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Variable Annuities Issues Working Group, American Academy of Actuaries
Nov. 15, 2016
"Acceptance of any proposal should be based on whether the proposal will remove incentives for companies to use captives for their variable annuity business. It should be verified through testing that none of the proposals add conservatism beyond that required for statutory reserves, since such provisions will continue to provide these incentives.... [S]everal additional areas in the proposal ... require regulatory approval."
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