Report of the VA CARVM Survey Results of the American Academy of Actuaries Variable Annuity Reserve Work Group

Similar documents
The Financial Reporter

Report of the American Academy of Actuaries Variable Annuity Reserve Work Group

Advanced Seminar on Principle Based Capital September 23, 2009 Session 1: C3P3 Overview

Product Development News

Katie Campbell, FSA, MAAA

Consistency Work Group September Robert DiRico, A.S.A., M.A.A.A., Chair of the Consistency Work Group

Comments of the American Academy of Actuaries Variable Annuity Reserve Work Group

The New Risk-Based Capital

October 16, The Honorable Nick Gerhart Chair, Variable Annuities Issues (E) Working Group National Association of Insurance Commissioners

Modeling Report On the Stochastic Exclusion Test. Presented by the American Academy of Actuaries Modeling Subgroup of the Life Reserves Work Group

Report of the VAGLB Work Group To the NAIC s Life and Health Actuarial Task Force Nashville - March, 2001

Report on Principles-Based Reserves for Participating Whole Life From the American Academy of Actuaries Life Reserves Work Group Modeling Team

Actuarial Guideline VA CARVM

PRACTICE NOTE FOR THE APPLICATION OF C-3 PHASE II. September 2006

Major Areas of Life & Health Activity

Comments on the Corporate Governance for Risk Management Act

PBA Reserve Workshop What Will PBA Mean to You and Your Software? Trevor Howes, FCIA, FSA, MAAA. Agenda. Overview to PBA project

MEMORANDUM. Bruce Friedland, Chair, American Academy of Actuaries Variable Universal Life Subgroup

PRACTICE NOTE FOR THE APPLICATION OF C-3 PHASE II AND VACARVM

11/17/2009. Introduction. Outline. Principles-Based Reserving Education Session 7:30-9:00 Maryland Ballroom D. NAIC 2009 Fall National Meeting

REPORT ON ANNUITY SUPPORTABILITY OF THE DISCLOSURE WORKING GROUP OF THE COMMITTEE ON STATE LIFE INSURANCE ISSUES

ADDENDUM I TO THE PRACTICE NOTE FOR THE APPLICATION OF C-3 PHASE II AND ACTUARIAL GUIDELINE XLIII. December 2009

RE: Comment Letter on APF to Keep Term and ULSG Separate in VM-20 Calculation to Reduce Allocation Concerns

Dave Sandberg Vice President for Life, American Academy of Actuaries

PBR Regulatory Update and Implementation Challenges

NAIC s Center for Insurance Policy and Research Summit: Exploring Insurers Liabilities

Session 39 PD, Non-Variable Annuity PBR Update. Moderator: James W. Lamson, FSA, MAAA

Asset Adequacy Analysis Whys and Hows William M. Sayre December 5, 2003

US Life Insurer Stress Testing

Article from: Small Talk. June 2009 Issue No.32

American Academy of Actuaries C3 Life and Annuity Capital Work Group Response to Comment Letters regarding September 2009 C3 Phase III Report

May Link Richardson, CERA, FSA, MAAA, Chairperson

12/11/2008. Gary Falde, FSA, MAAA Vice-Chair, Life Reserve Work Group Chair, LRWG Asset Subgroup

The Application of C3 Phase II and Actuarial Guideline XLIII July 2009

Principle Based Reserves

Please contact Bill Rapp assistant director of Public Policy at the Academy, if you have any questions.

