The Life Actuarial (A) Task Force (LATF) is requesting comments on the Concept for Starting Asset Allocation exposure.

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 has undertaken to address the selection of starting assets used in Principle-Based Reserve (PBR) calculations. We believe that modeled assets should be reasonably consistent with the assets a company actually holds and the investment practices it follows in managing the applicable business.