Recommended Approach for Setting Regulatory Risk-Based Capital Requirements for Variable Products with Guarantees (Excluding Index Guarantees) Reno, NV – March 2002 We reviewed the request and agreed that more sensitivity to the specifics of product design and funding strategy is appropriate to advance the goal of differentiating weakly capitalized companies from the rest. We have defined C-3 risk to include Asset/Liability risk in general, not just interest rate risk. Background: 3