SEPARATE ACCOUNTS LR006

Scenario and Cell Model Reduction

Re: VAIWG Exposure of Proposed Changes to Actuarial Guideline 43 and C-3 Phase II

Stochastic Modeling Concerns and RBC C3 Phase 2 Issues

Modified Coinsurance (MODCO) & Funds Withheld Reinsurance Issues in RBC

PBR in the Audit: What to Expect Michael Fruchter, FSA, MAAA Emily Cassidy, ASA, MAAA

Presented to the National Association of Insurance Commissioners Life and Health Actuarial Task Force. San Antonio, TX December 2006

Session 04PD: Statutory Life and Annuity Issues. Moderator: Thomas A Campbell FSA,MAAA,CERA

Report of the Joint Risk-Based Capital Work Group To the NAIC Risk-Based Capital (E) Task Force Atlanta March 2003

Dave Sandberg, FSA, MAAA Vice President, Life Practice Council

Report from the American Academy of Actuaries Economic Scenario Work Group

RBC C3 Phase II Seminar ACSW Spring Meeting 6/10/2005

Revised Life Risk-Based Capital Instructions for C-1 Risk for Modified Coinsurance and Funds Withheld.

The Financial Reporter

The American Academy of Actuaries' Life Risk-Based Capital Task Force prepared this report.

Report of the American Academy of Actuaries C3 Life and Annuity Capital Work Group On RBC C3 Requirements for Life Products

NAIC VA Reserve and Capital Reform: Overview of Proposed Revisions. Aaron Sarfatti

Response to FASB Invitation to Comment, Valuation Guidance for Financial Reporting

Report of the American Academy of Actuaries Annuity Reserves Work Group

Session 14PD: Non-Variable Annuity PBR: Let's Set Valuation Rates Daily! Moderator: Amber Ruiz FSA,MAAA

TaxNewsFlash. The IRS released a directive (LB&I (August 24, 2018)) to address the IIR project.

Response to Society of Actuaries Analysis of Proposed Principle-Based Approach From the American Academy of Actuaries Life Reserves Work Group

Principle Based Reserves Ohio Chapter IASA. November 21, 2016 Columbus, OH

Re: Pre-consultation comments on draft ICP revisions 4, 5, 7 and 8

July 16, Dear Mr. Yanacheak,

Session 021 TS - U.S. Statutory Update: Annuities. Moderator: Simpa A. Baiye, FSA MAAA

Background Information

NON-VARIABLE ANNUITY PBR UPDATE

Limited Guidance for Selecting Reasonable or Acceptable AVMs

July 14, RE: Request for Feedback on the IAIS MOCE Proposal and the C-MOCE. Dear Tom,

Post-NAIC Update/PBA Webinar

Are We Ready For PBR

ASOP No. 41: Actuarial Communications and the Actuarial Standards Board

STATUTORY STATEMENTS OF OPINION NOT INCLUDING AN ASSET ADEQUACY ANALYSIS BY APPOINTED ACTUARIES FOR LIFE OR HEALTH INSURERS

Date: June 3, Lou Felice, Chair, NAIC Capital Adequacy (E) Task Force

Presented to the National Association of Insurance Commissioners Life and Health Actuarial Task Force. April 2006

Practical Advice on PBR Implementation Where are we, and how are companies preparing?

Session 10, Statutory Life and Annuity Valuation Issues. Moderator: Donna R Claire FSA, CERA, MAAA

Practice Note Addendum: Compliance Actuarial Guideline XLIX

NAIC Life and Health Actuarial Task Force

NAIC Life and Health Actuarial Task Force. Academy Annuity Nonforfeiture Implementation Work Group

Research Report. Premium Deficiency Reserve Requirements for Accident and Health Insurance. by Robert W. Beal, FSA, MAAA

RECORD, Volume 30, No. 3 * Annual Meeting and Exhibit New York, NY October 24-27, 2004

PBR for Regulatory Actuaries

LONGEVITY RISK TASK FORCE UPDATE

Session 61 L, Economic Scenario Generators: Risk-Neutral and Real-World Considerations from an Investment Perspective

REPORT OF THE JOINT AMERICAN ACADEMY OF ACTUARIES/SOCIETY OF ACTUARIES PREFERRED MORTALITY VALUATION TABLE TEAM

Session 18, Non-Variable Annuity PBR Update. Moderator: John R Miller FSA, MAAA. Presenters: Corinne R Jacobson FSA, MAAA Michael C Ward FSA, MAAA

