the capital charges for individual risks are defined by an explicit calibration point, but aggregate RBC in the US RBC formulas is based on the sum of the capital charges for each of the individual risks with an offset for assumed risk correlation. In addition, we have identified some risks that are not covered by the current formulas. We look forward to discussing our responses with the SMI RBC Subgroup in more detail. Please contact Craig Hanna at 202.223.8196 for scheduling. Sincerely,
Mary Frances Miller President, American Academy of Actuaries cc: Kris DeFrain, Dan Swanson, Alex Krutov, Tim Wisecarver, Donna Novak, Tom Wildsmith, Nancy Bennett, Art Panighetti, Henry Siegel, Craig Hanna
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