CHICKEN NOODLE SOUP HAS ALWAYS BEEN ONE OF MY FAVORITE COMFORT FOODS. But even with a child’s disdain for vegetables, there was something appealing about Campbell’s vegetable alphabet soup. Perhaps there’s an unexplainable urge to turn individual letters into words. Somewhere along the road, the urge seems to morph as we turn words into letters. There is the dreaded ASAP in a memo from our supervisor. The joy of TGIF. A new generation has added BFFs and FWIW and IMO.

My term on the ABCD is ending, and as I reflect on my experiences, perhaps the most disappointing is what seems to be an almost universal dread of the Actuarial Board for Counseling and DISCIPLINE (emphasis added). I can think of several kinder, gentler phrases for the ABCD acronym. What about Any Body Can Discuss? Or A Bitter Concern is Debunked? Maybe Anyone Bothered Can Debate?

While most practicing actuaries focus on the Discipline function, a less intimidating primary function of the ABCD is to provide a Counseling resource to actuaries who want to discuss their own views or questions—that is…more letters…to address Requests for Guidance (or RFGs). Each year, the ABCD handles around 100 calls from actuaries on a diverse set of issues and questions.

Many requests come from newly credentialed actuaries, primed by their training to take their professional obligations seriously. However, some of the most troublesome violations of the Code of Professional Conduct (the Code) seem to come from more senior actuaries—perhaps overconfident based on their years of experience. This pattern of violations should be a warning to all practicing actuaries to stay up to date on their professional obligations. Each RFG call begins with an ABCD member reviewing the ground rules for any discussion:

1. The guidance provided is the individual ABCD member’s opinion, and they do not speak for the entire Board.
2. All discussions will be kept confidential.
3. The ABCD member will summarize the conversation and share it with the other Board members, who will also maintain confidentiality. If other Board members have different opinions or additional comments, there will be a subsequent discussion with the actuary who requested guidance.

The RFGs range across all practice areas and cover a variety of topics. The ABCD is frequently asked questions about the qualifications to perform certain assignments. The questions are usually addressed by reviewing the United States Qualification Standards (USQS)— more letters in the soup. Importantly, the USQS outlines both basic education and continuing education requirements.

In addition, it is important for actuaries to adhere to the USQS Subject Area Knowledge requirements—specifically, the FSA or FCAS credentialed actuary should have successfully completed education relevant to the subject area, or have at least one year of responsible actuarial experience in the particular subject area. Alternatively, an actuary who has not attained their FSA or FCAS credential should have at least three years of responsible experience in the subject area.

Regardless of the details, the ABCD guidance will almost certainly include a discussion of the particular request for guidance in light of the USQS and advise the actuary that he or she needs to make the ultimate decision as to their ability to perform the service requested of them.

The Board also receives a number of calls with respect to the Actuarial Standards of Practice (ASOPs), particularly when an ASOP is updated. As with the USQS, words are important. It is often said that no one wants to see how law or sausage is made. I believe the reverse is true for the ASOPs. The various practice committees discuss and debate the exact language to describe appropriate standards of practice for our profession. The committee’s proposed language is then submitted to the Actuarial Standards Board (ASB), and the ASB reviews the ASOP for consistency across practice areas, and to ensure it outlines appropriate actuarial practice. An ABCD member can help you determine what actions you need to take to comply with the standards.

Another common question relates to the Code’s Precept 13: when is an actuary required to disclose violations of the Code to the ABCD? Precept 13 makes clear that two conditions are essential in determining whether disclosure is required. Is the apparent violation unresolved and is it material? The Precept also provides that the actuary with a concern can approach the other actuary to discuss the concerns or issues and attempt to resolve the apparent violation directly with the other actuary. As with other RFGs, ultimately the decision to report or not report an apparent violation rests with the actuary. However, a discussion with an ABCD member can be helpful in making that decision. (See Up to Code in Contingencies, July/August 2007, on Precept 13.)

If the ABCD receives a complaint from an actuary or other party, the other major function of the ABCD begins. The Chairs will perform an initial review of the complaint and may decide to appoint an investigator to gather more information. The investigator will interview the subject actuary and other interested parties and provide a written report to the whole ABCD. The subject actuary will be provided an opportunity to respond to the investigation report and to the investigator and directly to the ABCD if a hearing is deemed appropriate. Ultimately, the ABCD has four options of resolution:

1. Dismiss the complaint.
2. Dismiss the complaint with guidance.
3. Recommend counseling for the subject actuary (counseling is provided in both written form and with an in-person session with designated ABCD members).
4. Recommend discipline for the subject actuary.

It is important to recognize that, while the ABCD’s name includes Discipline, the Board does not actually discipline subject actuaries. Instead, the Board may recommend discipline to the member organizations of the subject actuary—the Academy, SOA, CAS, ASEA, and CCA. Each of those organizations has their own disciplinary bodies and review process, with those organizations holding the ultimate authority to assess either private or public discipline for the subject actuary. The transition of responsibility from the ABCD to the member organization is a common misunderstanding among actuaries, but one that reinforces the shared role all member organizations in the U.S. play in complying with the code of conduct and supporting the important work of the ABCD.

While common themes occur in the course of our professional lives, we need to remember that nothing is ever set in stone. Campbell Soup Company is rebranding as The Campbell’s Company. Another childhood favorite, Post Alpha-Bits cereal, is no longer easily found in the supermarket aisles. And while many actuarial questions may first appear to be simple, actuaries, both newer and more experienced, should never hesitate to reach out to the ABCD for guidance and support. We—or as my term ends, they—look forward to hearing from you. And you can be assured that any call will be confidential and will be dealt with respectfully and thoughtfully.

Tales From the Dark Side’ Offers Inside Look at the ABCD
Each December for the past several years, the Academy has held “Tales From the Dark Side” professionalism webinars, offering case studies that have come before the Actuarial Board for Counseling and Discipline (ABCD). The series, which has become popular in part for the valuable year-end continuing education credit it offers, features ABCD members who outline actual (anonymized) case studies that can be at times enlightening, and at other times frightening. (Hence, the name.) “Tales” and other webinar recordings are available as a member benefit via Academy Learning.