Analysis of Proposed Principle-Based Approach

Post-NAIC Update/PBA Webinar

Contingent Deferred Annuities Solvency & Risk Management Issues

Re: Proposed Operational Risk Factors and Growth Charge for the Life RBC Formula

Investment Symposium March F7: Investment Implications of a Principal-Based Approach to Capital. Moderator Ross Bowen

RE: July 24th, 2017 comment letter from the American Academy of Actuaries regarding April 9, 2017 Real Estate Equity RBC Proposal

Re: ASB Comments Comments on Second Exposure Draft of the Modeling ASOP

A MERICAN ACADEMY of ACTUARIES

Sara Richman, Vice President, Products, Great-West Life & Annuity Insurance Company

Session 20 WS, Life Illustrations. Moderator: Donna Christine Megregian, FSA, MAAA

Presented to the National Association of Insurance Commissioners Life Risk-Based Capital Working Group September 2000 Dallas, TX

November 6, Variable and Indexed Annuities in QLACs. Dear Mr. Iwry:

Comments on the Exposure Draft of the Proposed Revision of Actuarial Standard of Practice Number 4

Stochastic Analysis Of Long Term Multiple-Decrement Contracts

January 30, Harlan Weller Government Actuary Department of the Treasury 1500 Pennsylvania Avenue, NW Room 4024 Washington, DC 20220

PBA DON T YOU JUST LOVE IT!

Transcription:

Report of the VA CARVM Survey Results of the American Academy of Actuaries Variable Annuity Reserve Work Group Presented to the National Association of Insurance Commissioners Life and Health Actuarial Task Force Washington, DC June 2006 The American Academy of Actuaries is a national organization formed in 1965 to bring together, in a single entity, actuaries of all specializations within the United States. A major purpose of the Academy is to act as a public information organization for the profession. Academy committees, task forces and work groups regularly prepare testimony and provide information to Congress and senior federal policy-makers, comment on proposed federal and state regulations, and work closely with the National Association of Insurance Commissioners and state officials on issues related to insurance, pensions and other forms of risk financing. The Academy establishes qualification standards for the actuarial profession in the United States and supports two independent boards. The Actuarial Standards Board promulgates standards of practice for the profession, and the Actuarial Board for Counseling and Discipline helps to ensure high standards of professional conduct are met. The Academy also supports the Joint Committee for the Code of Professional Conduct, which develops standards of conduct for the U.S. actuarial profession. Variable Annuity Reserve Work Group Thomas A. Campbell, F.S.A., M.A.A.A., Chair James W. Lamson, F.S.A., M.A.A.A., Vice-Chair Richard A. Combs, F.S.A., M.A.A.A. Andrew D. Eastman, F.S.A., M.A.A.A. Larry M. Gorski, F.S.A., M.A.A.A. John O Sullivan, F.S.A., M.A.A.A. James F. Reiskytl, F.S.A., M.A.A.A. Van E. Villaruz, F.S.A., M.A.A.A.

VA CARVM Survey Results: There were a total of 61 responses. Two duplicate responses were from the same company, only one of which was counted. Two surveys were not counted as they had incomplete or inapplicable responses. Therefore, the results detailed below are from a total of 58 companies submitted by 45 individuals. - A total of 42 companies responded yes to question 1. A total of 16 companies responded no to question 1. - A total of 24 companies responded yes to question 2. A total of 34 companies responded no to question 2. - Of those that responded no to question 1, they answered 1b as follows: o 9 companies chose 6/30/2007 o 5 companies chose 12/31/2007 o 1 company chose 3/31/2008 o 1 company chose 12/31/2008 - Of those that responded no to question 2, they answered 2b as follows: o 1 company chose 3/31/2007 o 17 companies chose 6/30/2007 o 1 company chose 9/30/2007 o 13 companies chose 12/31/2007 o 1 company chose 3/31/2008 o 1 company chose 12/31/2008 Survey Questions: 1. If AG VACARVM, as it is currently exposed, is adopted by LHATF in June 2006, will your company be ready to calculate reserves using the new methodology for year-end 2006 without substantial deviation from the requirements? a. Comments (optional) b. If the answer to #1 is no, which of the following effective dates will be the earliest date your company will be ready (please check only one box): 3/31/2007? 6/30/2007? 12/31/2007? Other? 2. If AG VACARVM, as it is currently exposed, is adopted by LHATF in September 2006, will your company be ready to calculate reserves using the new methodology for year-end 2006 without substantial deviation from the requirements? a. Comments (optional) b. If the answer to #1 is no, which of the following effective dates will be the earliest date your company will be ready (please check only one box): 3/31/2007? 6/30/2007? 12/31/2007? Other? 3. Additional comments:

