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|Academy of Actuaries Comments on NAIC Exposure Draft on Risk Corridors Collectability (PDF)|
American Academy of Actuaries
Nov. 2, 2015
"Some implications of the proposed guidance are not immediately clear to us, and we suggest that you might want address the following in the guidance:  If a company had previously recorded a 2014 risk corridor asset at less than the 37.8 percent level, are they now allowed under this guidance to recognize 2015 income by writing the asset up to 37.8 percent (and the non-admitting down to 12.6 percent)?  If a company had recorded a 2015 risk corridor asset in its second quarter financial statement, does it impair that asset, or non-admit it?"
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