the results of those services.
PROPOSED ACTUARIAL STANDARD OF PRACTICE
CAPITAL ADEQUACY ASSESSMENT
STANDARD OF PRACTICE
Section 1. Purpose, Scope, Cross References, and Effective Date
This actuarial standard of practice (ASOP) provides guidance to actuaries when performing professional services with respect to a review of the resiliency of an insurer through a capital adequacy assessment.
This standard applies to actuaries involved in capital adequacy assessment work for life or health insurers (including fraternal benefit societies and health benefit plans), property and casualty insurers, mortgage and title insurers, financial guaranty insurance companies, risk retention groups, public entity pools, captive insurers, and similar entities or a combination of such entities, when affiliated (collectively, referred to as “insurer”). The term insurer includes entities that insure or reinsure any entity mentioned in the preceding sentence. For the purposes of this standard, if an actuary is asked to assess the capital needed to support self-insured obligations of the types of insurance written by the businesses listed in the first sentence, the term “insurer” includes such self-insured obligations.
This standard does not apply to actuaries when providing actuarial services within the scope of ASOP No. 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Program Periodic Costs or Actuarially Determined Contributions.
This standard applies to actuaries designing, performing, or reviewing a capital adequacy assessment.
If the actuary’s actuarial services involve reviewing a capital adequacy assessment, the reviewing actuary should be reasonably satisfied that the capital adequacy assessment was performed in accordance with this standard. The reviewing actuary should use the guidance in this standard to the extent practicable within the scope of the actuary’s assignment.
When designing, performing, or reviewing a capital adequacy assessment of a group, the actuary need not assess the capital of individual members of the group unless warranted by the specific circumstances of the group.
If the actuary departs from the guidance set forth in this standard in order to comply with applicable law (statutes, regulations, and other legally binding authority), or for any other reason the actuary deems appropriate, the actuary should refer to section 4. If a conflict exists between this standard and applicable law, the actuary should comply with applicable law.
1.3 Cross References
When this standard refers to the provisions of other documents, the reference includes the referenced documents as they may be amended or restated in the future, and any successor to them, by whatever name called. If any amended or restated document differs materially from the originally referenced document, the actuary should consider the guidance in this standard to the extent it is applicable and appropriate.
1.4 Effective Date
This standard is effective for work commenced on or after four months after adoption by the Actuarial Standards Board.
Section 2. Definitions
The terms below are defined for use in this actuarial standard of practice and appear in bold throughout the ASOP.
2.1 Adverse Capital Event
A modeled or actual event that either a) causes capital to be significantly less than the risk capital target(s) or b) causes capital to be less than the risk capital threshold(s).
The excess of the value of assets over the value of liabilities, which depends on the valuation basis chosen.
2.3 Capital Adequacy Assessment
An assessment of capital of an insurer relative to its risk capital target(s) or risk capital threshold(s).
Affiliated group of individual organizations, of which at least one is an insurer.
2.5 Risk Appetite
The level of aggregate risk that an organization chooses to take in pursuit of its objectives.
2.6 Risk Capital Target
The preferred level of capital based on specified criteria, which is expressed as a function of a measure of risk. This can result in a single value or a range. There may be multiple risk capital targets based on different risk metrics at any one time. Any risk capital target is a function of, and aligned with, the insurer’s risk tolerance. This may include individual company, regulatory, and rating agency developed targets.
2.7 Risk Capital Threshold
The minimum level of capital necessary for an organization to operate effectively based on specified criteria and expressed as a function of a measure of risk. There may be multiple risk capital thresholds based on different risk metrics at any one time. Any risk capital threshold is a function of, and aligned with, the insurer’s risk tolerance. This may include individual company, regulatory, and rating agency developed thresholds or targets.
2.8 Risk Profile
The risks to which an organization is exposed over a specified period of time.
2.9 Risk Tolerance
The aggregate risk-taking capacity of an organization.
2.10 Valuation Basis
An accounting or economic framework for the recognition and measurement of assets and liabilities.
