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House Passes Build Back Better Reconciliation Bill
On November 19, the House of Representatives approved and sent to the Senate H.R.5376, the Biden/Democrats Build Back Better reconciliation bill. The $1.75 trillion measure passed on a 220-213 mostly partisan vote. The bill is more notable, from NAIFA’s perspective, for what it does not contain than for what it includes. Most of the adverse tax increases that had been proposed have been left out of the House bill.
All House Republicans opposed the bill and one House Democrat, Rep. Jared Golden (D-ME), joined them in voting against it.
The bill is sure to change in the Senate, but was passed by the House, it contains $130 billion in extended or expanded subsidies for affordable health insurance, through the Affordable Care Act (ACA) premium subsidies and tax credits. Also included in the bill is a new federal paid family and medical leave program that would provide up to four weeks of government-paid leave, starting after two weeks of absence. The federal benefit would replace wages based on income level—starting at about 90 percent of wage replacement for those earning $15,082/year or less and going down to 73 percent of wage replacement for income between $15,082 and $34,248 and capping out at about 53 percent for compensation between $34,248 and $62,000.
The bill’s supporters claim the cost of the bill is fully offset, although the official score, from the Congressional Budget Office (CBO), finds a shortfall of almost $400 billion. Among the offsets are almost $1.5 trillion in tax increases. These tax increases include:
The House bill also includes a one-year extension of the child tax credit, climate change provisions, education program funding, low-income housing support program funding, and an increase (to $80,000) in the limit on the deduction for state and local taxes (SALT).
Some of the offsetting revenue is due to come from increased funding to the Internal Revenue Service to “close the tax gap” (i.e., collect more tax already owed under current law through toughened enforcement), and limited new authority for the Federal government to negotiate the cost of certain prescription drugs.
For NAIFA, what’s even more important is what is not in the House version of H.R.5376. Effective lobbying by NAIFA members and their staff resulted in lawmakers rejecting proposals to:
H.R.5376 also excludes a proposal to require most employers to automatically enroll their workers in either a salary deferral retirement savings plan or a payroll-deduct IRA program. A proposal to make the Saver’s Credit refundable was also left out of the bill.
Prospects: Many of these House-approved provisions are likely to win support from the entirety of the Senate Democratic caucus (and it will be necessary to have that unanimity in order to pass the reconciliation bill), but some won’t. Senate Democrats are likely to delete, modify and/or add provisions to the House-passed bill. Information on what the Senate may change is in the story below.
NAIFA Staff Contacts: Diane Boyle – Senior Vice President – Government Relations, at dboyle@naifa.org; Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org; or Michael Hedge – Director – Government Relations, at mhedge@naifa.org
Senate Likely to Change House-Passed Build Back Better Bill
The Senate is working towards a vote on the House-approved Build Back Better (BBB) reconciliation bill, H.R.5376. Leadership wants the vote this month, although most Washington insiders think it will slip into 2022. Senators are virtually certain to make changes to the House bill. Among the possible changes are elimination or modification of the federal paid leave program, and modifications (and possibly additions) to the revenue/offset package.
Take Action Now!: NAIFA members are encouraged to contact their own Senators to remind them of the importance of not adding back any of the adverse proposals that the House bill left out of its version of H.R.5376. In particular, the message should ask Senators to oppose any effort to diminish the section 199A deduction for non-corporate business income, to tax unrealized investment gains (even if only for multi-millionaires), to eliminate step-up in basis, to increase capital gains tax rates, and/or to hike corporate tax rates.
Visit the Advocacy Action Center and voice your concerns today.
Many moderate Democrats are insisting that the finished measure be revenue-neutral—i.e., that all the new spending be fully offset. It is not currently revenue-neutral, based on the preliminary but official Congressional Budget Office (CBO) score. So, if the final CBO score, which is expected later this month and without which the Senate cannot, under the rules of reconciliation, proceed to a vote on the bill, confirms the initial finding that the bill is about $376 billion short of revenue-neutrality, Senators will have to either shrink some of the spending programs or add new revenue.
Further, there are Democratic Senators who want to add to the spending side of the bill. For example, Sen. Bernie Sanders (I-VT) is still fighting to expand Medicare benefits to include dental and vision benefits. However, that effort is in competition with other Senators’ attempts to shrink the House-approved expanded Medicare hearing benefit.
