The National Association of Insurance Commissioners (“NAIC”) Group Capital Calculation Working Group (“GCCWG”) is evaluating potential approaches for aggregation of capital at the insurance group level (“RBC Aggregation Approach”), in particular for groups with U.S. as well as non-U.S. businesses. The RBC Aggregation Approach would build on existing legal entity capital requirements where they exist rather than developing replacement/additional standards. In selecting this approach, it was recognized as satisfying regulatory needs while at the same time having the advantages of being less burdensome and costly to regulators and industry, respecting other jurisdictions’ existing capital regimes, and likely being the quickest approach to develop and implement. During the April 3, 2016 NAIC National Meeting in New Orleans, the American Council of Life Insurers (“ACLI”) gave a presentation on “An Aggregation & Calibration Approach to Insurer Group Capital.” We believe that this presentation provides an excellent foundation, particularly the guiding principles.

RRC appreciates the opportunity to offer our comments. Should you have any questions, we would be glad to discuss our comments with you and the GCCWG members.