Section 3. Analysis of Issues and Recommended Practices
3.1 General Considerations
In designing, performing, or reviewing a capital adequacy assessment, the actuary should take into account the following:
a. the insurer’s risk profile and capital;
b. the business and risk drivers, including the legal, tax, regulatory, and economic environments in which the insurer operates, as well as any past and anticipated changes or trends in those drivers;
c. the insurer’s strategy and plans and the likelihood of their successful execution;
d. the timing and variability of projected liability-related and asset-related cash flows, including the marketability and availability of assets and other financial resources (commonly forms the basis of a liquidity analysis);
e. the timing and intensity of future calls on capital and the means and ability to replenish capital in a timely manner;
f. current or available resources, including those available from affiliated entities as well as the capabilities of the insurer and affiliated entities to use the available resources. Resources include capital, data, computing power and storage, and human resources;
g. the effect on capital adequacy of changes, or projected changes, in the risk profile;
h. correlation of risks and events, diversification benefits, and the uncertainty of the interdependence between risks;
i. projections of future economic conditions;
j. parameter uncertainty; and
k. the methodology used to assess the adequacy of capital consistent with the scope of the actuary’s assignment.
3.2 Additional General Considerations
In designing, performing, or reviewing a capital adequacy assessment, the actuary should consider the following:
a. the insurer’s definition of risk, the primary risk metric(s) used in the risk management system of the insurer, the risk identification process, the risks identified by the insurer, relevant management risk reports, and the limitations of the analytical tools and processes that will be used by the insurer to evaluate and quantify each risk;
b. the insurer’s risk appetite and risk tolerance, including any conflicts between the risk profile and the risk appetite and how the risk appetite and risk profile are expected to change over time;
c. inconsistencies between the capital adequacy assessment and information contained in publicly released reports the actuary considers relevant, such as annual statements and SEC filings, and the rationale for any inconsistencies;
d. prior capital adequacy assessments, including underlying assumptions;
e. if the insurer is part of a group, or the assessment is of a group:
1. access to capital from the entities in the group;
2. intra-group transactions, including, for example, dividends, reinsurance, and guarantees;
3. transfers of risks from the group to each individual organization, for example, reinsurance with aggregates or limits on a multi-company basis; and
4. transfers of risks from each organization to the group and the degree to which the group manages capital adequacy for each individual organization or primarily at the group level; and
f. management actions, including whether they can be executed in a timely manner (see section 3.7).
3.3 Valuation Bases Underlying a Capital Adequacy Assessment
When designing or reviewing a capital adequacy assessment, the actuary should review the selected valuation bases for assets and liabilities to determine whether they are consistent with and appropriate for the intended use of the capital adequacy assessment. When doing so, the actuary should consider the following:
a. criteria used by management for making risk and other financial decisions;
b. any differences between the selected valuation bases and any mandated (for example, by regulators, accountants, or others) valuation bases;
c. the time horizon(s) considered by management in decision-making;
d. the characteristics and implications of the selected valuation bases; and
e. any restrictions on assets or capital that are not otherwise reflected in the valuation bases.
3.4 Risk Capital Target or Risk Capital Threshold
When the actuary assists in the design of or the review of the appropriateness or applicability of risk capital target(s) or risk capital threshold(s), the actuary should take into account the following (on a historical, current, and prospective basis, as appropriate):
a. the valuation bases;
b. the principal’s objectives for capital (such as maintaining minimum ratios of regulatory or rating agency capital, insurer stability, acquisition plans, new business, or infrastructure investment) and reasons they could change;
c. normal and adverse environments;
d. the time horizon over which the capital is assessed;
e. the methods used to aggregate results, including diversification benefits and the uncertainty of the interdependence among the risks; and
f. alignment with any existing risk appetite and risk tolerance.
3.5 Additional Considerations Regarding Risk Capital Target or Risk Capital Threshold
When the actuary assists in the design of or the review of the appropriateness or applicability of risk capital target(s) or risk capital threshold(s), the actuary should consider the following:
a. the approach used to determine the “sufficient” level of capital (such as models based on factors, historical averages, and economic capital), as well as the uncertainty inherent in the approach;
b. the relative merits of using a range for the risk capital targets versus a single number;
c. whether the insurer will be able to access additional capital if and when needed, including the availability and sources of capital within the group;
d. the risk capital targets or risk capital thresholds that are in use within the group; and
e. the relationship of risk capital targets or risk capital thresholds established by management and external stakeholders (such as rating agencies and regulators), as well as regulatory capital requirements, to the current capital and risks of the insurer.
