Life Operational Risk Work Group comments to the NAIC's Operational Risk (E) Subgroup on proposed operational risk factors and growth charge for the life risk-based capital (RBC) formula. Appendix attached.
( )SVL Interest Rate Modernization Work Group comments to the NAIC's VM-22 (A) Subgroup on its exposure draft on the VM-22 maximum valuation interest rates for income annuities.
( )SVL Interest Rate Modernization Work Group comments on valuation rate buckets to the NAIC's VM-22 (A) Subgroup on its exposure draft on the VM-22 maximum valuation interest rates for income annuities.
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