本件は、2016 年 1 月に IAA から公表された ISAP（International Standard of Actuarial Practice ）1A の公開草案に対して、当会 から 2016 年 3 月 31 日付 で提出 したコメ ント です。
退職給付会計基準委員会

Comments Template for Exposure Draft of ISAP 1A

INTERNATIONAL ACTUARIAL ASSOCIATION

Deadline: 31 March 2016
Please use this template to comment on the Exposure Draft of ISAP 1 A Governance of Models, and the proposed revisions to the Glossary for
ISAP 1A.
The IAA invites comments on this Exposure Draft, particularly on the questions set out below. Comments are most helpful if they:(a) Comment on the questions as stated;(b) Indicate the specific paragraph or group of paragraphs to which they relate;(c) Contain a clear rationale; and(d) Include any alternative that the IAA should consider, if applicable within the scope of the Statement of Intent for ISAP 1A.
Identification and instructions
Name of Individual:

Please indicate if your comments are personal, or represent your organization:

The Japanese Society of Certified Pension Actuaries

Name oforganization
Disclosure ofcomments:

Comments represent the organization.

Please indicate if your comments should be treated as confidential, and if so why:

Instructions for filling Please follow the following instructions for filling in the template:in and sending the Do not write in the yellow shaded cells
template Write in the white cells
 When commenting on a specific paragraph:oPlease use a separate row for each paragraph, sub paragraph, orbullet.

oPlease include the full reference in the first column such asrdnd“Introduction 3 paragraph 2 bullet” or “2.6.1.b.ii”

oPlease insert/append extra rows as needed.

Please send the completed template, renamed with the organization’s orindividual’s name, attached in Word Format, toISAP1A.comments@actuaries.org

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Comments Template for Exposure Draft of ISAP 1A

INTERNATIONAL ACTUARIAL ASSOCIATION

Deadline: 31 March 2016

Specific Questions asked by the ASC
Q1.

Is the guidance clear and unambiguous? If not, how should it be changed?

Q2.

Is the guidance sufficient and appropriate? If not, how should it be changed?

ResponseNo.

Q3.

Is it clear how the guidance in the proposed ISAP relates to the guidance in ISAP 1? If not,how should it be changed?

Q4.

Is the guidance at the right level of detail? If not, what text should be omitted because it is
too detailed? In what areas do actuaries need more detailed guidance?

Q5.

Are there other matters that should be included in this standard on governance of models?
Are there some included here that should not be?

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We have been told that, in order to avoid any
confusion at this stage of convergence process ofmany associations, and because this content
should be applied only to the actuarial practices inrelation to insurance company, such a separated
form as ISAP 1A from ISAP 1 is chosen. Thissounds preferable to many associations including
the JSCPA.
But, we could not actually find any expression ofsuch limitation of its applicability in ISAP 1A. An
actuary who asserts to be in accordance with ISAP
3 does not have to follow ISAP 1A because of theproposed ISAP structure. But, actually ISAP 1A isapplicable to this actuary, why doesn’t thisactuary assert to be in accordance with ISAP 1A?
We think this may cause confusion. And, this willbe troublesome when it is merged with ISAP 1 inthe future.

Comments Template for Exposure Draft of ISAP 1A

INTERNATIONAL ACTUARIAL ASSOCIATION

Deadline: 31 March 2016

General Comments on the ISAP 1A Exposure Draft

Comments on specific paragraphs of the ISAP 1A Exposure Draft
Full paragraphreference

Change proposed to the paragraph (markup preferred)

Reason the change is needed (can be kept very
brief or left blank if obvious from the change)

Comments on specific definitions in the Exposure Draft of the updated Glossary
Note that only the proposed revisions are open for comment
Defined Term

Change proposed to the definition (markup preferred)

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Reason the change is needed (can be kept very
brief or left blank if obvious from the change)