"The exposure draft defines 'model' broadly. Indeed, the last paragraph in the background section says: 'Actuaries generally agree that almost all actuarial work involves modeling of some type....' It is unclear why this ASOP is needed in situations involving straightforward calculations. For instance, in calculating a deterministic present value using a pension valuation system or even using pencil and paper, the actuary seems to be using a model, as defined. In situations such as these, the exposure draft does not seem to have any positive effect and might instead add cost and exposure to routine work. Therefore, we believe the definition of 'model' should be scaled back so that the ASOP only applies where it provides value."  MORE >>