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  • Comment Detail

  • Date: 08/17/20
    First Name: Jonathan
    Last Name: Glowacki
    Organization: Milliman
    City: N/A
    State: N/A
    Attachment: View Attachment
    Number: RIN-2590-AA95

  • Comment

    The proposed capital rule results in uneconomical capital charges for CRT and does not fully recognize the benefits of CRT as an effective source of capital. We recommend adjustments to the framework to recognize the benefits and loss absorbing capacity of CRT.