the beginning to: groups of life insurance policies subject to VM-20 Section 3.A.2 that pass “For the stochastic exclusion test…” Section 3.C.13.a, Officer on Investments”. The reference should be to Section “Investment 7.E.1.g of VM-20, not Section 5.E.1.g.. Section 3.C.13.c, Management on Internal Controls”. The SVL reference should be “Senior stated as not “12B(2)”, “12.B.(2)”. Thank you for providing me the opportunity to submit these comments. Craig Chupp, FSA, MAAA Life and Health Insurance Actuary Virginia Bureau of Insurance Phone: (804) 371-9131
the beginning to: “For groups of life insurance policies subject to VM-20 Section 3.A.2 that pass the stochastic exclusion test…” Section 3.C.13.a, “Investment Officer on Investments”. The reference should be to Section 7.E.1.g of VM-20, not Section 5.E.1.g.. Section 3.C.13.c, “Senior Management on Internal Controls”. The SVL reference should be stated as “12B(2)”, not “12.B.(2)”. Thank you for providing me the opportunity to submit these comments. Craig Chupp, FSA, MAAA Life and Health Insurance Actuary Virginia Bureau of Insurance Phone: (804) 371-9131
cmte_a_latf_180419_va_comments.docx