Over the summer, the NAIC ran a pilot review of the U.S. ORSA using 13 ORSA summary reports that a variety of insurers submitted. Although formal feedback to the industry is still pending, the NAIC did make some initial comments on the results of this review at its summer national meeting in August 2012. Although this feedback is unlikely to find its way into the guidance manual, insurers are likely to adapt ORSA processes in order to address it.

One particular area of comment was stress tests. Specifically, in addition to single-factor stress testing, companies should consider combined stress event scenarios. In addition, particularly for the life sector, there should be stress testing on liquidity.

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