3.6 Scenario Tests and Stress Tests
When scenario tests and stress tests are included in a capital adequacy assessment, the actuary should follow applicable guidance for scenario testing and stress testing in ASOP No. 46, Risk Evaluation in Enterprise Risk Management, and ASOP No. 47, Risk Treatment in Enterprise Risk Management. In addition, the actuary should consider the following:
3.6.1 Types of Tests
One or more forms of scenario tests or stress tests such as the following:
a. Deterministic—Tests to challenge the insurer in specific ways based on its unique exposures. For example, emerging risks may be considered using deterministic stress tests;
b. Stochastic—Tests chosen from one or more sets of stochastically generated scenarios;
c. Combination—Tests where multiple events happen simultaneously or sequentially; and
d. Reverse—Reverse-engineered tests that create an adverse capital event.
3.6.2 Level of Adversity
Different levels of adversity such as the following:
a. periods of normal volatility;
b. plausible adverse conditions; and
c. extremely unlikely catastrophic events.
3.6.3 Sensitivity Testing
The actuary may use sensitivity testing as part of a capital adequacy assessment. For example, sensitivity testing can be used to determine the applicability of the results of the scenario tests and stress tests under changing conditions, including the passage of time, as well as testing the materiality or impact of different assumptions, including stochastic model assumptions.
3.7 Incorporating Management Actions
When management actions are incorporated into a capital adequacy assessment, the actuary should consider the following:
a. effectiveness and applicability of prior management actions, given changes between when such actions were taken and the projection period, for example:
1. the magnitude of the impact of the prior action compared with the impact needed in the projection;
2. the differences in risk environment, including differences in the insurer’s business and operations, and the legal and regulatory environment;
3. differences in the insurer’s enterprise risk management program and risk profile; and
4. differences in the insurer’s financial strength;
b. feedback from board members or management;
c. legal, regulatory, and execution timing requirements;
d. experience, if available, of other insurers and non-insurance firms who took similar actions; and
e. expected reactions of regulators and other stakeholders.
3.8 Insurers that Operate in Multiple Jurisdictions
When the actuary is designing, performing, or reviewing a capital adequacy assessment of an insurer that individually or as part of a group operates in more than one jurisdiction, the actuary should take into account the following factors:
a. different regulatory regimes that might apply to different parts of the insurer or different entities (including non-insurance organizations) of the group, including:
1. cooperation and existence or non-existence of memorandums of understanding between regulators;
2. differing requirements for capital, scenario and stress tests, and financial reporting structures;
3. expected regulatory changes in some jurisdictions;
4. differing amounts of regulatory oversight;
5. impact of rules, restrictions, and time-lags on capital availability;
6. differing definitions of “insurance company” and “regulated entity”;
7. differing valuation bases; and
b. variations in taxation and approaches to litigation in various regulatory regimes.
3.9 Additional Considerations Regarding Insurers that Are Part of a Group
When the actuary is designing, performing, or reviewing a capital adequacy assessment of an insurer that is part of a group, or the assessment is of a group, the actuary should consider the following, if applicable:
a. level of complexity and extent of information available across all entities in the group;
b. levels of autonomy in selecting capital strategies for individual organizations within the group; and
c. the impact of varying ownership interests, including the following:
1. ownership splits, particularly between customers and shareholders;
2. shares listed on multiple stock exchanges; and
3. ownership concentrations.
3.10 Reliance on Data or Other Information Supplied by Others
When relying on data or other information supplied by others, the actuary should refer to the following ASOPs for guidance: ASOP No. 23, Data Quality; ASOP No. 41, Actuarial Communications; and, if applicable, ASOP No. 38, Using Models Outside the Actuary’s Area of Expertise (Property and Casualty). When relying on projections or supporting analysis supplied by others, the actuary should disclose both the fact and the extent of such reliance. In addition, the actuary should refer to ASOP No. 23, deeming such projections or supporting analysis as data covered by ASOP No. 23.
