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Committee on Property and Liability Financial Reporting

This committee monitors activities regarding financial reporting related to property and liability risks, reviews proposals made by various organizations affecting the actuarial aspects of financial reporting and auditing issues related to property and liability risks, and evaluates property and liability insurance and self-insurance accounting issues.

Staff liaison: Robert Fischer

Chairperson: Michelle Iarkowski
Vice Chairperson: Jennifer Balester
Rebecca Armon
Amy Baranek
Rachel Dolsky
Mark Doucette
Dawn Fowle
Susan Gozzo Andrews
Lise Hasegawa
Aaron Hillebrandt
Mary Kannon
John Karwath
Jennifer Leach
Leslie Marlo
Tara Miller
Kazuko Minagawa Prock
Kayla Robertson
Trevar Withers
David Wolfe

Related Publications

COPLFR FAQs Document Addresses Wildfires Issues

A new document from the Committee on Property and Liability Financial Reporting (COPLFR) addresses issues raised by the recent Los Angeles wildfires. The Supplement to the 2024 COPLFR Practice Note—LA Wildfires offers a list of FAQs and associated responses for Appointed Actuaries’ consideration when providing statements of actuarial opinion for companies materially impacted by such events, whether directly or indirectly.

(February 07, 2025 )

Statements of Actuarial Opinion On Property and Casualty Loss Reserves (2024)

The Committee on Property and Liability Financial Reporting's practice note on Statements of Actuarial Opinion on P/C Loss Reserves (2024), including discussion regarding changes in the NAIC Annual Statement Instructions—Property/Casualty (NAIC Annual Statement Instructions) regarding the Actuarial Opinion, the Actuarial Opinion Summary, and Actuarial Report. (December 27, 2024)

(December 27, 2024 )

COPLFR Requests Clarification on 2024 Regulatory Guidance

The Committee on Property and Liability Financial Reporting (COPFLR) asked the NAIC's Actuarial Opinion Working Group for clarification on 2024 regulatory guidance pertaining to immaterial long-duration unearned premium reserves.

(July 29, 2024 )

Statements of Actuarial Opinion on P/C Loss Reserves (2023)

The Committee on Property and Liability Financial Reporting's practice note on Statements of Actuarial Opinion on P/C Loss Reserves (2023), including discussion regarding changes in the NAIC Annual Statement Instructions—Property/Casualty (NAIC Annual Statement Instructions) regarding the Actuarial Opinion, the Actuarial Opinion Summary, and Actuarial Report.

(December 14, 2023 )

CPC and COPLFR Report to CASTF

Academy Casualty Policy Analyst Rob Fischer presented to the NAIC’s Casualty Actuarial and Statistical (C) Task Force (CASTF) on behalf of Casualty Practice Council and Committee on Property and Liability Financial Reporting (COPLFR) on recent publications and future work products expected for release in December 2023 and early 2024.

(December 01, 2023 )

COPLFR Comments to ASB on ASOP No. 36

The Committee on Property and Liability Financial Reporting, submitted a comment letter to the Actuarial Standards Board (ASB) on the second exposure draft of ASOP no. 36, Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves.

(November 01, 2023 )

CPC, COPLFR Report to CASTF

Senior Casualty Fellow Rich Gibson presented to the NAIC’s Casualty Actuarial and Statistical (C) Task Force (CASTF) on behalf of the Casualty Practice Council (CPC) and Committee on Property and Liability Financial Reporting (COPLFR) on recent publications and future work products expected for release in 2023.

(August 12, 2023 )

COPLFR Comments to IRS on Micro-Captives

The Committee on Property Liability and Financial Reporting (COPLFR) submitted a comment letter to the Internal Revenue Service (IRS) on an exposure on Micro-Captive Listed Transactions and Micro-Captive Transactions of Interest.

(June 12, 2023 )

Letter to NAIC Casualty Actuarial and Statistical (C) Task Force

The Committee on Property Liability and Financial Reporting (COPLFR) submitted a comment letter to the National Association of Insurance Commissioners (NAIC) Casualty Actuarial and Statistical (C) Task Force proposing a modification to the Annual Statement blank that would eliminate the distinction between “short-tailed” and “long-tailed” lines of business in Schedule P.

