7 pages. Excerpt: "If there are technical issues that can not be addressed for whatever reason, we would encourage CCIIO to provide specific instructions on how to work around those technical issues.... [If] CCIIO plans to make URRT data or actuarial memoranda transparent to the public, it might help to consider adding to the instructions the specific location at which this information will be posted.... We recommend CCIIO create instructions and allow $0 experience values for brand new carriers with no previous experience.... The proposed accounting treatment of the reinsurance premium (assessment) for small groups is as an administrative expense. However, proposed accounting treatment of reinsurance premium (assessment) for the individual market is as a negative premium."