At the Spring National Meeting, the National Association of Insurance Commissioners (“NAIC”) Group Capital Calculation Working Group (“GCCWG”) exposed a memo from NAIC staff dated February 28th (updated for comments from the March 24th meeting) that included a proposed approach to determining the scope of the group for purposes of applying the group capital calculation. The memo discusses a possible approach to determining scope and poses seven questions upon which the GCCWG is specifically requesting feedback.

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.