(April 26, 2023 )

Comment Letter to NAIC Blanks (E) Working Group

The Committee on Property Liability and Financial Reporting (COPLFR) and the Health Practice Council’s Committee on Financial Reporting and Solvency submitted a comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed exposure to add instructions for the appointed actuary and qualified actuary contacts to the Jurat electronic only section in order to address any actuarial questions.

(April 26, 2023 )

CPC and COPLFR Report to CASTF

Casualty Practice Council (CPC) Vice Chairperson, Dee Dee Mays and Committee on Property and Liability Financial Reporting (COPLFR) Chairperson Stephen Koca presented to the NAIC’s Casualty Actuarial and Statistical (C) Task Force (CASTF) on behalf of the CPC and COPLFR on recent publications and future work products expected for release in 2023.

(March 22, 2023 )

Statements of Actuarial Opinion on P/C Loss Reserves (2022)

The Committee on Property and Liability Financial Reporting's practice note on Statements of Actuarial Opinion on P/C Loss Reserves (2022), including discussion regarding changes in the NAIC Annual Statement Instructions—Property/Casualty (NAIC Annual Statement Instructions) regarding the Actuarial Opinion, the Actuarial Opinion Summary, and Actuarial Report as well as COVID-19 considerations.

(December 20, 2022 )

Risk Transfer Practice Note

The Committee on Property and Liability Financial Reporting (COPLFR) released the update to the Risk Transfer Practice Note (last updated in 2007). The Risk Transfer Practice Note includes definitions and relationships between regulatory treatments of risk transfer, e.g., U.S. statutory, U.S. GAAP, IFRS 4 and IFRS 17, and Solvency II; the process for determination of risk transfer; current techniques used in practice for determining risk transfer; and risk transfer documentation.

(November 04, 2022 )

COPLFR Submits Comments to the ASB on ASOP 36

Comment letter from the Committee on Property and Liability Financial Reporting, submitted to the Actuarial Standards Board (ASB) on the exposure draft of ASOP 36, Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves.

(September 29, 2022 )

Statements of Actuarial Opinion on P/C Loss Reserves (2021)

The Committee on Property and Liability Financial Reporting's practice note on Statements of Actuarial Opinion on P/C Loss Reserves (2021), including discussion regarding changes in the NAIC Annual Statement Instructions—Property/Casualty (NAIC Annual Statement Instructions) regarding the Actuarial Opinion, the Actuarial Opinion Summary, and Actuarial Report as well as COVID-19 considerations.

(December 17, 2021 )

CPC and COPLFR Comments to CASTF

Casualty Practice Council Vice Chairperson, Dee Dee Mays, and Committee on Property and Liability Financial Reporting (COPLFR) Chairperson, Derek Freihaut, presented to the NAIC’s Casualty Actuarial and Statistical (C) Task Force on behalf of CPC and COPLFR on the recent publications and future work products expected for release in early 2022.

(December 07, 2021 )

COPLFR Updated Comment Letter to the NAIC Blanks (E) Working Group

The Committee on Property and Liability Financial Reporting (COPLFR) sent an updated version of its comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed changes to P/C annual statements. Many of the Committee’s previous comments stand unchanged but were edited in response to the modified exposure draft.

(October 21, 2021 )

COPLFR Comment Letter to the NAIC Casualty Actuarial and Statistical (C) Task Force

The Committee on Property and Liability Financial Reporting (COPLFR) sent a comment letter to the National Association of Insurance Commissioners (NAIC) Casualty Actuarial and Statistical (C) Task Force on proposed changes to P/C annual statements. The letter addresses such areas as definition of exposure, calendar date alignment, and existing alternative data sources.

(July 06, 2021 )

COPLFR Comment Letter to the NAIC Blanks (E) Working Group

The Committee on Property and Liability Financial Reporting (COPLFR) sent a comment letter to the National Association of Insurance Commissioners (NAIC) Blanks Working Group on proposed changes to P/C annual statements. The letter addresses such areas as definition of exposure, calendar date alignment, and existing alternative data sources.