ANSWER YES TO BOTH QUESTIONS A total of 24 companies responded yes to both question 1 and 2. Comments: Question #1a: - Yes, with the exception of the Option Valuation part, the calculations are similar to those already required for C3 Phase II. - We use a 3 rd party to do the reserves. We expect that they will be ready. - Yes, we will be prepared to substantially comply with VACARVM. - Yes, [Company name] used the Alternative Method to satisfy C3 Phase 2 requirements, and could use the AM allowed under VACARVM; the Standard Scenario would still have to be implemented (not required under C3P2 with the AM), but we believe that this is feasible. - Yes, [Company name] uses the Alternative Methodology due to low volume of business. Unless there is a significant increase in the volume of VA business, [Company name] will continue to use the Alternative Methodology. - Yes, assuming no major changes to the requirements we will be ready to comply. - We will be using the Alternative Methodology and should be able to comply if the Academy provides the CTE (75) factors on a timely basis. Question #2a: - Yes, but it would be a stretch. Adoption in June 2006 to provide more lead time is significantly more desirable than waiting until September for the outcome. - While additional notice is preferred, we can be prepared. - We use a 3 rd party to do the reserves. We expect that they will be ready. - Yes, we are currently preparing for VACARVM to be effective 12/31/2006, using the currently exposed version. However, the possibility for changes decrease the likelihood of being ready. A potential, possibly large problem would be the risk that our valuation software vendor does not have the capabilities ready in time for year-end. The vendor is only required to have changes made 90 days from adoption of new rules. - Yes, [Company name] uses the Alternative Methodology due to low volume of business. Unless there is a significant increase in the volume of VA business, [Company name] will continue to use the Alternative Methodology. - Yes, assuming no major changes to the requirements we will be ready to comply. - We will be using the Alternative Methodology and should be able to comply if the Academy provides the CTE (75) factors on a timely basis. Question #3: - I firmly believe that reserves based on the tails of the distributions of modeled results, WITHOUT MINIMUM SCENARIO OVERLAYS, is the appropriate way to go. CTE 65 reserves based on modeling reveal and make appropriate conservative provisions for risk. I object to arbitrary additional minimum reserve requirements which layer on excess conservatism. - We would require the support of a consulting actuarial firm since it s doubtful that our current actuarial modeling software would be able to perform the necessary testing by 12/31/2006. If we were doing this without assistance, I would not expect to be ready until 12/31/2007.

- We plan to use the Alternative Method. We will be able to comply with the new requirements by year-end 2006 only if that option remains available, with no changes from its current format. - As long as the general methodology of VA CARVM tracks the methodology of RBC C3 Phase II, then differences in assumptions or the level of CTE do not cause major extra effort. - [Company name] is reviewing the full stochastic method for our block of policies. However, we view the Alternate Method as the primary method for compliance and may use the stochastic method if it is developed in time. - Due to complexities of compliance, a 12/31/07 effective date is strongly desired.