The actuary should consider preparing and retaining documentation to support compliance with the requirements of section 3 and the disclosure requirements of section 4. The actuary should consider preparing such documentation in a form such that another actuary qualified in the same practice area could assess the reasonableness of the actuary’s work or could assume the assignment if necessary. The degree of such documentation should be based on the professional judgment of the actuary, and may vary with the complexity and purpose of the actuarial services. In addition, the actuary should refer to ASOP No. 41, Actuarial Communications, section 3.8, for guidance related to the retention of file material other than that which is to be disclosed under section 4.
Section 4. Communications and Disclosures
4.1 Required Disclosures in an Actuarial Report
When issuing an actuarial report under this standard, the actuary should refer to ASOP Nos. 23, 41, 46, 47, and, if applicable, 38. In addition, the actuary should disclose the following in such actuarial reports, if applicable:
a. the businesses (insurance or non-insurance) that are included or excluded (and reasons for exclusion) in the assessment;
b. the key current and future business and risk drivers, including the legal, regulatory, and economic environments in which the insurer operates (see section 3.1[b]);
c. the key elements of business and risk management strategies included in the capital adequacy assessment (see section 3.1[c]);
d. a discussion of the timing and variability of projected liability-related and asset-related cash flows, including the marketability and availability of assets and other financial resources (see section 3.1[d]);
e. a discussion of future calls on capital, and the insurer’s means and ability to replenish it (see section 3.1[e]);
f. the treatment of interdependence and diversification (see section 3.1[h]);
g. the basis for projections of future conditions (see section 3.1[i]);
h. a discussion of the sensitivity of any assumption used to gauge the materiality of alternative assumptions, including any sensitivity tests of the parameters used in stochastic models (see section 3.1[j]); and
i. the selected valuation bases for assets and liabilities, and why they are appropriate (see section 3.3).
4.2 Additional Disclosures in an Actuarial Report
The actuary should include the following disclosures, as applicable, in an actuarial report:
a. the extent to which information regarding prior sources of capital was reflected in the capital adequacy assessment, including any reasons for deviations from past trends in such sources and uses, if such information was available;
b. how the insurer’s risk management practices or processes, or the insurer’s risk profile, risk appetite, or risk tolerance were reflected in the assumptions or methodology underlying the capital adequacy assessment, if they were material to the capital adequacy assessment (see sections 3.2[a] and 3.2[b]);
c. any material differences between a prior capital adequacy assessment or relevant publicly available or internal reports and analyses and the assumptions underlying the capital adequacy assessment, if the actuary had access to such assessment or reports and analyses (see sections 3.2[c] and 3.2[d]);
d. whether the actuary has considered any capital adequacy assessments performed at the group level and how that information has been used, and describe how being part of the group is reflected in the capital adequacy assessment, if the insurer is a part of a group (see sections 3.2[e] and 3.9);
e. a description of specific management actions, their impact on the capital adequacy assessment, and whether the actions could be effectively implemented in a timely manner, if the capital adequacy assessment reflects such actions (see sections 3.2[f] and 3.7); and
f. the actuary’s role and the rationale underlying the design or the results of the actuary’s review if the actuary had a role in the design of or reviewed the risk capital targets or risk capital thresholds (see sections 3.4 and 3.5);
g. a summary of the tests, including the type and levels of adversity, and the results of the tests, if scenario or stress tests are part of the capital adequacy assessment (see section 3.6);
h. a description of how operating in the various jurisdictions is reflected in the capital adequacy assessment, if the insurer operates, either individually or as part of a group, in multiple jurisdictions (see section 3.8);
i. the disclosure in ASOP No. 41, section 4.2, if any material assumption or method was prescribed by applicable law;
j. the disclosure in ASOP No. 41, section 4.3, if the actuary states reliance on other sources and thereby disclaims responsibility for any material assumption or method selected by a party other than the actuary; and
k. the disclosure in ASOP No. 41, section 4.4, if, in the actuary’s professional judgment, the actuary has otherwise deviated materially from the guidance of this ASOP.