(June 25, 2021 )

Statements of Actuarial Opinion on P/C Loss Reserves (2020)

The Committee on Property and Liability Financial Reporting's practice note on Statements of Actuarial Opinion on P/C Loss Reserves (2020), including discussion regarding changes in the NAIC Annual Statement Instructions—Property/Casualty (NAIC Annual Statement Instructions) regarding the Actuarial Opinion, the Actuarial Opinion Summary, and Actuarial Report as well as COVID-19 considerations.

(January 19, 2021 )

FAQs About COVID-19 and PC Financial Reporting

The Committee on Property and Liability Financial Reporting issued an updated and expanded set of questions and answers regarding the impact of the coronavirus pandemic on P/C financial reporting.

(January 13, 2021 )

Academy Updates CASTF on Casualty Practice Council Activity

The Academy’s Casualty Practice Council (CPC) and Committee on Property and Liability Financial Reporting (COPLFR) presented an update on CPC and COPLFR activity to the NAIC’s Casualty Actuarial and Statistical Task Force (CASTF), including pandemic risk insurance, workers’ compensation, automobile insurance, and cyber risk, and gave a preview of December’s Seminar on Effective P/C Loss Reserve Opinions.

(November 10, 2020 )

Audit Committees and Actuarial Loss Reserve Expertise

A new paper has been published, An Overview for P/C Insurers' Audit Committees: Effective Use of Actuarial Loss Reserve Expertise. Produced by the Committee on Property and Liabi8lity Financial Reporting, this document replaces an earlier paper on the same subject.

(September 21, 2020 )

Committee Comments on Financial Examiners Handbook

The Committee on Property and Liability Financial Reporting has submitted comments to the NAIC's Actuarial Opinion Working Group, suggesting some changes to the wording the Financial Examiners Handbook.

(August 27, 2020 )

Committee Issues FAQ on Covid-19 and PC Financial Reporting

The Committee on Property and Liability Financial Reporting has issued a set of questions and answers about the impact of the coronavirus pandemic on P/C financial reporting.

(June 11, 2020 )

COPLFR Comments on 2020 SAO PC Instructions

The Committee on Property and Liability Financial Reporting submitted comments to the National Association of Insurance Commissioners, regarding proposed instructions for the 2020 Statement of Actuarial Opinion for P&C companies.

(May 11, 2020 )

COPLFR Comments on Continuing Education Form

The Committee on Property and Casualty Liability Financial Reporting filed comments on the CAS/SOA proposed new form for P/C Appointed Actuaries to report their continuing education activities

(March 10, 2020 )

Committee Responds to Questions About Reporting Retroactive Reinsurance

The Committee on Property and Liability Financial Reporting sent a comment letter to the NAIC's Statutory Accounting Principles Working Group, continuing a dialogue about financial reporting of certain retroactive reinsurance transactions.

(February 28, 2020 )

Statements of Actuarial Opinion on P/C Loss Reserves (2019)

The Committee on Property and Liability Financial Reporting's practice note on Statements of Actuarial Opinion on P/C Loss Reserves (2019), including frequently asked questions about new requirements for Appointed Actuaries.

(January 07, 2020 )

COPLFR Letter to the NAIC’s Actuarial Opinion Working Group on Draft Regulatory Guidance, Revised Sept. 17, 2019

Committee on Property and Liability Financial Reporting letter to the NAIC’s Actuarial Opinion Working Group on Draft Regulatory Guidance (2 of 2).

(September 19, 2019 )

COPLFR Letter to the NAIC’s Actuarial Opinion Working Group on Draft Regulatory Guidance, Issued Aug. 30, 2019

Committee on Property and Liability Financial Reporting letter to the NAIC’s Actuarial Opinion Working Group on Draft Regulatory Guidance (1 of 2).