ANSWER NO TO BOTH QUESTIONS A total of 16 companies responded no to both question 1 and 2. To question 1b, 9 companies chose 6/30/2007, 5 companies chose 12/31/2007, 1 company chose 3/31/2008 and 1 company chose 12/31/2008. To question 2b, 3 companies chose 6/30/2007, 1 company chose 9/30/2007, 10 companies chose 12/31/2007, 1 company chose 3/31/2008 and 1 company chose 12/31/2008. Comments: Question #1a: - The existence of the option floor requirement and the overall complexity of the Standard Scenario calculation will make it difficult for our company to meet its usual financial reporting deadlines under any circumstances. We believe that we will need to retool the financial close process for our variable annuity business. - Of course, if implementation at 12/31/2006 becomes a requirement, we will somehow find a way to comply; however, we feel that a go decision in less than two months will leave a number of unresolved issues, such as tax compliance and effect on the annual AOM/CFT process, that will complicate the implementation home stretch. We will not have an opportunity to do a relatively full-scale dress rehearsal at 9/30/2006, so that in many respects we will be going live without the benefit of prior quarters experience. We are still adapting to the 12/31/2005 RBC implementation, which was quite positive but for which we prepared steadily for a fifteen-month period during which there were relatively few fundamental changes or fundamental unresolved issues that impacted our company. - No, because complying with C3P2 we had to employ consultants, and we had to test the fixed account in a separate model using C3P1 methodology. I don t see that this simpler treatment of the fixed account is specifically allowed in VACARVM as it was in Appendix 6 of the C3P2 report. I am not aware that vendor software is even available to handle the complexities of several categories of separate account funds along with the investment/reinvestment capabilities for the general account subaccounts of a variable annuity. Also, I don t think the standard scenario capabilities have been built into software yet. - The option value calculation would be impossible to implement in 6 months. - No, I believe there are too many unresolved issues. While I would like to see VACARVM adopted as soon as possible I would prefer we didn t rush the process. We need to do this right. We have the benefit that the new capital requirements are in place. This should give us all comfort that we are holding an adequate amount of capital and reserves. I would be in favor of adoption of VACARVM sometime during 2006, but with a 12/31/07 effective date. - It would require substantial efforts for us to implement it for year-end 2006. - We will not be in a position to perform the option-floor calculations. - I couldn t promise that we would be ready. We are set up to make this type of calculation, but currently we have some logistical problems in getting the reserve calculated and validated in time. The logistical timing issues of model set-up and run-time (with running at least 1,000 scenarios) would have to be solved prior to them. Question #1b: - The 6/30/2007 date is contingent upon a clear definition of the option floor requirement by 12/31/2006. The definition needs to be at least as complete as the Recommendations of the American Academy of Actuaries for stochastic testing. We would need a minimum of 6 months after the final definition is officially adopted by the NAIC. Question #2a: - The existence of the option floor requirement and the overall complexity of the Standard Scenario calculation will make it difficult for our company to meet its usual financial reporting deadlines under any circumstances. We believe that we will need to retool the financial close process for our variable annuity business.

