The Life Actuarial Task Force (LATF) is requesting comments on the American Academy of Actuaries’ VM-20 Spread and Default Methodology Review.

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

We appreciate the work LATF and the Academy have undertaken to evaluate whether the current VM-20 methodology continues to provide an appropriate balance among economic realism, prudence, transparency, consistency, and regulatory practicality.