Also at risk is the new paid leave program that was included in the House bill. Some Senate moderate Democrats are concerned not only about the program’s cost, but also about adding more benefits to Medicare when Medicare itself is facing a solvency crisis in just a few years. Plus, the federal paid leave program may not survive its “Byrd Bath”—the process by which the Senate parliamentarian determines whether the provision complies with the reconciliation rules. If she determines that the federal paid leave program does not comply with the (highly complex) reconciliation rules, the program will have to be dropped from the final package.
There are other unrelated-to-NAIFA provisions likely to change in the Senate, too—for example, the state and local tax (SALT) deduction provision, the tax credit for union-built electric vehicles, and the corporate minimum tax provision, among others.
When all is said and done, there is a real possibility that additional offsetting revenue will be needed. That could bring back into play provisions left out of the House bill—things like an increase in the corporate, personal and/or capital gains tax rate; modification (to shrink its benefit) of the deduction for pass-through business income; and estate tax rule changes.
Visit the Advocacy Action Center and voice your concerns today.
Prospects: Senate action will take time. Democrats want the bill finished by Christmas, but the complexity of the negotiations (combined with the need to win unanimous Democratic support), and other demands on Senate time, mean most Washington insiders (on and off the Hill) think a Senate vote on the BBB will slip into 2022. Then, the bill as changed by the Senate has to go back to the House for its approval, and that, too, could take time. In short, while the goal is to finish work on the BBB reconciliation bill before Christmas, most Washington insiders predict the effort could easily spill into 2022.
NAIFA Staff Contacts: Diane Boyle – Senior Vice President – Government Relations, at dboyle@naifa.org; Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org; or Michael Hedge – Director – Government Relations, at mhedge@naifa.org
Congress Passes Debt Limit Increase, Medicare Sequester
Congressional leadership devised a process for raising the debt limit, and passed it on December 14, thus averting the economically catastrophic potential for a default by the U.S. on its existing debt. The agreement also included legislation to avoid $14 billion in otherwise required Medicare cuts.
The agreement was a complex, process-oriented strategy that allowed Democrats to by themselves raise the debt limit—to $2.5 trillion, enough to get the U.S. through until after the November 2022 elections, without the threat of a filibuster in the Senate. It also allowed them to pass the legislation needed to stave off the budget law-required sequester—automatic cuts—to Medicare. Opposition to the cuts—two percent across the board, or about $14 billion—was bipartisan and widespread.
Generally, the agreement required Congress to first pass a bill that allowed a one-time exception to the Senate’s filibuster rules that let Democrats by themselves, with a 51-vote majority, raise the debt limit. This bill required 60 votes in the Senate to pass.
The House passed the process bill, S.610, which also includes the needed extension of the deferral of the sequester of Medicare funds, on December 7. The Senate passed the process bill on December 9. President Biden then signed it into law. So, enactment of S.610 means the across-the-board Medicare cuts have been averted.
Then, both the House and Senate had to vote on a separate bill to increase the debt limit. Those votes—all Democratic with no Republican support—came on December 14, the day before the December 15 date that Treasury said would mark the end of its ability to borrow enough to meet its existing obligations, on a timely basis.
Prospects: The agreement—which was signed off on by Congressional leaders from both parties in both the House and Senate—had its opponents, and they were vociferous in their dislike of the idea. But at the end of the day, there were the votes to pass the debt limit increase measure in time to avert a default.
Some in Washington are concerned that this is a precedent-setting maneuver that could weaken the minority party’s use of the Senate filibuster. But whether that proves to be true remains to be seen.
NAIFA Staff Contacts: Diane Boyle – Senior Vice President – Government Relations, at dboyle@naifa.org; Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org; or Michael Hedge – Director – Government Relations, at mhedge@naifa.org
Congress Funds the Government through February 18
Lawmakers avoided a messy government shutdown on December 3 by passing a Continuing Resolution (CR) that funds the U.S. government between December 3, 2021, and February 18, 2022. The CR passed on December 2; President Biden signed it into law on December 3.
