U.S. Qualification Standards

I didn’t see a thread about the first exposure draft. 2nd exposure draft of USQS was published.

https://www.actuary.org/node/14452

The American Academy of Actuaries’ Committee on Qualifications (COQ) has approved the release of a second exposure draft of the Qualification Standards for Actuaries Issuing Statements of Actuarial Opinion in the United States (USQS). This document is intended to replace the Qualification Standards (including Continuing Education Requirements) for Actuaries Issuing Statements of Actuarial Opinion in the United States that took effect Jan. 1, 2008. The comment deadline for the second exposure draft is Aug. 20, 2021.

The first exposure draft was issued on Sept. 2, 2020, with a comment deadline of Oct. 30, 2020. The COQ received 152 comment letters, indicating that many members of the actuarial profession care strongly about the USQS and the standards they set for individual actuaries. The COQ thanks everyone who submitted comments.

Actuaries did not confine their comments just to the changes set forth in the exposure draft, but took the opportunity to comment on the USQS in total. The comments received were thoughtful, came from actuaries from a variety of practice areas, and covered a wide range of topics, including area of practice, basic education, specialty tracks and examinations, enrolled actuaries, and diversity, equity, and inclusion.

The COQ carefully considered the comments and made changes as reflected in this second exposure draft. The Academy Board of Directors reviewed this draft and provided comments, which were taken into consideration in developing this exposure draft.

The Transmittal Memorandum at the beginning of the second exposure draft describes the significant changes proposed and asks for comments from members of actuarial organizations governed by the USQS and all interested parties, including the public.

How to Submit Your Comments

The Committee accepts comments by electronic means.

  • The required form is electronic.
  • Please provide section or paragraph references for specific comments.
  • Comments will be posted in the order that they are received.
  • The Committee plans to post all signed comments received to its webpage to encourage transparency and dialogue. Unsigned or anonymous comments will not be considered by the Committee nor posted to the webpage.
  • The comments will not be edited, amended, or truncated in any way.
  • Comments will be removed when final action is decided by the Academy to this process such as revising the U.S. Qualification Standards in accordance with Appendix 3 to the U.S. Qualification Standards.

The comments submitted will be accessible to the public. The Academy disclaims any responsibility for the content of the comments posted, which are solely the responsibility of those who submit them.

Email Submission

If you wish to comment, please send a message to USQSComments@actuary.org. You may include your comments either in the body of the message or as an attachment prepared in any commonly used word processing format. Please do not password protect any documents.

Comments should be submitted no later than August 20, 2021.

This seems to be a good change. The addition of bias topics is a good one for sure.

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That thing is 39 pages (including appendices), can someone give me a “tl;dr” version?

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I’m going to pull out some quotes from the document – this relates to the comment letters from the earlier draft.

Area of practice—Several commentators said it was unclear what was meant by “area of
practice,” which is referenced in several sections of the current USQS. The COQ notes that
section 1.4 states, “The traditional areas of actuarial practice are casualty, health, life, and
pension.” This language appears in both the 2008 USQS and this exposure draft. The lack of
clarity relates to references or circumstances when the same terminology “area of practice” was
used to refer to an area that may be more specific than these four practice areas. In response to
the comments, references to “area of practice” in sections 2.1(d), 2.1(d)(1), 2.1(d)(2), 2.1(d)(3),
and 2.1.1(b) where the COQ recognized more specificity was needed, were revised.

Specialty tracks and examinations—The COQ revised the language to clarify that section
2.1(d) sets qualifications for issuing SAOs “on a particular subject within an area of actuarial
practice,” rather than “an area covered by a specialty track offered by the Society of Actuaries or
in an area of practice covered by the exams for the Casualty Actuarial Society or the American
Society of Pension Professionals and Actuaries.” The goal was to keep this section of the U.S.
Qualification Standards clearly focused on the basic education component in a way that was both
sufficiently particular about basic education as well as sufficiently general so as not to become
outdated solely because of a change in the name of a specialty track or the addition of a
particular specialty track offered by a basic education provider. In addition, the applicability of
this section to actuaries with CAS credentials was unclear because the CAS does not currently
offer specialty tracks.

Diversity, Equity, and Inclusion (DE&I)—Many commentators requested that the USQS
clarify that professionalism topics include DE&I, and several of those commentators suggested
that DE&I continuing education be required. The COQ considered all these comments and
agreed with the need to clarify that some DE&I topics could be considered professionalism CE.
Thus, Frequently Asked Question #48 has been updated to clarify that DE&I topics may be
considered either general business skills CE or professionalism CE depending upon the content
of the particular CE offering. This change immediately addresses some of the comments received,
with the understanding that the FAQ may be further amended if appropriate upon final approval
of an updated USQS.

New Requirement for CE related to Bias Topics—This second exposure draft includes a new
one-hour minimum CE requirement dedicated to what is referred to as “bias topics.” Section
2.2.6 specifies that bias topics “include content that provides knowledge and perspective that
assists in identifying and addressing biases that may exist in data, assumptions, algorithms, and
models that impact Actuarial Services. Biases may include but are not limited to statistical,
cognitive, and social biases.” The COQ included bias topics in the CE requirements to focus on a
topic that provides knowledge and perspective that is relevant to the Actuarial Services that form
the basis of an SAO.

Should be interesting to see what people will come up w/ for bias-related CE.

Of course, in the statistical sense, a biased estimator is one for which the expected value differs from the value of the thing you’re trying to estimate.

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Wasting a chance to get some CE!

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Well, there’s that.

I will give you a TOC, so you can decide what to read:

pp 2-6 – background & summary of comment letters from first draft
6-10 – changes made in this draft from prior draft
11 – committee members
12-13: intro to new QS
14-19: general QS (including CE requirement)
20-21: specific QS
22: change in practice/field
23: acknowledgement statement
24: recordkeeping
25-30: Appendix 1 - examples of SAOs
31: Appendix 2 - alternative basic qual
32-36: App 3 - procedures for adopting new QS
37-38: App 4 - procedures to determining specific QS needed
39: App 5 - recordkeeping form

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The response letters to the first draft can be found here, just to pop out this link:
https://www.actuary.org/node/13857

I went to a session last year about bias in measuring expected losses, and how the "red lines"of the past affect today’s rates. It was quite good. I’m sure there’s more where that came from.

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Agreed. These seem like mostly modest changes that improve the US qualification standards.