Background and Current Practices
Note: This appendix is provided for informational purposes and is not part of the standard of practice.
Enterprise risk management (ERM) has been the focus of the insurance industry, including insurers, regulators, and rating agencies, for some time. In response to this increased attention to ERM, the Actuarial Standards Board (ASB) created the ERM Task Force (now Committee), which developed ASOP No. 46, Risk Evaluation in Enterprise Risk Management, and ASOP No. 47, Risk Treatment in Enterprise Risk Management. These two ASOPs provide guidance to the actuary for overall ERM work.
Historically, most insurers did not undertake formal assessments of capital adequacy. Instead, they tended to use rules of thumb (for example, premium to surplus ratios) or relied on regulatory rules (for example, risk-based capital ratios) or rating agencies (for example, A. M. Best’s Capital Adequacy Ratio). Many companies also relied on stress tests or what-if analyses to assess capital levels. Insurance regulators designed deterministic stress tests that reflected potential experience beyond the range of an insurer’s normal operations. Over time, deterministic stress tests were developed for a wide variety of assumptions.
Starting in 2012, insurance regulators began implementing the own risk and solvency assessment (ORSA) process throughout the world. Specifically, the ORSA process is a part of the Insurance Core Principles (ICP 16) set out by the International Association of Insurance Supervisors (IAIS) and is required by the NAIC accreditation standards. A key feature of ORSA is that it requires a formal assessment of capital adequacy to be a part of an insurer’s ERM program.
Given the new ORSA requirements and the increasing demands from regulators, rating agencies, and other external stakeholders, insurers are under pressure to perform formal, more sophisticated capital adequacy assessments. These formal capital adequacy assessments typically involve considerations of complex contingencies in determining the impact of adverse experience on the insurer and its capital adequacy, making this a process that will usually involve actuaries in some or all of the assessment process.
Company practice in making these assessments varies significantly. Some companies have created their own stochastic models (or use commercially available software) that simulate underwriting results across all lines of business and geographies, as well as economic conditions and investment results. These models typically incorporate the insurer’s strategic plan and may include complicated feedback loops that reflect management’s responses, if any, to specific situations (for example, underwriting results, a recession, multiple catastrophic events, a pandemic). They may also include predictions of how regulators and rating agencies may react to changes in the financial condition of the insurer. Other models may analyze capital adequacy at very high levels of aggregation and have limited or no feedback loops (i.e., they analyze specific management actions one at a time).
Larger insurers may have whole departments focused on analyzing the global economy. For smaller insurers, this work may be tasked to a specific individual or may be outsourced to consultants. In many of these insurers, actuaries and non-actuaries are involved in these analyses and the building of the models.
Rating agencies and regulators are concerned with individual company and group-wide capital adequacy. Many insurers are part of complex, multi-national organizations (including insurers and non-insurers) that span many different accounting, financial, and regulatory regimes. The relationships among the members of a group and the differences among these regimes can have a significant impact on capital adequacy and the group’s ability to fulfill its promises to its customers. In most countries, ORSA requires groups operating in multiple countries to perform a group-wide assessment of their capital adequacy across all jurisdictions.
Comments on the Second Exposure Draft and Responses
The second exposure draft of this proposed ASOP, Capital Adequacy Assessment, was issued in September 2017 with a comment deadline of March 1, 2018. Nine comment letters were received, some of which were submitted on behalf of multiple commentators, such as by firms or committees. For purposes of this appendix, the term “commentator” may refer to more than one person associated with a particular comment letter. The Enterprise Risk Management Committee carefully considered all comments received, reviewed the second exposure draft, and proposed changes. The ASB reviewed the proposed changes and made modifications where appropriate.
Click here to view a summary of the significant issues and questions contained in the comment letters and responses.
The term “reviewers” in appendix 2 includes the Enterprise Risk Management Committee and the ASB. Also, unless otherwise noted, the section numbers and titles used in appendix 2 refer to those in the second exposure draft.
Comments on this Exposure Draft
Click here to view the comments on this exposure draft in their entirety.