H.R.6119, the CR, passed the House by a 221 to 212 vote. Just a few hours later, the Senate passed the measure by a 69 to 28 vote. The CR funds the government at fiscal year (FY) 2021 levels (FY 2021 ended September 30, 2021). Thus, Congress must still decide on funding levels and budget policy changes for FY 2022. Those decisions—or another CR—are now required by February 18, 2022.
Prospects: While lawmakers, government agencies, and voters alike are glad to not face a government shutdown right around the holidays, the CR does no more than delay resolution of the controversies surrounding the U.S. government and agency funding. Expect another heads-butting budget debate to heat up to a full boil towards the end of January.
NAIFA Staff Contacts: Diane Boyle – Senior Vice President – Government Relations, at dboyle@naifa.org; Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org; or Michael Hedge – Director – Government Relations, at mhedge@naifa.org
New Fiduciary Rule Impacting Annuities, Life Insurance Expected Next Year
Industry experts are expecting a new proposed fiduciary rule that would impact those who sell life insurance and annuities. The Department of Labor (DOL) had said it would propose the new rule this month, but that looks like it will not happen. It now seems likely the proposal will come out next year, possibly early in January or February. DOL’s Employee Benefits Security Administration (EBSA) has announced its intention to propose new fiduciary rules applicable especially to rollovers into IRAs or annuities.
Despite EBSA’s announced intention of releasing the new proposed fiduciary rule this month (December), agency personnel are still meeting with stakeholders including NAIFA. After those meetings conclude, and the proposal is drafted, it will have to go to the White House (the Office of Information and Regulatory Affairs, or OIRA) for review before it can be released. Thus, a December release is highly unlikely. And since OIRA can take weeks or longer to review a proposed new regulation, it could be quite sometime before the public sees the new proposal.
Currently, after multiple conversations with EBSA regulators by NAIFA and others in the retirement savings community, it appears that EBSA is planning to issue rules that will require more financial professionals, including those who sell proprietary annuity products, to adhere to fiduciary standards. Of particular concern is the standard that may be applied to advisors who are discussing retirement savings options for the first (and perhaps only) time with prospective clients.
Commission-based compensation could be impacted under a new fiduciary standard, requiring advisors who are paid by commission to make fiduciary disclosures, comply with strict recordkeeping requirements, and comply with conflict-of-interest rules.
Industry experts involved in discussions with EBSA say the new definition could substantially impact first-time advice, potentially making a fiduciary anyone who talks about investment products with plan participants, said Fred Reish, a Los Angeles law firm partner who specializes in retirement plan issues. “A new fiduciary definition could provide that, where there is a relationship of trust between a retirement investor and an insurance agent or a representative of a broker-dealer, one-time advice could be fiduciary advice,” he said. “I expect that for all of those fiduciary recommendations there will be rigorous standards of care, disclosures, mitigation requirements, at the least. That will probably have the greatest effect on advice to IRAs and on annuity sales.”
Prospects: NAIFA is closely watching fiduciary rule developments at EBSA and is in regular communication with EBSA personnel about pitfalls to avoid and appropriate rules to consider. We will keep you posted as the issue develops.
NAIFA Staff Contact: Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org
IRS Addresses Accelerated Expiration of ERTC
On December 6, the Internal Revenue Service (IRS) issued guidance (Notice 2021-65) to help employers caught unawares by the acceleration of the expiration of the employee retention tax credit (ERTC). Generally, the guidance gives two weeks of leniency to employers who are expected to make use of the ERTC through the end of 2021.
As originally enacted and then extended, the ERTC—a refundable (against the payroll tax) credit tied to keeping employees on the payroll during the pandemic—would have been in effect through the end of 2021. However, the recently enacted bipartisan traditional infrastructure bill accelerated the ERTC expiration date to September 30, 2021.
Under the rules of Notice 2021-65, an employer has until December 20 to comply with the new procedures if they are to avoid penalties. Generally, the guidance explains how and when a business that received an advance payment, based on projected ERTC claims for October 1 through December 31, 2021, can return that money on a penalty-free basis. It also addresses how an employer that reduced its payroll tax payments in anticipation of getting the ERTC can avoid penalties now that the ERTC is no longer available for the October-December timeframe. The Notice allows these employers to repay advanced payments by the time their tax returns are due.