(September 19, 2019 )

Committee Comments on Reporting of Loss Portfolio Transfer

COPLFR comment letter to the NAIC regarding ambiguity in how companies should report retroactive reinsurance and other loss portfolio transfer matters.

(May 23, 2019 )

Statements of Actuarial Opinion on P/C Loss Reserves (2018)

Committee on Property and Liability Financial Reporting Statements of Actuarial Opinion on P/C Loss Reserves practice note. (January 15, 2019 )

Comments on Proposed California Workers' Compensation Regulation

Committee on Property and Liability Financial Reporting letter offering comments on the California Department of Insurance’s proposed changes to reporting requirements for large deductibles in workers’ compensation plans. (August 09, 2018 )

Retained Property Casualty Insurance-Related Risk: Interaction of Actuarial Analysis and Accounting

Committee on Property & Liability Financial Reporting practice note on retained risk.
(April 23, 2018 )

Results of Academy Survey Research Into Schedule P Reporting Practices

Exposure Draft: Retained Property Casualty Insurance-Related Risk

COPLFR practice note exposure draft on retained risk. Exposed for comment until March 30. (January 18, 2018 )

Statements of Actuarial Opinion on P/C Loss Reserves (2017)

Committee on Property and Liability Financial Reporting Statements of Actuarial Opinion on P/C Loss Reserves practice note.
(December 19, 2017 )

Comments on Life Insurance Valuation Manual Changes' Possible Impact on P/C Reporting

Committee on Property and Liability Financial Reporting comment letter to NAIC's Actuarial Opinion Working Group on the impact of life insurance Valuation Manual changes on P/C insurers' Statements of Actuarial Opinion that include accident and health (A&H) and long-term care (LTC) lines of business. (October 18, 2017 )

Committee Comments on Proposed New Definition of PC Reinsurance Risk Transfer

The Committee on Property and Liability Financial Reporting’s comment letter to the NAIC’s Statutory Accounting Working Group, questioning the proposed new definition of reinsurance risk transfer in SSAP No. 62R: Property and Casualty Reinsurance. (October 04, 2017 )

COPLFR Letter to NAIC Title Insurance Group

COPLFR's comment letter to the NAIC's Title Insurance Financial Reporting Working Group regarding proposed changes to reporting of reserves in the title statement of actuarial opinion (July 14, 2017 )

Statements of Actuarial Opinion on P/C Loss Reserves (2016)

Committee on Property and Liability Financial Reporting Statements of Actuarial Opinion on P/C Loss Reserves practice note. (December 27, 2016 )

CPC, COPLFR Comment Letter to ASB on Modeling ASOP

Casualty Practice Council (CPC) and Committee on Property and Liability Financial Reporting (COPFLR) letter to the Actuarial Standards Board commenting on the third exposure draft for the proposed Actuarial Standard of Practice (ASOP) on modeling. (October 14, 2016 )

Joint FRC/COPLFR Letter on SEC S-K Disclosure Requirement

Financial Reporting Committee (FRC) and Committee on Property and Liability Financial Reporting (COPLFR) comments to the SEC on its concept release on the modernization of certain disclosure requirements in Regulation S-K. (July 21, 2016 )

COPLFR Letter to NAIC on Inconsistencies in Loss Reserve Instructions for International Insurers

Comment letter from the Committee on Property and Liability Financial Reporting (COPLFR) to the NAIC noting inconsistencies in the instructions for certification of loss reserves for international insurers. (July 07, 2016 )

COPLFR Comments on Actuarial Opinion Instructions

Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC’s Actuarial Opinion (C) Working Group on the Actuarial Opinion Instructions. (February 12, 2016 )

COPLFR Comments on Fees Incurred for Salvage/Subrogation Recoveries

Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC’s Statutory Principles (E) Working Group on the proposed Clarification of Accounting Treatment for Fees Incurred for Salvage/Subrogation Recoveries. (February 03, 2016 )

COPLFR Comments on Workers’ Compensation Large Deductible Study

Committee on Property and Liability Financial Reporting (COPLFR) comments to the NAIC/IAIABC Joint (C) Working Group on the 2015 Workers’ Compensation Large Deductible Study draft. (January 19, 2016 )

