ACLI to Government

1980s

  • (p34) - John H. Filer, Chairman of the Board, AETNA Life & Casualty:
    • Whole life insurance is not partially insurance and partially savings.
      • It is wholly insurance.
    • It is not designed to provide for the possibility of economic gain in return for a risked sum of money.
      • That's an investment.
    • Nor is it designed to accumulate deposits of money building toward an individual or family goal as the depositor remains alive to make the deposits.
      • That's a savings account.
    • It is designed to provide a guaranteed benefit at death, whenever death ocours, in return for a price which is expressed as a fixed periodic premium.
      • That is what it is, that is what it does.
  • (p131) - 1980 0130 - Letter - ACLI - American Council of Life Insurance to GOV (Senator Howard Cannon (D-NV)
    • DEAR SENATOR CANNON: Enclosed is a copy of the response of the American Council of Life Insurance to the comments by the Federal Trade Commission on the Council's testimony on the Commission's life insurance cost disclosure report which was issued on July 10, 1979.  Sincerely, Robert Bland Smith, Jr.
      • The staff of the Federal Trade Commission has chosen to respond to eight of the criticisms of the staff report made by representatives of the life insurance business at the October 17, 1979 hearing of the Senate Committee on Commerce, Science and Transportation. These responses merely repeat the erroneous ideas and conclusions that were set out at length in the FTC staff report.
      • We should like to offer a few comments pointing out what we see as flaws in the responses of the FTC staff in order to clarify some of the matters under dispute. Our comments will follow the same sequence used by the FTC staff.
        • l. The FTC staff report "adopts the flawed theory that whole life insurance is a hybrid combination of term insurance and a savings account."
          • Instead, "whole life is not partially insurance and partially savings. It is wholly insurance."

1979 0710 and 1017 - GOV (Senate) - FTC Study of Life Insurance Cost Disclosure, Howard Cannon (D-NV)   ---  [BonkNote] 

1979 07 - FTC - Report - Life Insurance Cost Disclosure, Federal Trade Commission  ---   [BonkNote]  ---  [PDF-460p]

2000s

  • 2001 0621 - GOV (House) - Insurance Product Approval: The Need for Modernization - [PDF-208p, VIDEO-?] - Speed to Market - House - Committee on Financial Services - Subcommittee on Capital Markets, Insurance, and Government Sponsored Enterprises
    • William B. Fisher, Vice President and Associate General Counsel, Massachusetts Mutual Life Insurance Company, On Behalf of the American Council of Life Insurers (ACLI)
      • In late 1999, the ACLI completed a comprehensive study of the current state of life insurance regulation, which identified speed to market as a highly pressing issue.
      • I have a copy of that report which I would like to submit for the record.
      • [The report referred to can be found on page 85 in the appendix.]  (p12)
  • 2002 - ACLI to GOV - Gasper, Joseph J., Statement of the American Council of Life Insurers Before The Subcommittee on Capital Markets, Insurance, and Government Sponsored Enterprises of the Committee on Financial Services of the United States House of Representatives on Insurance Regulation and Competition of the 21st Century Product and Financial Regulation, June 11. <Bad Link> - <http://financialserviceshouse_gov/media/pdf/061 102jg.pdf> - ?p
  • 2003 0313 - Letter - ACLI to DOL/EBSA - RFI - Automatic Rollovers - 1210-AA92/00014 - 5p 
  • 2008 1006 - Letter - ACLI to DOL/EBSA - ERISA - 1210-AB13-2/00034 - 9p
  • 2008 1113 - Letter - ACLI to SEC - File No. 4-573, SEC Mark-to-Market Accounting Study (MTM Study).  - 4p

2010s

  • 2010 0920 - ACLI to SEC - RFC - Re: Request for Comment on Core Definitions in Title Vll of the Dodd-Frank Act; Release No. 34- 62717; File No. S7-16-10 - 72p
  • 2011 0209 - ACLI to DOTT (Geithner) - Re: Supervision and Regulation of Certain Non-bank Financial Companies (p2-5) - 5p
  • 2011 0225 - ACLI to DOTT (Geithner) - re: response to notices of public rulemaking issued by the Financial Stability Oversight Council (FSOC)
  • 2011 1219 - ACLI to DOTT (Geithner) - re: response to notices of public rulemaking issued by the Financial Stability Oversight Council (FSOC). 
  • 2011 07 - ACLI to SEC - RFC - Re: File No. S7-16-11, Further Definition of "Swap," "Security-Based Swap," and "Security-Based Swap Agreement"; Mixed Swaps; Security-Based Swap Agreement Recordkeeping - 75p
  • 2011 0926 - ACLI to SEC - RFC - Re: File No. S7-32-11C, "Stable Value Contract Study" - 7p
  • 2013 1218 - Testimony - ACLI - GOV (Senate) - The Role of Social Security, Defined Benefits, and Private Retirement Accounts in the Face of the Retirement Crisis - 63p
    • Senate - Committee on Finance - Subcommittee on Social Security, Pensions, and Family Policy
  • 2014 0204 - ACLI to GOV - The Federal Insurance Office’s Report on Modernizing Insurance Regulation - 8p
  • 2015 0325 - GOV (Senate) - FSOC Accountability Nonbank Designations
    • (p78) - Prepared Statement of Gary E. Hughes - Executive Vice President and General Counsel, American Council of Life Insurers 
  • 2015 0708 - ACLI to GOV - The Role of the Financial Stability Board in the U.S. Framework, Dirk Kempthorne, President and CEO - 14p
  • 2015 0715 - Letter - ACLI to GOV-DOL/EBSA - Subject: Definition of the Term “Fiduciary”; Conflict of Interest Rule—Retirement Investment Advice (RIN 1210-AB32); Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Consultants, Insurance Companies and Investment Company Principal Underwriters (RIN 1210-ZA25); and Proposed Best Interest Contract Exemption (RIN 1210-ZA25) - 326p
  • 2015 0721 - Letter - ACLI to GOV-DOL/EBSA - Subject: Definition of the Term “Fiduciary”; Conflict of Interest Rule—Retirement Investment Advice (RIN1210-AB32);Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption(PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Consultants, Insurance Companies and Investment Company Principal Underwriters (RIN1210-ZA25); and
    Proposed Best Interest Contract Exemption (RIN 1210-ZA25) - 326p
  • 2016 0105 - ACLI to Connecticut - Re: Impacts of Recent USDOL Proposals on State-Run Retirement - 5p
  • 2017 0524 - ACLI to GOV-DOTT - re: comments on the April 21, 2017 Presidential Memorandum on the Financial Stability Council’s (FSOC) systemically significant determination and designation processes for non-bank financial companies - 6p
    • 2017 0421 - Memorandum on the Financial Stability Oversight Council - 3p
  • 2017 - ACLI to GOV-

2020s

  • 2020 0903 - ACLI to GOV-DOL/EBSA - Improving Investment Advice for Workers and Retirees - 3p 
  • 2022 0516 - ACLI to GOV-DOL/EBSA - Subject: Z-RIN 1210-ZA30 - Request for Information on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate-Related Financial Risk - 4p
  • 2024 0102 - ACLI to GOV-DOL/EBSA - Subjects: Retirement Security Rule: Definition of an Investment Advice Fiduciary (RIN 1210-AC02); Proposed Amendment to Prohibited Transaction Exemption PTE 84-24 (Application No. D-12060); Proposed Amendment to Prohibited Transaction Exemption PTE 2020-02 (Application No. D-12057) - 40p