The Notice also provides that while failure to deposit payroll taxes by December 20 will trigger penalties, the IRS will hear appeals and consider “reasonable cause relief.”
Prospects: The accelerated expiration of the ERTC has caused issues for a number of employers that planned to make use of the pandemic-relief-related tax credit. This leniency from the IRS is designed to help those businesses.
NAIFA Staff Contacts: Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org; or Michael Hedge – Director – Government Relations, at mhedge@naifa.or
House Committee Favorably Reports Retirement Bill
On November 10, the House Education & Labor Committee unanimously favorably reported out its portion of the SECURE 2.0 retirement savings legislation. The bipartisan bill, H.R.5891 is named the Retirement Improvement and Savings Enhancement Act (RISE). It is now ready for a House vote, although a House vote has not yet been scheduled.
The RISE Act addresses non-tax ERISA-focused improvements to retirement savings law. The non-tax ERISA portion of emerging generation-two retirement savings legislation joins the tax-focused Ways & Means Committee-approved Securing a Strong Retirement Act (SSRA) bill, H.R.2954. Together, the two bills are known as SECURE 2.0.
The Education & Labor-approved legislation would create a searchable database allowing individuals to find retirement benefits from former employers that they may have forgotten about. The bill also expands eligibility to join a pooled employer plan and permits small financial incentives to encourage workers to participate in employer-provided retirement savings plans. Also included in the bill are provisions requiring the Department of Labor (DOL) to study and report to Congress on target date fund benchmarks, pension risk transfers, and retirement plan reporting requirements.
Prospects: Generation two retirement savings legislation has broad bipartisan support and good prospects for enactment next year. However, it is unlikely we will see any further movement on retirement savings bills this year.
NAIFA Staff Contact: Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org
Ways & Means Subcommittee Holds Hearing on Social Security Reform
On December 7, the House Ways & Means Committee’s Subcommittee on Social Security held a hearing about the need to shore up the Social Security program, and on how to do it. The hearing focused on H.R.5723, a Social Security reform bill.
Introduced on October 26 by Social Security Subcommittee Chairman Rep. John Larson (D-CT), with 196 Democratic cosponsors, H.R.5723 would increase Social Security benefits for lower- and middle-income wage earners and surviving spouses and increase Social Security payroll taxes on incomes above $400,000/year.
Other reforms in H.R.5723 include combining the current separate trust funds (old age and survivors, and disability) into just one Social Security trust fund, provision of caregiver credits to cover those who care for children or other dependents instead of working outside the home, ending the five-month waiting period for disability benefits, and changes to the cost-of-living calculation formula.
The nine witnesses at the hearing focused on the need for uninterrupted and, where possible, enhanced Social Security benefits, especially for lower-and-middle-income workers who have little or no other retirement income. They noted the need to strengthen the trust fund(s) that support Social Security benefit payments—the Old Age, Survivor, and Disability Income trust funds (OASDI) are currently projected to be depleted by 2034. If Congress doesn’t act by then to shore up the trust funds, benefit cuts of up to 24 percent are projected.
Prospects: Although Rep. Larson wants a House vote on H.R.5723 as soon as possible—and certainly by next year, it is unlikely Congress will act on the Social Security issue this year or next. The proposal is controversial, and Social Security is a sensitive issue that will likely require bipartisanship to address. And bipartisanship is in very short supply in this Congress.
NAIFA Staff Contacts: Diane Boyle – Senior Vice President – Government Relations, at dboyle@naifa.org; or Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org
IRS Proposes Minimum Essential Coverage Regulation
On November 22, the Internal Revenue Service (IRS) proposed a new regulation (RIN: 1545-BQ11) on what constitutes minimum essential coverage under the Affordable Care Act (ACA). Generally, the proposed rule excludes from the definition of minimum essential coverage Medicaid coverage that is limited to covid-19 testing and diagnostic services and extends the time employers have to issue ACA-required notices.
The proposed rule makes automatic the extension of time health insurers and self-insured employers have to provide statements regarding health coverage to employees. The proposed rule also provides an alternative method for providing required statements when the employer does not owe any shared responsibility fines or penalties. In addition, the proposed new rule grants an automatic time extension to employers with more than 50 full-time employees to provide statements relating to the health insurance they offer to their full-time workers.