- Of course, if implementation at 12/31/2006 becomes a requirement, we will somehow find a way to comply; however, we feel that a go decision in less than two months will leave a number of unresolved issues, such as tax compliance and effect on the annual AOM/CFT process, that will complicate the implementation home stretch. We will not have an opportunity to do a relatively full-scale dress rehearsal at 9/30/2006, so that in many respects we will be going live without the benefit of prior quarters experience. We are still adapting to the 12/31/2005 RBC implementation, which was quite positive but for which we prepared steadily for a fifteen-month period during which there were relatively few fundamental changes or fundamental unresolved issues that impacted our company. - I don t see the adoption date as mattering if the effective date is still 12/31/2006. - The option value calculation would be impossible to implement in 3 months. Other elements of the calculation would be very difficult, or impossible, to implement in 3 months. - No, I believe there are too many unresolved issues. While I would like to see VACARVM adopted as soon as possible I would prefer we didn t rush the process. We need to do this right. We have the benefit that the new capital requirements are in place. This should give us all comfort that we are holding an adequate amount of capital and reserves. I would be in favor of adoption of VACARVM sometime during 2006, but with a 12/31/07 effective date. - We will not be in a position to perform the option-floor calculations. - I couldn t promise that we would be ready. We are set up to make this type of calculation, but currently we have some logistical problems in getting the reserve calculated and validated in time. The logistical timing issues of model set-up and run-time (with running at least 1,000 scenarios) would have to be solved prior to them. Question #2b: - This 12/31/2007 date is contingent upon a clear definition of the option floor requirement by 6/30/2007. The definition needs to be at least as complete as the Recommendation of the American Academy of Actuaries for stochastic testing. We would need a minimum of 6 months after the final definition is officially adopted by the NAIC. Question #3: - We do not believe that the current Standard Scenario meets the criteria for a floor reserve set by the NAIC. To meet this goal, a floor reserve needs to be reasonably easy to calculate (so that companies can meet reporting deadlines), must satisfy the requirements for a tax reserve, and must not exceed the stochastic CTE (65) reserve except in the unusual circumstance that the Company s actuary is using inappropriate methods or assumptions in the stochastic modeling. The Standard Scenario, as currently fashioned, meets none of these criteria. It is important to note that the C3 Phase 2 calculations are performed annually and that results and certifications are due two moths after yearend. By Contract, reserve calculations are done quarterly and many company internal reporting deadlines are in the 7-15 day range. Therefore, it is important that the time and cost of calculating reserves should be both as simple as possible, yet at the same time yield meaningful information and assurances to insurance regulators and company management. The current Standard Scenario will add complexity and cost, will require a reserve that is far too conservative to be a floor in most cases, and will actually deter the development of principles based methods that are capable of assessing risk in a robust and meaningful way. It is also important to note that the LHATF abandoned discussion of Actuarial Guideline MMMM in 2002 because it used a deterministic scenario that was not capable of assessing company s risk accurately. A deterministic Standard Scenario calculation has the same problem. - We feel the most fundamental problem is not company readiness but rather regulatory community readiness. We would be going live with a principles-based reserve valuation at a relatively early stage in the evolution of principles-based valuation in the US, when much of the valuable governance/oversight infrastructure that can give regulators comfort is still being hammered out, so that some regulators may understandably have a highly defensive posture that may translate into punitive reserve floors and a related tendency to retreat to formulaic or other prescribed solutions. If this implementation were to occur at a later time when the evolution of this infrastructure and the experience with C3 Phase II is more seasoned, there is the possibility that the defensive posture could be somewhat tempered, resulting in a more genuine principles-based reserve framework. By contrast, if the implementation leads to valuation requirements that dwarf the RBC requirements, the overall VA initiative will become highly problematic and will have much greater difficulty recovering from early tarnished perceptions. Similarly if the implementation precedes a clear vision of the tax consequences of the initiative, that will potentially set the stage for resource-intensive company interactions with the IRS in the interests of clarification that will further complicate the industry landscape during the initial effective period.

- I do not think it would be wise to implement VACARVM with an effective date of 12/31/2006. There are too many outstanding issues and this is such a paradigm shift from the current practice that actuaries need time to study the final approved version, software vendors need time to code for it, and companies need time to run some tests with it. The certifying actuary is being asked to do a lot of work in developing assumptions, reviewing revenue sharing agreements, and developing models. Adding a CDHS would just add to the complexity. VACARVM differs from C3P2 in that it must be done every quarter. As such, it is a significantly larger drain on resources than C3P2 is. A better idea would be to implement VACARVM on an illustrative basis for 2007, but still use the current approach for reported reserves. That will allow companies time to really work through the issues without having to be concerned that the first time through the calculations they need to produce certifiable reserves. - We strongly oppose the adoption of the January exposure draft and would ask the Academy to continue to support the December exposure draft. With respect to implementation dates, our valuation staff is fully occupied throughout the first quarter of the year and would be unable to comply with a 3/31 implementation date (in any year). - We prefer to see the adoption in this year but has an effective date next year. - C3P2 has a provision for smoothing the TAR. Without a similar smoothing process for VACARVM the capital and reserve amounts will move at different rates and possibly in different directions leading to possibly volatile and strange capital requirements. LHATF should consider this prior to any adoption. - [Several sentences contain too much identifying information and have been redacted.] Our current reserving processes include cashflow adequacy testing and demonstrations. - Board approval for hedging may prove to be a problem for some companies if AG VACARVM is adopted at the last minute.

