Feedback on ISAP Due Process – Editorial and Suggested Clarifications
The following are suggested editorial and clarification changes to the existing Due Process document.
We consider these to be non-controversial and capable of immediate implementation without
changing the current due process. They are listed by the number of the step to be changed in the
current Due Process document.
Throughout – change IASSC to ASC
1.2. More complete list of ways to react to an ISAP –Currently the step says that an FMA or other body
that wishes to act upon an ISAP can “either” adopt it or modify it before adopting. This list of options
should be expanded to the following:
•
Adopting this ISAP, with appropriate modification, following the drafting instructions
where items covered in this ISAP are not currently contained in existing actuarial
standards, or where such portions of existing actuarial standards are to be withdrawn;
•
Endorsing this ISAP as an alternative to existing standards;
•
Modifying existing standards to obtain substantial consistency with this ISAP; or
•
Confirming that existing standards are already substantially consistent with this ISAP.
1.3.a Change “the version of the ISAP that is so accepted” to “… that is so adopted”.
1.3.c (Noting that ISAPs apply to actuaries and not employers of actuaries) – At the end of step 1.3.c
where it discusses when an ISAP does not apply, delete the part that says “or the products of the
actuary’s employers”.
2.1 This step currently says that there are five stages of this Due Process for an ISAP. The last two
stages are approval of the final ISAP, with stage 4 identifying the EC’s role and stage 5 identifying the
Council’s role. Condense these into a single stage (going from 5 stages to 4).
2.1 In step 2.1, first bullet, rephrase the approval of the ISAP strategic action plan from being approved
“by Council” to being approved “by the EC with ratification by Council”.
4.1. Add the phrase “as outlined in the final SOI”, so it reads “potential revisions to the scope as
outlined in the final Statement of Intent may be identified”.
4.1.c - change wording of the SOI requirement for “a high level indication of the proposed contents” to
instead require “a clear indication of the proposed contents”.
4.2 Where it says that the consultation process for an ISAP exposure draft will be for “60 days”, change
this to “at least 60 days”.
4.3 - SOI conditions for EC approval - Add to the list of considerations the likelihood that “the ISAP will
ultimately be adopted by an 80% approval byvote of Council”.
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Comment [G1]: Alternatively” approval
by 80% of Council votes”
Feedback on ISAP Due Process – Editorial and Suggested Clarifications
4.3 This step discusses considerations for the EC to use in approving (or not) an SOI. The last part of this
step deals with ISAPs designed not for universal adoption but to meet the needs of a select group of
FMAs. The suggestion is to add the word “only” to the phrase:
“However, where the reason for developing an ISAP is to assist only some member associations,
…”
4.4. Add the word “proposed” in step 4.4 where it would say:
“The ASC will submit for approval to the Executive Committee a final proposed Statement of
Intent …”
5.3, 5.4 In step 5.3 change “promulgate” to “publish” and “promulgation notice” to “publication”. A
similar editorial change is recommended for step 5.4.
6.3 Editorial correction (changes in italics, underlined) – Change step 6.3 from:
“The submission will include a statement from the Professionalism Committee that this Due
Process has been complied with.
to:
“The submission will include the statement from the Professionalism Committee as to
compliance with this Due Process.”
Note that this wording change allows for comments about immaterial non-compliance that
supposedly would not prevent ISAP approval.
8.2 Who “maintains” the list of ISAPs in development – Step 8.2 requires the PC to maintain a list of
ISAPs in development (i.e., that are on the ISAP Strategic Plan). There is some question as to who
maintains this list, although it is clear that the PC needs such a list for its monitoring work. Does the first
bullet of Step 8.2 need to be clarified (so multiple parties aren’t responsible for maintaining duplicate
lists)?
8.2 The last bullet of step 8.2 requires the PC to report that “due process has been followed”. This
wording does not allow for the possibility that it wasn’t. Suggested wording would require reporting
“on whether (and to what extent)” due process has been followed.
10.1, 10.2, 10.3 Transition portion of Due Process now obsolete – Steps 10.1, 10.2 and 10.3 dealt with
the transition from the old class 4 IASPs to either IANs or ISAPs. The ASC subgroup believes that these
steps are now obsolete and should be deleted from the Due Process document.
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Feedback on ISAP Due Process – Editorial and Suggested Clarifications
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