Prospects: The proposed rule states that it could impact taxpayers who claim ACA premium tax credits, health insurers, and self-insured employers, among others. Comments on the proposed regulation are due 60 days after publication of the proposed rule in the Federal Register (i.e., by January 22).
NAIFA Staff Contact: Michael Hedge – Director – Government Relations, at mhedge@naifa.org
IRS Releases FSA Inflation Adjustments
On November 10, the Internal Revenue Service (IRS) released inflation-adjusted limits on flexible spending arrangements (FSAs). The adjustments are in Revenue Procedure (Rev. Proc.) 2021-45.
Generally, the Rev. Proc. states that for plan years beginning on or after January 1, 2022, the health FSA salary reduction contribution limit will increase to $2,850, up from $2,750 in 2021. The carryover limit (indexed at 20 percent of the maximum FSA salary reduction contribution) will go from the current $550 to $570. That means that an FSA owner can carry over $570 from a 2022 plan year to his/her 2023 plan year.
These adjustments are separate from the pandemic-related carryover allowances that permit FSA owners to carry over the full unused FSA account balance from plan years ending in 2020 and 2021 to the subsequent plan years ending in 2021 and 2022 respectively.
Generally, the maximum a person plus his/her employer can contribute to an FSA (starting on or after January 1, 2022) is $2850 by the employee and $500 for the employer, for a combined maximum contribution of $3,350.
NAIFA Staff Contacts: Judi Carsrud – Assistant Vice President – Government Relations, at jcarsrud@naifa.org; or Michael Hedge – Director – Government Relations, at mhedge@naifa.org
Kentucky and Mississippi become the 17th and 18th States to Adopt the Annuity Best Interest Standard
As the year comes to a close, two (2) more states have completed the adoption of the NAIC’s updated Model on Annuity Suitability which includes a Best Interest Standard of Care for annuity transactions. Mississippi and Kentucky’s regulatory amendments will take effect on January 1st, 2022, along with Alabama, Maine, Nebraska, and North Dakota. Though in Mississippi, the amended regulation will not apply to actions or practices until July 1st, 2022, aligning with the deadline for agents to complete updated annuity continuing education.
NAIFA members and State Chapter Leaders, working closely with our advocacy partners, have been instrumental in promoting passage of the laws and regulations. The Best Interest Standard is an important step forward and will continue to provide enhanced protection for consumers seeking guaranteed lifetime income through annuities. And unlike a fiduciary-only approach, these measures make sure savers, particularly middle and working-class Americans, can access information about different choices for long-term security throughout retirement.
As we move into 2022, broad adoption of the updated NAIC Model continues to be a top priority for NAIFA advocacy. With eight (8) additional states already considering adoption either by updated regulation or legislation, we anticipate more states will recognize the benefits and follow suit.
NAIFA Staff Contact: Maeghan Gale – Policy Director – Government Relations, at mgale@naifa.org
Washington Care Trust Fund Faces an Uncertain Future
The Washington Care’s Trust Fund is a first-of-its-kind publicly administered Long-Term Care insurance program. Legislation creating the program was passed by the Washington state legislature in 2019, and it is set to begin collecting premiums through a .58% payroll tax on January 1st, 2022. The implantation has been a rollercoaster ride for insurance producers selling in Washington, including many NAIFA members. The program allowed for a one-time opt-out provision for workers who owned qualifying private-long term care insurance prior to November 1st, 2021. This created a substantial run on the private LTC market, causing many carriers to significantly limit or suspend sales entirely, and producers to work around the clock to keep up with demand. Far from being a windfall, the longevity of these newly acquired policies is still undetermined, leaving many producers with concerns about the impact on their practice.
As January 1st moves closer, legal, political, and administrative challenges continue to mount for the Washington Cares Trust Fund. Opponents on all sides have voiced significant criticism about many elements of the program and it appears they are being heard. Over recent weeks it’s been a flurry of activity including; a cease-and-desist order filed by Idaho’s Attorney General concerning the collection of taxes from Idaho residents, a class-action lawsuit has been filed alleging that the program is unenforceable and violates ERISA and other federal and state laws governing employee benefit plans, a group of state Democrats sent a letter to Governor Inslee calling for a delay until January 1st, 2023 so that they can use the 2022 legislative session to address the concerns, a ballot initiative has been filed to make the program voluntary, and seven (7) bills have been pre-filed in the legislature seeking everything from additional exemptions to outright repeal of the program. Governor Inslee has expressed his understanding of the situation, but no action has been taken yet. The Washington Legislature convenes January 10th, 2022, and would need to call a special session to act before January 1st. Regardless of whether the Washington Care’s Trust Fund launches with the New Year, its fate remains uncertain. And with several other states considering similar programs, NAIFA, along with our advocacy partners will not be the only ones monitoring the situation closely.