Statements of Actuarial Opinion on P/C Loss Reserves (2015)

Committee on Property and Liability Financial Reporting Statements of Actuarial Opinion on P/C Loss Reserves practice note. (December 22, 2015 )

Academy Committees Comment on PCAOB Auditor and Specialist Paper

The Financial Reporting Committee, Pension Accounting Committee, Casualty Committee on Property and Liability Financial Reporting, Health Financial Reporting and Solvency Committee, and Life Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) “The Auditor's Use of the Work of Specialists” consultation paper. (July 15, 2015 )

Statements of Actuarial Opinion on P/C Loss Reserves (2014)

Committee on Property and Liability Financial Reporting 2014 Practice Note on Statements of Actuarial Opinion on P/C Loss Reserves. (December 30, 2014 )

COPLFR Overview for P/C Insurers' Audit Committees

Committee on Property & Liability Financial Reporting (COPLFR) overview providing information on effective use of actuarial loss reserves expertise by audit committees and boards. (December 10, 2014 )

COPLFR Comment Letter on Proposed Changes to IRIS Ratios

Committee on Property and Liability Financial Reporting comment letter to the NAIC's Casualty Actuarial and Statistical Task Force on proposed changes to IRIS ratios 11, 12, and 13, which would add adjusting and other expenses to the basis for calculating these ratios. (July 10, 2014 )

Statements of Actuarial Opinion on P&C Loss Reserves (2013)

Committee on Property and Liability Financial Reporting 2013 practice note on statements of actuarial opinion on P&C loss reserves. (December 23, 2013 )

Presentation to Regulators on Process Allowing Non-CAS Members to Sign NAIC P/C Opinions

Presentation to the NAIC’s Casualty Actuarial & Statistical Task Force on the Casualty Practice Council’s application process for non-CAS members to be approved to sign NAIC P/C Opinions. (August 24, 2013 )

Comments on Proposed Regulations on CA Workers’ Comp Self-Insurance Plans

COPLFR comment letter to the California Office of Self Insurance Plans concerning proposed final regulations on the state’s workers’ compensation self-insurance plans. (June 07, 2013 )

COPLFR Comment Letter on Proposed Changes to Schedule P

Committee on Property & Liability Financial Reporting comment letter to the NAIC’s Blanks Working Group on its proposed changes to move all force-placed or lender-placed business from the current line to the write-in line of Schedule P. (March 07, 2013 )

Statements of Actuarial Opinion on P&C Loss Reserves (2012)

Committee on Property and Liability Financial Reporting's 2012 practice note on Statements of Actuarial Opinion on P&C Loss Reserves. (December 17, 2012 )

COPLFR Comments on Proposed NAIC 2012 Actuarial Opinion Instructions

Comments by Committee on Property and Liability Financial (COPLFR) to the NAIC's Blanks Working Group on its proposed 2012 Actuarial Opinion Instructions. (May 01, 2012 )

Statements of Actuarial Opinion on P&C Loss Reserves (2011)

Committee on Property and Liability Financial Reporting's 2011 practice note on Statements of Actuarial Opinion on P&C Loss Reserves. (December 16, 2011 )

Reinsurance Attestation Supplement 20-1: Risk Transfer Testing

Committee on Property & Liability Financial Reporting practice note on risk transfer testing. (February 01, 2007 )

Comments to AICPA on Draft Audit & Accounting Guide for Property and Liability Insurance Entities

Committee on Property and Liability Financial Reporting comments to the AICPA regarding its working draft of Audit and Accounting Guide Property and Liability Insurance Entities. (August 26, 2011 )

GAAP Survey Results Committee on Life Insurance Financial Reporting (COLIFR)

Committee on Life Insurance Financial Reporting (COLIFR) report on its GAAP survey.
(April 02, 2001 )

COPLFR Report on Improvements to Statements of Actuarial Opinion

Committee on Property & Liability Financial Reporting's report on its recent activities to the NAIC's Casualty Actuarial & Statistical Task Force. (February 01, 2011 )