ANSWER YES TO QUESTION 1 AND NO TO QUESTION 2 A total of 18 companies responded yes to question 1 and no to question 2. To question 2b, 1 company chose 3/31/2007, 14 companies chose 6/30/2007 and 3 companies chose 12/31/2007. Comments: Question #1a: - Yes. However, our ability to conform with AG VACARVM specifications for 12/31/2006 depends on early final consensus of the specific details regarding the valuation of VAGLBs and the treatment of hedging under the standard scenario method. There appear to be significantly more nuances to the projection and valuation of various guarantees (such as VAGLBs) and the treatment of hedging under the standard Scenario in AG VACARVM than currently exists under the RBC C3 Phase II regulation. The existence of this added complexity may result in significantly more development time being required to implement AG VACARVM than was needed to implement RBC C3 Phase II. - If adopted in June 2006, it would be very difficult, if not impossible, to meet a 12/31/06 reporting requirement. Hurdles for the company include complex products, availability of adequate computing power, incorporation of hedging into valuation models, and availability of sufficient resource to address this project. Consulting help may be required to meet a 12/31/06 reporting requirement and deviations from the requirements would be likely. There would likely be no time for a peer review prior to reserve reporting with this timetable. Due to the above contingencies, a yes/no answer is not adequate to respond to this question. - Yes. Some items may have to be estimated. - To be ready at year-end 2006 our vendor software [Vendor name] would need to be available early enough to allow time for implementation. It is my understanding that [Vendor name] staff are also responding to this survey. Substantial work would be needed for the standard scenario. While it would be difficult but not impossible to be ready at 12/31/06, we would prefer an effective date of 12/31/07. - Yes, provided that NY does not adopt a separate variation of AG VACARVM. - Yes if adopted there really isn t a choice in the matter. In reality, the requirement for fair market valuation would be very difficult to implement, particularly on a seriatim basis. Question #2a: - No. If the new methodology is adopted that late, it will be difficult to implement the necessary changes to the reserve system by the end of 2006. - If adopted in September 2006, meeting the requirements for a 12/31/2006 reporting timetable, without substantial deviation from the requirements, would not be feasible. While the company is working on this project, a full scale effort would not take place until the methodology is finalized and the regulation takes final form. - No, we do not believe it would be possible without substantial estimates. - No, there would not be enough time to implement all the changes in time for year-end. Question #3: - If requirements were adopted in September 2006, it would be unlikely that we would be able to comply with AG VACARVM requirements before 6/30/2007 due to Q1 2007 being occupied with year-end reporting requirements. We would also like to mention the need for early and final consensus to details regarding the AG VACARVM regulations to be implemented. The last minute changes that occurred with the RBC C3 Phase II regulation made implementation for a 12/31/05 deadline challenging. - The more often the proposed rules change and the later in the year the method is finalized, the more difficult it becomes to comply.

SURVEYS DISREGARDED FOR INCOMPLETENESS Two surveys were disregarded because answers were incomplete or answers were not applicable. Survey 1: - Question 1a.: Not applicable because the Company does not offer the product. - Question 2a.: The Company does not plan to offer this type of product. It does plan to offer a Equity Indexed Annuity in 2006. If the AG applies to EIAs, I choose 12/31/2007. Survey 2: - Question 1a.: Our company has no products within the scope of AG VACARVM. - Questions 2a.: Our company has no products within the scope of AG VACARVM.