NAIFA Staff Contact: Maeghan Gale – Policy Director – Government Relations, at mgale@naifa.org
NAIC November Highlights
November was a busy month at the NAIC. Here are a few highlights from the committees, task forces, and working groups that met in November.
The NAIC 2021 Fall National Meeting will be held in San Diego, CA from December 11th – 16th, 2021. NAIFA will be attending, and you can find an update in next month’s GovTalk.
As we welcome in the new year, we will also welcome new NAIC President - Director Dean Cameron of Idaho (former NAIFA member). Director Cameron has already shared that he is looking for a more streamlined approach and we look forward to a productive 2022 at the NAIC.
NAIFA Staff Contact: Maeghan Gale – Policy Director – Government Relations, at mgale@naifa.org
Remote SECURE Notarization fails in the U.S. Senate
Over the last several weeks and months, NAIFA worked closely with industry partners to find a path forward for the SECURE Notarization Act as part of the National Defense Authorization Act (NDAA). Ultimately, these efforts came up short, as a combination of process challenges in the Senate imperiled most of the non-defense provisions coming out of the House, along with negotiations between Senators stalling the process of inclusion in NDAA.
Previously, on September 23, the House of Representatives passed its version of the fiscal year 2022 National Defense Authorization Act by a bipartisan 316-113 margin. Legislators inserted the Secure Notarization language in an attempt to ease the remote notarization burden on members of the military. NAIFA worked with legislators on an amendment to broaden the scope of the legislation to include all Americans.
This amendment provides all Americans additional flexibilities and options for executing critical life documents, including for real estate transactions, wills, and health care directives using remote online notarization (RON). The text of the amendment is taken from H.R. 3962, the SECURE Notarization Act, which had the strong, bipartisan support of 53 cosponsors, and it builds upon language included in the underlying bill by Representative Turner to modernize military notary services.
The last year has demonstrated how technology can be leveraged to modernize services across a variety of markets. Notarizations are widely used for real estate, financial services, and other legal documents. RON allows the consumer, notary, and other parties to a transaction to be in different locations using two-way audiovisual communication to securely notarize documents. This process provides assured consumer access to notarization, allows for flexible scheduling, and affords consumers time to review documents and proceed when they are ready to sign.
Prospects: Despite our efforts to get secure notarization across the finish line as part of NDAA falling short, this has been a process full of positive and productive accomplishments that set NAIFA and the industry up well for work going forward. NAIFA has worked hard to help build broad, bipartisan support, educated key Members, staff, and Committees, and helped to develop a strong platform from which to be successful in the future.
NAIFA Staff Contact: Maeghan Gale – Policy Director – Government Relations, at mgale@naifa.org
NAIFA Testifies at NCOIL Annual Meeting on Senior Financial Protection
On Nov 19th, 2021, NAIFA Policy Director Maeghan Gale and Director Government Relations, Michael Hedge testified before the Life Insurance & Financial Planning Committee at the National Council of Insurance Legislators (NCOIL) 2021 Annual Meeting in Scottsdale AZ. The pair spoke of the importance of recent Federal and State efforts to protect vulnerable seniors, including NAIFA’s advocacy work on the Senior Safe Act and the importance of producer immunity for reporting efforts. On the State side, Gale spoke on the North American Securities Administrators Association (NASAA) Model to Protect Vulnerable Adults from Financial Exploitation, its adoption status across the states, and NAIFA’s proposed variations from the modeling, including a voluntary and firm-level reporting process.
NAIFA Staff Contacts: Maeghan Gale – Policy Director – Government Relations at mgale@naifa.org; or Michael Hedge – Director – Government Relations, at mhedge@naifa.org
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