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.
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